Documents

• a) Capitalia shareholders owning at least 20% of Capitalia shares or voting rights;
• b) managers or employees of Capitalia, its related company Capitalia Investment Holding, AS, or Capitalia Fund Management AIFP, SIA;
• c) any natural or legal person connected to the persons referred to in points a) and b) above through control, as defined in Article 4(1)(35)(b) of Directive 2014/65/EU (“relationship between a parent undertaking and a subsidiary, or a similar relationship between any natural or legal person and an undertaking”), such as companies wholly or majority-owned or controlled by voting rights by the persons referred to in points a) and b), and managers or shareholders of the persons referred to in point a).

Situations where a Capitalia employee or manager may alter their judgement, decisions or actions at the client's expense, has an interest in a service outcome different from the client's interest, or has an incentive to support another client's interests over that specific client.

Capitalia related parties are not allowed to be Project owners on the Platform (including cases where a related party would be a co-owner of the Project owner).

If the Investment Committee adopts a positive decision, before the project is published on the Platform the Project owner must sign an Authorisation Agreement in which the Project owner confirms that it is not a Capitalia related party and has no additional personal interest in obtaining financing beyond the financing purpose stated in the Key investment information sheet and the Financing offer form.

To avoid conflicts of interest regarding Project owners that are Capitalia related parties, all employees must declare all legal entities related to them in accordance with point c). During application assessment, Financing specialists must verify whether the reviewed Project owner is listed in that file. If so, the Project owner may be denied financing due to conflict of interest. Employees are required to update information about their participation in other legal entities annually.

Capitalia employees must not participate in assessment of loan applications or make decisions on a Project owner if this would create a conflict of interest for them. If a conflict of interest arises, the employee must inform their direct manager and the case must be reassigned to another employee.

Capitalia employees must under no circumstances accept gifts or remuneration from Project owners to act in favour of a specific party.

If several Project owners operating in the same industry apply simultaneously for Capitalia crowdfunding services, Capitalia's Financing Department ensures independent analysis of each project and the Investment Committee applies the same Pricing Policy to all projects, thus ensuring equal opportunities to attract financing from Investors.

Capitalia allows parties related to Capitalia to register as Investors on the Platform, subject to additional rules as described below.

To invest in Capitalia crowdfunding offers, Capitalia related parties must complete the same identification and assessment process as other Investors.

Access to investments for Capitalia related parties is provided only through the Auto-invest feature (individual loan portfolio management service). Capitalia related parties are under no circumstances allowed to invest in individual loans without the Auto-invest feature.

Capitalia employees must under no circumstances accept gifts or remuneration from Investors to act in favour of a specific party.

By signing an employment contract, an 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.

At the same time as a financing offer is published on the Platform, Capitalia SE's related company Capitalia Investment Holding, AS, invests 1% of the target financing amount. The exact subscription amount of Capitalia Investment Holding, AS, in numerical terms is shown in the specific crowdfunding offer form, and the displayed amount available for Investors already deducts Capitalia Investment Holding, AS's investment. Capitalia Investment Holding, AS, has an investor profile on the Platform the same as other investors. Capitalia Investment Holding, AS, may discontinue co-investing in new projects at any time. Any changes to Capitalia Investment Holding, AS's co-investment policy are disclosed to registered investors.

If the minimum target amount is not reached by the end of the fundraising period, Capitalia Investment Holding, AS, is entitled, but not obliged, to finance the remaining available amount.

The financing offer form for each project states that Capitalia related parties are entitled to invest in the project through Auto-invest and indicates the minimum amount invested by Capitalia Investment Holding, AS, in the project.

Since Capitalia Investment Holding, AS, invests in all projects published on the Platform, an exact list of projects is not published.