Policies

Crowdbase conflicts of interest policy

Introduction

Crowdbase is committed to ensuring the fair treatment of its clients and the protection of their interests. This Conflicts of Interest Policy provides information on the arrangements Crowdbase has in place to identify, prevent, and manage conflicts of interest that may arise during the provision of crowdfunding services. Crowdbase complies with the EU Crowdfunding Regulation (ECSPR) (Regulation (EU) 2020/1503) when addressing potential conflicts of interest.

General Principles

Crowdbase has established the following general principles as part of its Conflicts of Interest Policy:

  • Identify circumstances that may give rise to conflicts of interest entailing a material risk of damage to clients’ interests.
  • Establish procedures and measures to manage such conflicts.
  • Ensure appropriate independence for relevant persons engaged in different business activities involving a conflict of interest.

Identification of Conflict of Interest Cases

Crowdbase considers the following situations as potential conflicts of interest:

  • The company, project owner, or crowdfunder is likely to make a financial gain or avoid a financial loss at the expense of a client.
  • The company, project owner, or crowdfunder has an interest in the outcome of a service provided to the client that is distinct from the client’s interest in that outcome.
  • The company has a financial or other incentive to favour the interest of project owners over the interest of crowdfunders.
  • The company receives or will receive from a project owner an inducement in relation to a service provided to the client, other than the standard commission or fee for that service.
  • The company has a financial or other incentive to provide preferential treatment to a member of a group of clients compared to the rest of the group.

Prevention and Management

Crowdbase has implemented the following measures to prevent and manage conflicts of interest:

  • Transparency in platform operations – Crowdbase ensures full transparency in its crowdfunding services by providing clear and accessible information to investors. Details about each campaign, including risk factors, fees, and potential conflicts, are disclosed on campaign pages and throughout the platform.
  • Clear disclosure of relationships – If any person closely linked to Crowdbase (e.g., shareholders, managers, employees) invests in a crowdfunding campaign, this will be fully disclosed on the platform, ensuring all investors are aware.
  • Prohibition of preferential treatment – No investor, project owner, or third party receives preferential access, pricing, or terms that could create conflicts of interest.
  • Independent oversight – Crowdbase’s Investment Committee and Non-Executive Directors oversee the selection of campaigns to ensure fair treatment of all project owners and investors.
  • Refusal to provide services in case of unavoidable conflicts – If a conflict of interest cannot be sufficiently managed or disclosed, Crowdbase reserves the right to decline to offer its services in that specific instance.
  • Ongoing monitoring and compliance reporting – The Compliance Officer actively monitors for potential conflicts of interest, records them, and ensures that appropriate action is taken when necessary.

Procedures & Controls for Identification and Management

Crowdbase has established procedures and controls to ensure that relevant persons can identify and manage conflicts of interest, including:

  • Ensuring awareness and knowledge of this policy among all relevant staff.
  • Compliance Officer oversight in decision-making related to conflicts of interest.
  • Monitoring and reporting by the Compliance Officer to ensure ongoing compliance.
  • Immediate notification of potential conflicts to the Compliance Officer for evaluation.
  • Disclosure and management of conflicts when organisational arrangements are insufficient to eliminate the risk.
  • Recording instances of conflicts and maintaining a log of actions taken and consents obtained.

By adhering to these principles, procedures, and controls, Crowdbase ensures that any conflicts of interest are identified, managed, and mitigated in compliance with Regulation (EU) 2020/1503 to protect its clients’ interests.