Conflict of Interest Policy

Purpose

At Goldman Whites, we are committed to maintaining the highest ethical standards and safeguarding the trust of our clients, partners, and stakeholders. This Conflict of Interest Policy (“Policy”) establishes guidelines to identify, disclose, and manage situations where personal, financial, or other interests may conflict with the interests of the firm or its clients.

Scope

This Policy applies to:

• All employees, officers, and directors of Goldman Whites

• Contractors, consultants, agents, and other representatives acting on behalf of Goldman Whites

Definition of Conflict of Interest

A conflict of interest arises when an individual’s personal, financial, or other external interests may, or may appear to, interfere with their ability to act in the best interests of Goldman Whites or its clients. Common examples include, but are not limited to:

• Holding financial interests in a client, competitor, or supplier

• Personal relationships influencing professional decisions

• Accepting gifts, entertainment, or favors that could compromise impartiality

• Using proprietary information for personal gain

Responsibilities

Employees and Representatives

• Avoid situations where personal interests conflict with firm or client interests.

• Disclose actual or potential conflicts promptly to management or the Compliance Officer.

• Abstain from decisions or actions that could create a conflict without prior approval.

 Management and Compliance

• Review disclosed conflicts objectively.

• Implement strategies to manage, mitigate, or eliminate conflicts.

• Ensure all personnel understand and comply with this Policy.

Disclosure Procedure

1. Identify: Recognize any situation that may constitute a conflict of interest.

2. Disclose: Report the situation immediately to your supervisor or Compliance Officer in writing.

3. Review: Management evaluates the conflict and determines an appropriate course of action.

4. Document: Maintain a written record of the conflict and the resolution.

Acceptable Practices

Some situations may not constitute a conflict if properly disclosed and managed. These include:

• Accepting modest, customary gifts or hospitality that do not influence decision-making

• Investments or financial interests that are immaterial or fully disclosed

• Engagements or activities approved by management that do not compromise professional duties

Consequences of Non-Compliance

Failure to disclose or properly manage a conflict of interest may result in:

• Disciplinary action, up to and including termination

• Legal or regulatory consequences

• Reputational harm to the firm

Review and Updates

This Policy will be reviewed periodically and updated to ensure compliance with applicable laws, regulations, and industry best practices.

Acknowledgment

All employees, officers, and representatives of Goldman Whites are required to acknowledge that they have read, understood, and agree to comply with this Conflict of Interest Policy.