Measures to prevent conflicts of interest

I. Prevention of conflicts of interest with regard to potential project owners

Invesdor GmbH does not enter into any business relationships with project owners in which Invesdor GmbH or other companies of the Invesdor Group hold shares. 

The following persons will also not be admitted as project sponsors:

• Shareholders who directly or indirectly hold at least 20% of the capital shares or voting rights in Invesdor GmbH,
• Employees of the management or employees of Invesdor GmbH or companies of the Invesdor Group,
• Persons who are closely related to the mentioned shareholders or employees of the management or employees of Invesdor GmbH through control relationships or in a relationship of superordination/subordination similar to a parent/subsidiary relationship. (Close connection within the meaning of Art. 4 (1) No. 35 lit. b of Directive 2014/65/ EU (MiFID / Financial Markets Directive))

Invesdor GmbH has in particular identified the following legal entities as relevant persons giving rise to a conflict of interest:  

• Invesdor INV AG with a 100% shareholding in Invesdor GmbH 
• Versorgungswerk der Zahnärztekammer Berlin K.d.ö.R with a shareholding of more than 20% in Invesdor INV AG
• Invesdor Services SPV 2 Oy with a shareholding of more than 20% in Invesdor INV AG 

If special purpose vehicles are used for a financing project on the platform of Invesdor GmbH, these regulations will be applied accordingly to the special purpose vehicles, so that no financing is offered with special purpose vehicles in which Invesdor GmbH or shareholders with more than 20% of the company shares in Invesdor GmbH, members of the management or employees of Invesdor GmbH or companies of the Invesdor Group or persons closely related to Invesdor GmbH through control relationships (See Art. 4 (1) No. 35 lit. b Directive 2014/65/EU) are involved in the special purpose vehicle. (See Art. 8 (2) ECSP Regulation).

II. Prevention of conflicts of interest with regard to investing persons 

The possibility to invest in any offered crowdfunding projects on the crowdfunding platform of Invesdor GmbH exists in unrestricted form also for shareholders, members of the management and employees of the Invesdor Group as well as persons closely associated with the Invesdor Group within the meaning of Art. 4 (1) No. 35 lit. b of Directive 2014/65/EU (MiFID). 

Persons of these groups are only allowed to invest in offered crowdfunding projects if they go through the same automated investment process with the same rules that is also available to other investors of the platform as the only opportunity to invest in crowdfunding projects offered on the platform of Invesdor GmbH. This ensures that an investment is only possible under the same conditions as for other investors on the platform. 

Due to the automated investment process, it is also not possible for persons of the mentioned groups to obtain privileged access to crowdfunding offers. Investments on the platform of Invesdor GmbH without using the automated investment process are not possible. 

All relevant information for an investment regarding crowdfunding offers are published on the platform of Invesdor GmbH and in the corresponding key investment information sheet of the project owner, which also means that there is no privileged access to information on offered crowdfunding projects for the groups of affected persons. 

Invesdor GmbH also monitors whether conflicts of interest may arise from other circumstances not mentioned here and addresses them appropriately. 

III. Procedures to prevent the occurrence of conflicts of interest  

In order to ensure compliance with the regulations set out above, Invesdor GmbH and the other companies of the Invesdor Group hold regular internal training sessions with their employees. 

Employees who are involved in the due diligence process of the project owners are required  to check for any possible involvement of the relevant persons in the project owner (see section 1.) and to report any such involvement immediately. Should a significant participation be identified, the respective project owner will not be admitted to the platform of Invesdor GmbH, so that no conflict of interest can arise in this respect. 

If employees receive privileged information ("insider knowledge") about a project owner due to their field of activity, which is not accessible to other investors from the information on the platform and in particular the key investment information sheet of the project owner, these employees are excluded from an investment in the respective project owner (see section 2.).  As part of the training, all employees of Invesdor GmbH and of the Invesdor Group are informed that own investments due to privileged information are not allowed and may have consequences according to labour law.

Invesdor GmbH ensures equal treatment of investors with the measures outlined here and thereby avoids any positive or negative discrimination.

The named rules are internally evaluated and reviewed at least once a year. 

All processes and regulations for the prevention of conflicts of interest are always kept up to date and are also made available to clients on a permanent data carrier in the investor portfolio for viewing and downloading.

Publication on the website in the Handeling conflicts of interest section ensures that information on dealing with conflicts of interest is disclosed transparently and in a timely manner so that it can be appropriately taken into account in the decision-making process of the investor.