While we operate at arm’s length from the government, Kenwood Capital Management is subject to rigorous accountability standards. Accountability is deeply embedded in the Kenwood Capital Management Act as well as in the policies and practices that govern our Board, our executives, and all employees.

Our accountability is ultimately to our public financial stewards, including the U.S. Treasury Secretary and other regional regulatory authorities. This responsibility is fulfilled through a number of specific practices:

• Our public reports are reviewed by the Audit Committee of the Board of Directors, which then recommends them for approval by the full Board. This includes our financial statements and annual report.

• Our annual report is formally submitted to the U.S. Treasury Secretary for presentation to Congress.

• Our financial statements are audited annually by an independent external accounting firm.

• A comprehensive review of Kenwood Capital Management and its oversight framework is conducted every three years by the U.S. Treasury Department and relevant federal authorities.

• The U.S. Treasury Secretary may request a special audit at any time.

• An independent Special Examination of our records, systems, and practices is carried out every six years.

• We host biennial public meetings across multiple regions, where citizens and stakeholder groups may engage directly with our Chair and CEO.

• We maintain a robust, transparent online presence, publishing regular updates that allow stakeholders to monitor Kenwood Capital Management’s strategy, activities, and investment performance.

Beyond these mandated requirements, we set high internal standards for responsible and ethical behavior. Our Code of Conduct, reaffirmed annually by all employees, outlines expectations for integrity and professionalism.

To reinforce this commitment, we have appointed an independent Conduct Review Advisor, currently Sheila Block, an internationally recognized expert in litigation and dispute resolution. Her role, as defined in the Code of Conduct, includes serving as a confidential resource for employees, officers, directors, and external stakeholders on matters related to ethical behavior and professional responsibility.