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 is designed to provide 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 applicable law, EU Crowdfunding Regulation, CySEC’s CIF Law and CF Directive paragraph 6 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.
• Ensuring appropriate independence for relevant persons engaged in different business activities involving a conflict of interest.

Identification of Conflict of Interest Cases

Crowdbase takes into account the following situations as potential cases of 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 adopted various measures to prevent and manage conflicts of interest, including:

• Separate supervision and segregation of duties/functions.
• Option to refuse the provision of services.
• Implementing Chinese Walls/Management of confidential information.
• Remuneration policies to ensure staff performance does not conflict with clients’ best interests.
• Prohibiting inducements in certain circumstances.
• Equal treatment of clients.
• Independent supervision through the Evaluation Committee and independent Directors.
• Transparency in operations and project selection.
• Prohibition of certain transaction practices.

Procedures & Controls for the Identification and Management of Conflicts of Interest

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

• Ensuring awareness and knowledge of the Policy.
• Compliance Officer decision-making regarding conflicts.
• Monitoring and reporting by the Compliance Officer.
• Immediate notification of potential conflicts to the Compliance Officer.
• Disclosure and management of conflicts when organisational arrangements are insufficient.
• Recording instances of conflicts and maintaining a record of actions taken and consents obtained.

By adhering to these principles, procedures, and controls, Crowdbase aims to ensure that any conflicts of interest are properly identified, managed, and mitigated to protect its clients’ interests and comply with the EU Crowdfunding Regulation and CySEC’s CIF Law.