Effective Date: September 21, 2025

Introduction

At Iron Elk Capital Equity Income Fund, LP (the "Fund"), we are committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in all aspects of our operations. As a Delaware limited partnership managed by Iron Elk Capital Advisors, Inc. (the "Investment Manager") and with Iron Elk Capital, Inc. serving as the General Partner, the Fund operates as a private investment vehicle focused on equity income strategies. This Compliance Policy outlines our approach to ensuring adherence to applicable laws, regulations, and ethical standards, protecting investor interests, and fostering a culture of accountability.

This policy is designed to be publicly available on our website to demonstrate our dedication to compliance. It is not intended as legal advice and should be read in conjunction with the Fund's Confidential Private Placement Memorandum (PPM), Limited Partnership Agreement (LPA), Investment Management Agreement (IMA), and Subscription Documents. The Fund is offered exclusively to accredited investors under Rule 506(c) of Regulation D and is not registered as an investment company under the Investment Company Act of 1940. We collaborate with trusted third-party providers to enhance our compliance framework.

Regulatory Framework

Iron Elk Capital Advisors, Inc. as the Investment Manager of the Fund, files as an Exempt Reporting Adviser (ERA) with the U.S. Securities and Exchange Commission (SEC). As an ERA, we are subject to the Investment Advisers Act of 1940 and other U.S. federal securities laws, as applicable. Filing as an ERA does not imply a certain level of skill or training.

We monitor changes in federal and state securities laws, including those administered by the SEC, the Financial Industry Regulatory Authority (FINRA), and relevant state securities commissions. The Fund does not engage in activities requiring registration as a broker-dealer or commodity pool operator, and we adhere to exemptions under the Commodity Exchange Act where applicable.

Compliance Governance and Oversight

The Fund has appointed a Chief Compliance Officer (CCO) responsible for overseeing all compliance matters. The CCO reports directly to the General Partner and collaborates with our third-party providers to implement and review policies.

A Compliance Committee, comprising senior management from the Investment Manager and General Partner, meets periodically to assess compliance risks, review audit findings, and approve policy updates.

Investor Qualification and Onboarding

Interests in the Fund are available only to accredited investors as defined under Rule 501(a) of Regulation D. We verify accreditation through documentation such as financial statements, tax returns, or third-party attestations.

Subscription documents require investors to represent their eligibility and acknowledge risks, as outlined in the PPM and

Subscription Documents.

Prospective investors are subject to anti-money laundering (AML) and know-your-customer (KYC) checks by the fund administrators, including screening against the U.S. Department of Treasury’s Office of Foreign Asset Control (OFAC) sanctions lists and Politically Exposed Persons (PEP) databases

Investment and Trading Practices

Investments are managed in accordance with the Fund's strategies detailed in the PPM, focusing on equities, options, and U.S. Treasuries for long-term value and income generation.

All trades are executed through the Funds prime broker with pre-trade compliance checks to ensure alignment with fund guidelines, including concentration limits and risk parameters.

Risk Management

The Fund employs a multi-layered risk framework, including Sharpe, Sortino, and Calmar ratios as described in our investor materials. The Fund administrator may provide independent risk assessments.

We have also implemented appropriate physical and technological measures to safeguard our systems and sensitive information from being accessed by unauthorized parties.

Privacy and Data Protection

Investor data is handled in compliance with applicable state privacy laws. We do not share personal information without consent, except as required by law.

Reporting and Disclosures

Investors receive periodic reports on performance, holdings, and fees, prepared with the Fund administrators assistance.

Annual audited financial statements are provided by our outside CPA's.

Material changes to the Fund's terms or operations are communicated via amendments to the PPM or LPA to subscribed investors only.

Monitoring, Audits, and Enforcement

This policy is reviewed periodically and or upon significant regulatory changes, with assistance from our outside legal counsel and compliance advisors.

Contact Information

For questions about this Compliance Policy or to report concerns, contact our Chief Compliance Officer at:

Email: [email protected]

Phone: 1-888-217-6032

This policy reflects our unwavering commitment to compliance and investor protection. We reserve the right to update it as needed to reflect evolving regulations or best practices.