Conflicts of Interest

Policy Statement

1.1

It is the policy of CrowdProperty (“the Firm”) to operate with high standards of ethics and integrity in all aspects of its business conduct and to adhere to the principles set out in the FCA Handbook (PRIN) and in particular Principle 8: a firm must manage conflicts of interest fairly, both between itself and its customers, and between a customer and another client.

1.2

CrowdProperty is committed to complying with all applicable laws, rules and regulations in the markets and jurisdictions it operates in, including, but not limited to, the UK Bribery Act 2010 and the FCA Handbook (and COBS in particular).

1.3

This policy is supported and endorsed by the Firm’s Board of Directors and should be read in conjunction with the Firm’s policy on Treating Customers Fairly and Anti-Bribery and Corruption.

Principles

2.1

A conflict of interest is any situation in which an individual or corporation is in a position to unfairly exploit aprofessional or official capacity in order to realize a personal or corporate benefit.

2.2

Corporate conflicts of interest include: mis-selling products and services; abuse of client information; abuse of fiduciary obligations; preferential treatment of one customer at the expense of other customers.

2.3

Personal conflicts of interest include: employees incentivised to take unnecessary risks; employees or directors with conflicting business interests outside of their employment, including charitable or political activity, working for competing businesses or close personal relationships with customers or competitors.

2.4

Disclosure of a conflict of interest does not in itself resolve the conflict, but it enables the necessary steps to be taken to determine how the conflict should be best managed or resolved. CrowdProperty will record all real and potential corporate and personal conflicts of interest and measures taken to resolve it in order to demonstrate that all conflicts of interest have been appropriately identified and managed.

Application

3.1

This policy applies to all permanent, full-time or part-time employees, senior managers, directors, agents, consultants, contractors and any other third parties who perform any form of service on behalf of CrowdProperty.

Risk Control Framework

4.1

CrowdProperty recognises that there is an ongoing obligation to monitor the business to ensure that any new conflicts of interest that arise are documented and controls are put in place to manage them.

The Compliance department will maintain the Conflicts of Interest Log and will, for each actual or potential conflict identified in the inventory:

• Take all reasonable steps to prevent conflicts of interest.

• Implement a written policy and disclose the conflicts to clients.

• Explicitly allocate ownership of the conflict risk.

• Have clear arrangements for dealing with significant or sensitive issues that impact on the reputation or financial stability of the Firm.

• Ensure appropriate disclosures are made.

• Ensure control processes are capable of independent review.

4.2

All directors and employees must promptly disclose all relevant information when circumstances change after an initial disclosure has been made or when new situations arise, sufficient for an appropriate decision to be made on how to manage the conflict.

4.3

The responsibility for disclosure rests with the individual, and this shall be reinforced in directors’ service contracts and employees’ employment contracts.

4.4

The Compliance department will be responsible for issuing and reviewing annual declarations for all employees, which specifically includes disclosure of conflicts of interest.

4.5

Options for resolution can include one or more of the following strategies, as appropriate:

• Divestment or liquidation of interest;

• No involvement in an affected decision-making process;

• Restriction of access by the affected individual to particular information;

• Transfer of the individual to duty in a non-conflicting function;

• Rearrangement of the individual’s duties and responsibilities;

• Assignment of the conflicting interest in a genuinely ‘blind trust’ arrangement;

• Resignation of the individual from the conflicting private-capacity function;

• Resignation of the individual from the Firm;

• Full disclosure.

Obligations on the Firm

5.1

All CrowdProperty employees and relevant third parties (as per section 2.1) must complete mandatory Conflicts of Interest training, as well as any rolespecific training as and when assigned.

5.2

All CrowdProperty employees and third parties (as per section 2.1) must report any known or suspected breaches of FCA Rules or the Firm’s conflicts of interest policies and procedures to either the Head of Compliance or the Whistleblowing Champion.

5.3

Failure to comply with the requirements of this Policy may lead to disciplinary action, up to and including dismissal or regulatory action.