Invesco DB Energy Fund

Insider Trading Policy

The Managing Owner hasadopted an Insider Trading Policy, which applies to all of its employees and itself. The Insider Trading Policy operates in concert with the Code of Ethics and Personal Trading Policy for North America (collectively, the “Trading Policies”). The Managing Owner believes that the Trading Policies are reasonably designed to promote compliance with insider trading laws, rules and regulations with respect to the purchase, sale and/or other dispositions of securities, including Shares of the Fund, as well as the applicable rules and regulations of the Exchange. A copy of the Insider Trading Policy is filed as Exhibit 19.1 to this Annual Report on Form 10-K.

The Fund has no employees, officers or directors. The Managing Owner receives a monthly Management Fee of 1/12th of 0.75% per annum of the daily NAV of the Fund at the end of each month.

For the year ended December 31, 2025, the Fund incurred Management Fees of $375,415 of which $349,944 had been paid at December 31, 2025. Management Fees of $25,471 were unpaid at December 31, 2025 and are reported as a liability on the Statements of Financial Condition.

For the year ended December 31, 2025, the Fund incurred brokerage commissions of $15,331 of which $15,331 had been paid at December 31, 2025. There were no unpaid brokerage commissions at December 31, 2025.

For the year ended December 31, 2024, the Fund incurred Management Fees of $527,219 of which $498,459 had been paid at December 31, 2024. Management Fees of $28,760 were unpaid at December 31, 2024 and are reported as a liability on the Statements of Financial Condition.

For the year ended December 31, 2024, the Fund incurred brokerage commissions of $8,004 of which $3,003 had been paid at December 31, 2024. Brokerage commissions of $5,001 were unpaid at December 31, 2024 and are reported as a liability on the Statements of Financial Condition.

For the year ended December 31, 2023, the Fund incurred Management Fees of $729,661 of which $674,832 had been paid at December 31, 2023. Management Fees of $54,829 were unpaid at December 31, 2023 and are reported as a liability on the Statements of Financial Condition.

For the year ended December 31, 2023, the Fund incurred brokerage commissions of $16,336 of which $11,343 had been paid at December 31, 2023. Brokerage commissions of $4,993 were unpaid at December 31, 2023 and are reported as a liability on the Statements of Financial Condition.