Seedblink SA ("SeedBlink") acts honestly, fairly, and professionally in the interest of its clients. This document details the types of conflicts of interest that may arise in Seedblink's activities and establishes how Seedblink identifies, monitors, prevents, and manages potential or real conflicts of interest that may arise from the provision of crowdfunding services.
This document identifies the situations, relationships, services, activities, or transactions of Seedblink where conflicts of interest may arise.
SeedBlink maintains and applies effective internal rules to prevent conflicts of interest.
Term
Definition and/or, if applicable, the act defining the term
1. Crowdfunding service
Matching interested investors with project developers through the use of a crowdfunding platform, a service that includes any of the following activities: (i) facilitating the granting of loans; (ii) placing, without a firm commitment as provided in Annex I Section A point 7 of Directive 2014/65/EU, securities and instruments admitted for the purpose of crowdfunding issued by project developers or an investment vehicle, as well as receiving and transmitting client orders, as mentioned in point 1 of the mentioned section, regarding those securities and instruments admitted for the purpose of crowdfunding (Regulation (EU) 2020/1503).
2. Customer
Refers to any investor or project developer, potential or actual, to whom a crowdfunding service provider performs or intends to perform crowdfunding services.
3. Conflict of Interest
A conflict of interest represents a conflict that can arise between the interests of the client and the interests of SeedBlink or those of another employee when carrying out crowdfunding services, in such a way as to affect the interests of SeedBlink's clients. SeedBlink presents the types of conflicts of interest that can occur in its own activity. Typically, a conflict of interest arises when two or more persons have competing interests and there is a duty of diligence or trust between those persons.
4. Close Links
According to Article 4(1) point 35 letter (b) of Directive 2014/65/EU, it represents a situation where at least two natural or legal persons are connected through: (a) participation in the form of ownership, directly or through control, of at least 20% of the capital or voting rights of a company; (b) 'control', namely the relationship between a parent company and a subsidiary, in all cases provided for in Article 22 paragraphs (1) and (2) of Directive 2013/34/EU or a similar relationship between any natural or legal person and an enterprise, any subsidiary of a subsidiary enterprise also being considered as a subsidiary of the parent company that controls them; (c) a permanent link of both or all of them by one and the same person through a control relationship.
The Compliance and Risk Officer has an active role in identifying and monitoring conflicts of interest that may arise in the course of providing crowdfunding services offered by SeedBlink.
Contact details: [email protected];
a) moral integrity;
b) impartiality and non-discrimination;
c) professionalism and transparency;
d) compliance with the provisions of the current legislation;
e) confidentiality;
f) prevention and combating of acts of corruption, money laundering, and financing of terrorism;
g) prudence;
i) avoidance of defamation.
Seedblink takes all appropriate measures to prevent, identify, manage, and disclose conflicts of interest between crowdfunding service providers, shareholders, management board members, their employees, or any other natural or legal person related to them through a control relationship, and their clients or between one client and another client.
Situations in which conflicts of interest may arise in Seedblink's activities include:
8.1 Measures for preventing conflicts of interest related to SeedBlink's staff
In order to avoid a possible conflict of interest, Seedblink's personnel (including management and employees) must be subject to the following obligations:
Seedblink shall ensure that, in such a case, where the persons referred to above in points (a) to (c) invest, they will receive the same information regarding specific crowdfunding projects and that such investments are made under the same conditions as those of other investors and that such persons do not receive preferential treatment. In this respect, Seedblink has implemented the internal procedure regarding transactions carried out within the platforms operated by Seedblink, by the persons referred to in points a) to c).
Seedblink will publicly display on its website that it accepts these individuals as an investor.
8.2. Measures to assure independence
Seedblink has the following measures in place to ensure the necessary degree of independence:
8.3. Measures for the prevention and management of conflicts
Opt-out Rule - Seedblink has no interest in crowdfunding offers on the crowdfunding platform.
Independence rule - all departments and related personnel act independently with regard to the interests of the intended clients.
Information barriers - Seedblink respects the confidentiality of information received about or from customers. Seedblink applies the "need to know" approach. Thus, personal information about clients will only be disclosed internally when it is necessary to obtain a crowdfunding service. In line with this approach, Seedblink limits access to information, controls access to nonpublic information by maintaining information barriers to prevent potential unauthorized access and misuse of nonpublic information and inside information.
