Conflict of Interest Policy

About Konvi

Konvi is a trading name of Konvi Crowdfunding Limited, an independent Crowdfunding Service Provider. Konvi Crowdfunding Limited, is an Irish company, whose registered number is 683014 and has its registered office at Office 2, 12A Lower Main Street, Lucan, Ireland.

I. GENERAL

1.1. This Konvi Policy on the Avoidance of Conflicts of Interest aims to establish the circumstances related to Konvi’s crowdfunding platform business model which cause or may cause a conflict of interest violating the interests of one or several crowdfunding project owners, as well as the requirements which should be maintained in order to avoid a conflict of interest, and instruments, which are resorted to manage conflicts of interest.

1.2. The Board of Directors of Konvi is responsible for putting a framework in place, and implementing systems, controls, and procedures to identify, escalate and manage conflicts of interest.

1.3. Notwithstanding the provisions of this policy, persons associated with Konvi may invest in projects on equal terms with other investors.

1.4. Every employee of Konvi is responsible for identifying and escalating potential conflicts of interest so that they may be appropriately managed and resolved.

1.5. In this document any reference to crowdfunding project owner, shall also be taken to include any investor in the relevant crowdfunding project.

1.6 Shareholders, managers, employees and natural or legal person linked to those shareholders, managers or employees by control as defined in point (35)(b) of Article 4(1) of Directive 2014/65/EU will be accepted as investors in Konvi crowdfunding projects offered on the Konvi crowdfunding platform. Where such a person invests in a specific crowdfunding project, Konvi shall ensure that such investments are made under the same conditions as those of other investors and that those persons do not enjoy any preferential treatment or privileged access to information.

II. CAUSING OR ABLE TO CAUSE CONFLICTS OF INTEREST

2.1. In seeking to determine potential conflicts of interest that might be able to affect the financial interests of crowdfunding project owners, Konvi has appointed a Chief Risk Officer. The CRO shall, in observance of the following minimum criteria, assess whether Konvi, or any person associated with Konvi, or any person in a control function directly or indirectly associated with Konvi is exposed to any of the situations listed below:

a. may experience a financial advantage or avoid a financial loss at the expense of the crowdfunding project owner;

b. has an interest in the result of the rendered service or in the result of a transaction concluded at the expense of the crowdfunding project owner other than the interest of the crowdfunding project owner;

c. receives or will receive from a person (other than the crowdfunding project owner) an inducement in relation to a service provided to the crowdfunding project owner, in the form of monies, goods or services, other than a standard commission or fee for that service;

d. has a financial or other incentive to favour the investment conditions of a particular project to the crowdfunding project owner which is not in the best interest of them.

2.2. Conflicts of interest relating to Konvi can be broadly described as scenarios where:

a. Konvi favours itself and related persons’ projects over the projects of other crowdfunding project owners;

b. Konvi may assess crowdfunding project owners in a biased and subjective manner, compared to individuals who have direct or indirect links with Konvi;

c. related persons may enter into crowdfunding transactions at their own expense, using the confidential information entrusted to Konvi.

2.3. Where a conflict of interest may arise, priority should be given to the interests of the crowdfunding project owner, rather than to the interests of Konvi.

III. MANAGEMENT OF CONFLICTS OF INTEREST

3.1. Konvi shall take all necessary actions to ensure that the actions taken by Konvi will be exclusively based on the best interest of the crowdfunding project owner.

3.2. In the performance of their functions, all employees of or persons related to Konvi must ascertain whether there is any conflict of interest, avoid conflicts of interest or withdraw if there are any potential situations that may cause or provoke a conflict of interest.

3.3. If a conflict of interest arises, participation in crowdfunding transactions may be rendered only if the crowdfunding project owner clearly expresses his/her consent concerning the provision of crowdfunding services.

3.4. Konvi takes measures to ensure that:

a. Konvi’s interests have no unfair advantage over the crowdfunding project owner’s interests and its actions must be compatible with the crowdfunding project owner’s interests;

b. personal, financial or other interests of Konvi, its managers, employees or other associated persons have no influence or appear to have no influence on the provision of services to the crowdfunding project owner on behalf of the Konvi;

c. the interests of one crowdfunding project owner are not preferred over those of other crowdfunding project owners.

3.5. Konvi has appointed an employee who periodically monitors and reviews the management of conflicts of interest and the effectiveness of the current procedures. The employee responsible for the management of conflicts of interest must:

a. periodically review the provisions of the Policy and ensure the compliance with the requirements of applicable laws;

b. inform the employees and related persons of Konvi, whether a conflict of interest lies in the ongoing situation, as well as advise on how such a situation should be managed;

c. perform any other action aimed at the proper and timely identification and management of conflicts of interest.

3.6. Konvi shall retain any information that would corroborate the absence of a conflict of interest, as well as documents and other information that may confirm that the crowdfunding project owner was duly informed about the relevant situation and agreed to the further provision of services by Konvi.

3.7. In the event of a conflict of interest, Konvi must inform each crowdfunding owner explicitly, clearly and against a receipt, of any conflicts of interest that may have arisen. This information can also be presented by telephone if it is being recorded and can be used as proof.

3.8. Konvi must present information to crowdfunding project owners on a durable medium and the information should be clearly understandable to them, in order to make an informed decision on potential ongoing collaboration with Konvi, with respect to which a conflict of interest may arise.

3.9. In the event where a conflict of interest arises between several crowdfunding project owners, Konvi shall coordinate the unwinding of the situation in such a way that no crowdfunding project owner would benefit preferentially over another crowdfunding project owner.

IV. BREACH OF POLICY

4.1. An employee failing to comply with the provisions of this Policy will be subject to disciplinary measures, which may include measures up to and including dismissal.

4.2. In determining the level of disciplinary measures in any particular case, the seriousness and/or frequency of an offense will be taken into account.

4.3. In addition, employees may run the risk of fines, penalties, judgments, damages, and settlements related to regulatory or legal actions against Konvi and them as individuals.

V. FINAL PROVISIONS

5.1. The Policy shall be reviewed annually.