Conflict of Interest Policy

1. Purpose of the Policy

This policy establishes Finesser’s internal rules to prevent conflicts of interest, in compliance with Article 8 of Regulation (EU) 2020/1503.

2. Definition of Conflict of Interest

A conflict of interest arises when circumstances may create a potential detriment to investors or an unfair benefit to Finesser, its representatives, or its business affiliates.

Conflicts of interest may occur between:

• Finesser and its investors, where Finesser's actions may not align with investor interests.
• Two or more investors on the platform with competing interests.
• Finesser and an external party (such as an Investment opportunity or project promoter).

Factors indicating a conflict of interest include:

• Financial gain by Finesser or its representatives at the expense of investors.
• A Finesser representative having a personal interest in a project beyond standard remuneration.
• The favoring of one investor or project over another.
• Receipt of non-standard incentives (monetary or otherwise) that could influence decision-making.

3. Persons Subject to This Policy

This policy applies to all Finesser representatives and their related persons, including:

• Board members and executives.
• Managers, employees, and contractors.
• Direct or indirect partners of Finesser.
• Affiliated entities of Finesser.

Also covered are their related parties, including:

• Spouses, domestic partners, and immediate family members.
• Entities controlled by or benefiting the individual (e.g., private companies they own).

4. Restrictions on Related Projects

To ensure neutrality and fairness, Finesser does not invest in or promote projects where it has a financial interest. Specifically, Finesser will not accept projects where majority of project is owned by:

• Shareholders who own 20% or more of Finesser’s voting rights.
• Executives or employees of Finesser.
• Companies controlled by Finesser representatives.
• Any natural or legal person related to such partners, managers, or employees by control (as defined in Article 4(1)(35)(b) of Directive 2014/65/EU). However, projects where a Finesser related person is a general partner but the ownership restrictions do not fulfil, Finesser may promote the project or invest in it and no direct conflict of interest is seen.

5. Conflict of Interest Oversight

A Control Body within Finesser is responsible for monitoring, identifying, and resolving conflicts of interest. This body must:

• Ensure compliance with this policy.
• Provide guidance on potential conflicts.
• Implement corrective measures when needed.

6. Reporting and Resolving Conflicts

If any individual covered under this policy identifies a potential conflict of interest, they must:

• Refrain from decision-making on the affected matter.
• Disclose the conflict to the Control Body in writing.
• Provide all relevant details for resolution.

The Control Body will assess the situation and determine the appropriate course of action. If the conflict involves a member of the Control Body, the matter will be escalated to Finesser’s governing board.

Guiding principles for resolution:

• Finesser will not prioritize its financial interests over those of investors.
• Fair treatment must be ensured for all investors and project promoters.
• No investor or category of investors shall receive preferential treatment.

7. Transparency to Investors

Finesser will inform investors of:

• The general nature and sources of conflicts of interest.
• The measures in place to prevent and manage such conflicts.

Investors will be notified in a timely and clear manner to allow them to make informed investment decisions.

8. Enforcement & Non-Compliance

Any violation of this policy will result in disciplinary action in accordance with applicable legal and regulatory provisions. Individuals found in breach of this policy may be subject to:

• Suspension or removal from decision-making roles.
• Legal action if the conflict resulted in investor harm.