Conflicts of Interest Policy

A conflict of interest is any situation where what is good for us, or for someone connected to us, might not be good for you. This page explains the ones that can arise here and what we do about them.

Crowdbase Ltd does not participate in campaigns on our own platform

Crowdbase takes no participation in any crowdfunding offer on its own platform. We do not invest in the companies we list, and we take no stake, warrant or other interest in any offer, whether for cash or as part of our fee. This is required by Article 8(1) of Regulation (EU) 2020/1503.

We do not let our own people raise money here

We will not accept as a project owner:

• any shareholder holding 20 per cent or more of our share capital or voting rights
• any of our managers or employees
• any person or company linked to those people by control, as defined in point (35)(b) of Article 4(1) of Directive 2014/65/EU

This applies whoever they are and however good the business is. It is required by Article 8(2) of the Regulation and there is no exception to it.

Our people can invest, and when they do we name them

Our shareholders, managers and employees are allowed to invest in campaigns on the platform.

When one of them invests, we say so on the campaign page, and we say how much. They invest on exactly the same terms as you, at the same price, with the same rights. They get no early sight of information, no preferential allocation and no better deal.

Naming the person and the amount goes further than the Regulation requires, which is to disclose the fact and the specific projects involved.

Early access windows

Some campaigns open to a group of investors a few days before they open to everyone. We call this an early access window.

Anyone can join it. When we announce that a campaign is coming, you can register for early access. Registration is open to every investor on the same terms, and it is not capped. Nobody, including our own people, can invest before the window opens and the email goes out. When it opens, everyone in it gets the same email at the same moment and can see the full campaign and invest.

The terms are identical. Same price, same instrument, same rights, same documents. An early access investor is not buying on better terms. They are buying earlier.

Everyone in the window receives the Key Investment Information Sheet before they can commit anything, and the four calendar day reflection period applies in exactly the same way.

Our shareholders and employees register for early access like everyone else. They go through the same registration, get the same email at the same moment, and invest on the same terms. When they do, we name them and the amount on the campaign page, as we do for any investment by someone connected to us.

Where a campaign can be oversubscribed, orders are filled in the order they are received, up to the maximum stated in the Key Investment Information Sheet. So an early access window can fill a campaign before it opens publicly. If that matters to you, register as soon as we announce.

Where else conflicts can arise

We look in particular for situations where Crowdbase, our shareholders, our managers or employees, or anyone linked to them by control:

• would make a gain, or avoid a loss, at your expense
• have an interest in the outcome of something we are doing for you that differs from yours
• have a reason to favour the companies raising money over the people investing
• are offered something by a project owner beyond our normal fee for a service we provide
• have a reason to treat one group of clients better than another

We also treat our relationship with Crowdbase Nominee Services Limited, which holds legal title to investors’ instruments on nominee-structured campaigns, as a source of potential conflict and manage it under this policy.

What we do about them

Approval is not in one pair of hands. Senior management recommends a campaign. Our Investment Committee approves it. The Committee decides unanimously and its quorum always includes a member who is not part of senior management, so no campaign reaches the platform on the say-so of the people who sourced it.

We keep information separated. Where two people inside Crowdbase are working on things that could pull in different directions, we control what passes between them and they report to different people.

Pay is not linked across conflicting roles. Nobody’s pay is tied to the pay of, or the revenue generated by, a colleague whose work could conflict with their own.

Our Compliance function monitors, records and acts. Anyone at Crowdbase who spots a possible conflict must report it to Compliance immediately. Compliance keeps a register of every conflict identified, what was decided and what was done.

We tell you. We disclose here the general nature and sources of the conflicts of interest we have identified and the steps we take to mitigate them, and we keep this page up to date. Where a specific conflict arises on a particular campaign, we describe that conflict and what it means for you, in enough detail to be useful, before you decide.

And if we cannot manage it, we walk away. Where a conflict cannot be properly managed or properly disclosed, we decline the business.

Questions

If you think a conflict has affected how you were treated, tell us. Our complaints procedure is on this site and using it costs nothing.