Conflict of interest register - the Conflicts of interest register is a register of the types of conflicts of interest involving a material risk of damage to the interests of one or more clients, conflicts that have arisen or could arise in connection with regulated services or activities.
Employee Compensation – Seedblink's remuneration policy prevents remuneration structures that could give rise to conflicts of interest.
Gift Policy - Where gifts are offered, they will be declined by Seedblink employees if they are unreasonable and exceed a maximum value set internally, and create a conflict of interest or perception of conflict of interest.
Communication - Where a (potential) conflict of interest is identified, the proposed procedures and measures should effectively prevent the risk of harm to clients' interests from materializing. Seedblink relies on managing such risks through customer communication and consent only when there is a reasonable belief that such risks cannot be prevented. The client can then decide whether or not to proceed on this basis.
Informing clients of the potential conflict of interest will be done in a timely manner so that they can make an informed decision about the service in the context of which the conflict of interest arises. It shall include a specific and clear description of conflicts of interest and associated risks identified in the context of a particular service, taking into account the profile of disclosed clients, in particular their qualification (sophisticated or unsophisticated investors). The disclosure shall make clear that the organizational and administrative arrangements adopted by Seedblink for the prevention or management of conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to clients' interests are avoided.
The source of the conflict
Risks
Actions to minimise the risks
Accepting gifts offered by customers for financial or non-financial advantage.
Preferential treatment that conflicts with the interests of customers
General principles applicable to Seedblink personnel. Gift Policy
Advising a Seedblink employee for personal financial gain at the expense of the project developer or investor.
Risk of use of confidential information for financial and/or non-financial advantage.
General Principles Applicable to Seedblink Personnel. Information barriers
Acceptance of one of the persons listed in chapter 7, para. 1 of this document , as project developer. That person has an interest in the outcome of a crowdfunding service that is different from the interest of the client.
Preferential treatment of a campaign by members of Seedblink's management bodies and/or employees.
General Principles Applicable to Seedblink Personnel. Independence rule. Escalation towards members of management bodies responsible for effectively managing identified conflicts of interest.
Seedblink's Stake in One of the Crowdfunding Offerings
Risk of acquiring inside information
General principles applicable to Seedblink personnel, in particular Seedblink's management. Non-participation rule
Obtaining Financial and Non-Financial Advantages from the Relationship between Two Seedblink Customers
Risk of acquiring inside information. Risk of earning additional income
General principles applicable to Seedblink personnel. Information barriers
A Seedblink employee is involved in running a related and affinity campaign up to Grade 3
Risk of acquiring inside information
General principles applicable to Seedblink personnel. Information barriers
The emergence of a conflict of interest which cannot be managed by applying reasonable commercial measures.
Reputational risk for Seedblink. Risk of acting contrary to clients' interests
Refusal to act or termination of a campaign when the conflict has been identified before the contractual commitments have been fulfilled and if there are no other obligations.
An employee of Seedblink does not declare a position held outside of employment with Seedblink
Risk of acquiring inside information. Risk of earning additional income
General principles applicable to Seedblink personnel. Compensation of employees
Acceptance of one of the persons listed in sec. 8.1, para. 10 of the present proceedings, as an investor, without making public on the website
Risk of acquiring inside information. Risk of preferential treatment
General principles applicable to Seedblink personnel. Information barriers
Subscription to projects carried out through the Seedblink Platform by persons referred to in point 8.1.9(a) to (c) on the basis of information which has not been made public
Risk of making subscriptions on preferential terms compared to other investors
General principles applicable to Seedblink personnel. Internal procedure regarding employee and management underwritings and transactions within the platforms operated by Seedblink.
Execution of transactions within the Newsletter managed by Seedblink, by persons referred to in point 8.1.9 letters a) to c), based on information that has not been made public
Risk of trading on preferential terms over other investors
General principles applicable to Seedblink personnel. Internal procedure regarding employee subscriptions and transactions and management within the platforms managed by Seedblink.
# 10. Monitoring and review
This document will be reviewed at least annually and material changes will be notified via our www.seedblink.com page. The Campaign Manager is at your disposal with further information on Seedblink's measures to prevent and manage conflicts of interest.
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