Conflict of interest policy

Overview

Endenex Limited (“Endenex”) publishes independent repowering and decommissioning cost benchmarks. The company is committed to maintaining high standards of independence, objectivity and methodological integrity in the publication and maintenance of its indices. The Decommissioning Cost Index ("Endenex DCI") family is published as objective, independently produced market intelligence. Any actual or perceived conflict of interest that could compromise the accuracy, integrity, or independence of that intelligence represents a fundamental risk to the company's purpose.

This policy sets out the framework by which Endenex identifies, discloses, manages, and mitigates conflicts of interest. It applies to all employees, contractors, and board members of Endenex, and governs the full Endenex DCI family — including all asset class-specific and market-specific indices — as well as all related data platforms and advisory services.

The policy is designed to align with the IOSCO Principles for Financial Benchmarks on a voluntary basis and to demonstrate robust governance standards to market participants.

Sources of Potential Conflict

Future equity investors

As Endenex grows, it may accept investment from entities that operate in the renewable energy, infrastructure, or decommissioning sectors. Such investors could have a commercial interest in the level or direction of Endenex DCI benchmarks or in the conclusions of advisory engagements.

Mitigation:

• No investor, regardless of equity stake, is permitted influence over benchmark methodology, data inputs, calculation processes, or publication decisions.
• Investment agreements will include explicit independence provisions preventing interference with index publication process.
• Any equity investment by an entity that is also a data contributor, platform subscriber, or advisory client will be disclosed to the Oversight Officer and recorded in the Conflicts Log.
• Endenex will assess each prospective investment for conflict risk before closing and may decline or structure investments to preserve independence.

Data contributors

The Endenex DCI benchmarks rely on cost, technical, and operational data provided by industry participants — including decommissioning contractors, asset operators, recyclers, and logistics providers. These contributors may have an interest in the index reflecting certain cost levels or trends, for example to support commercial negotiations, procurement benchmarks, or reputational positioning.

Mitigation:

• No single data contributor is given visibility into individual submissions by other contributors.
• Benchmark values are calculated using aggregation rules that prevent any single submission from determining the published figure.
• Data contributors do not have access to index values before publication.
• All contributions are verified through Endenex's internal validation processes.
• Contributors are required to submit data in good faith and are informed that deliberate misreporting will result in removal from the contributor panel.

Platform subscribers and advisory clients

Subscribers to the Endenex data platform and clients of advisory services use Endenex DCI data for commercial decision-making — including asset valuation, provisioning, M&A due diligence, and regulatory compliance. These users may have an interest in index values moving in a particular direction.

Mitigation:

• Advisory engagements are conducted independently of index production. Advisory teams do not influence index methodology or publication.
• Advisory outputs are clearly labelled as client-specific analysis and are distinct from published benchmark values.
• Platform subscribers receive the same published data as all other users — there is no preferential access to data, early release, or bespoke index adjustment.
• Client-specific advisory work does not feed back into benchmark inputs unless the data is collected through the standard contribution process and subject to the same validation.

Relationships with industry participants

Endenex employees and contractors may, in the normal course of business, have professional or personal relationships with individuals at organisations that contribute data, subscribe to the platform, commission advisory work, or otherwise participate in markets where Endenex DCI data is used.

Mitigation:

• All employees and contractors are required to disclose relevant relationships as part of the annual conflicts disclosure process.
• Individuals with a material relationship to a data contributor, subscriber, or advisory client are excluded from any role in which that relationship could influence benchmark outcomes.
• Gifts, hospitality, and inducements above a de minimis threshold must be declared and approved in advance.

Identifying Conflicts

Annual disclosures

All employees, contractors, and board members are required to complete an annual conflicts of interest disclosure. This covers financial interests, outside business activities, relationships with industry participants, and any other circumstances that could give rise to a conflict or the perception of one.

Ad-hoc reporting

Any individual who becomes aware of a potential conflict — whether involving themselves or another person — is required to report it promptly to the Governance Officer. This obligation applies regardless of whether the conflict has materialised or is merely perceived.

Pre-transaction reviews

Before Endenex enters into any new advisory engagement, data contribution agreement, platform subscription with an entity that is also a data contributor, or equity investment, a pre-transaction conflicts review is conducted. This review assesses whether the proposed relationship could compromise — or could be perceived to compromise — the independence of index publication.

Raising Concerns

How to report

Any individual may report a conflict of interest concern by contacting compliance@endenex.com.

Conflicts Log

All reported conflicts are recorded in the Endenex Conflicts Log, which is maintained by the Governance Officer and reviewed by the Oversight Officer on a quarterly basis. The register records the nature of the conflict, the parties involved, the assessment of risk, and the mitigation measures applied.

Escalation

Where a reported conflict is assessed as material — meaning it could, if unmanaged, compromise the integrity of a published benchmark or advisory output — it is escalated to the Oversight Officer for review. The Oversight Officer has authority to require additional mitigation, to suspend publication, or to mandate disclosure to affected parties.

Managing and Mitigating Conflicts

Governance and segregation of duties

Endenex maintains a clear separation between the functions responsible for index production, advisory delivery, commercial relationships, and corporate governance. Individuals involved in index calculation and publication are not responsible for commercial negotiations with data contributors or advisory clients.

Procedural controls

All benchmark methodology changes are subject to a documented review and approval process that includes consultation with the Oversight Officer. No single individual has authority to unilaterally alter methodology, suspend publication, or override calculation procedures.

Transparency of methodology

The Endenex DCI methodology is published in full and is available to all market participants. Changes to methodology are communicated in advance, with a rationale provided. This transparency ensures that any deviation from established procedures would be immediately visible to users.

Prohibition on trading and improper influence

Endenex employees and contractors are prohibited from trading, or advising others to trade, on the basis of non-public benchmark information. Any attempt by an external party to influence benchmark values — whether through data manipulation, commercial pressure, or any other means — is treated as a serious breach and reported to the Oversight Officer.

Data security and confidentiality

All data contributed to Endenex for the purpose of index production is held securely and is accessible only to authorised personnel. Contributor-level data is never disclosed to other contributors, subscribers, or advisory clients. The systems and processes governing data storage and access are subject to periodic review.

Material Residual Conflicts

At the date of this policy, Endenex is not aware of any material conflict of interest that has not been identified and mitigated through the measures described above.

In particular:

• Endenex has no equity investors with interests in the decommissioning or renewable energy sectors that could give rise to a conflict.
• No data contributor has a commercial relationship with Endenex beyond the contribution agreement itself.
• No advisory client has preferential access to benchmark data or influence over index methodology.

This position is reviewed on an ongoing basis and will be updated should circumstances change.

Ongoing Review

Review schedule

This policy is reviewed at least annually by the Governance Officer and approved by the Oversight Officer. Additional reviews are triggered by any material change in business activities, ownership structure, or regulatory requirements.

Update process

Proposed amendments to this policy are documented, reviewed by the Oversight Officer, and published to all relevant stakeholders. A record of all amendments and the rationale for each is maintained.

Oversight review

The Oversight Officer conducts periodic reviews of the effectiveness of conflict mitigation measures. The findings of these reviews are documented and any recommendations are implemented within a defined timeframe.

Contact

For questions relating to this policy or to report a conflict of interest, please contact compliance@endenex.com.