Conflict of Interest Policy

Last updated: Dec 13, 2023

This policy describes how Capitalia SE (Capitalia) identifies, prevents, manages, and discloses conflicts of interest of its shareholders, managers, employees, and any natural and legal persons linked to Capitalia. It is published on the Capitalia website.


Parties related to Capitalia:

Conflict of interest

Situations that occur when an employee or a manager of Capitalia is likely to compromise their judgment, decisions or actions at the expense of the client, has an interest in a different service outcome than the client, has the incentive to favor the interests of other clients over the particular client.

Prohibition to issue loans to the Parties related to Capitalia

Parties related to Capitalia are not allowed to be Project owners (including partial ownership of the Project owners) on the Platform.

When a positive committee decision is made, before publishing the project on the Platform, the Project owner is required to sign a Mandate agreement, whereby the Project owner confirms that they are not a Party related to Capitalia and that it has no additional personal interest in acquiring the financing besides the financing purpose, as stated in the Key investment information sheet and Crowdfunding offer form.

In order to avoid a conflict of interest regarding Project owners being a Party related to Capitalia, all employees should declare all legal entities linked to them according to clause (c). During the application evaluation process, Investment managers are required to check if the reviewed Project owner is not included in the file. If it is, the Project owner may not be financed due to a conflict of interest. The employees are required to update the information about their participation in other legal entities on an annual basis.

Conflict of interest rules regarding Project owners

Capitalia employees may not participate in the evaluation of the loan applications or make any decision regarding a Project owner if it would result in a conflict of interest for them. If there is a conflict of interest, the employee must inform their direct supervisor and the case must be forwarded to another employee.

Under no circumstances Capitalia employees are allowed to receive gifts or remuneration from Project owners in order to act favorably for the particular party.

If numerous Project owners operating in the same industry simultaneously apply as Project owners for Capitalia crowdfunding services, the Capitalia Financing department will ensure independent analysis of each project and the Investment committee will use the same Pricing policy for all projects, that way providing equal opportunities regarding financing attraction from the Investors.

Conflict of interest regarding Investors

Capitalia allows the Parties related to Capitalia to register as Investors on the Platform with the additional rules applied as described below.

In order to invest in Capitalia crowdfunding offers, the Parties related to Capitalia will have to undergo the same identification and assessment process as other Investors.

Parties related to Capitalia parties will be granted access to invest only through the Auto-invest function (individual loan portfolio management service). Under no circumstances Parties related to Capitalia parties are allowed to invest in individual loans without the Auto-invest function.

Under no circumstances Capitalia employees are allowed to receive gifts or remuneration from Investors in order to act favorably for the particular party.

By signing an employment contract, the employee undertakes not to disclose to anyone outside Capitalia any information that would provide preferential access to information about Project owners and crowdfunding projects on the Platform

Special rules for Capitalia Investment Holding, AS

Simultaneously with the financing offer publication on the Platform, Capitalia SE-related company Capitalia Investment Holding, AS, invests 2.5% of the target financing amount. The exact Capitalia Investment Holding subscription amount in numerical terms will be declared in the particular crowdfunding offer form and the reflected amount available for Investors to invest already subtracts Capitalia Investment Holding’s investment. Capitalia Investment Holding will have an Investor profile on the Platform like other Investors. Capitalia Investment Holding can stop co-investing in new Projects at any time. Any changes to Capitalia Investment Holding's co-investment policy are disclosed to the registered Investors.

If the minimum target amount is not raised by the time the financing raising period ends, Capitalia Investment Holding is eligible but not obligated to finance the remaining available amount.

Disclosure of information about conflicts of interest

The Crowdfunding offer form for each project states that Parties related to Capitalia are eligible to invest in the project through Auto-invest and states the minimum amount Capitalia Investment Holding invests in the project.

Capitalia also discloses the exact list of projects Parties related to Capitalia have invested in and their total share in each project. This information is renewed once a month and it is available only to registered Investors.