Conflicts of interest shall be understood as all those circumstances that constitute or may give rise to a conflict with a possible detriment or loss of profit for a customer or customers or a profit for a Subject Person or for FELLOW FUNDERS.
Customer means both promoter and investor.
Under the current Conflict of Interest Policy, the following is understood as a Subject Person:
Conflicts of interest may arise between:
Subject Persons must know and comply with the provisions in FELLOW FUNDER’S current Conflict of Interest Management Policy, whose main objectives are:
To identify conflicts of interest that may arise, it will be taken into account if FELLOW FUNDERS or the Subject Persons:
Subject Persons may be subject to potential conflicts of interest by virtue of their family, economic or professional ties or for any other cause with regard to a specific action, service or operation.
For the purpose of this Conflict of Interest Policy:
Subject Persons may not:
The following rules are to be considered in the resolution of conflicts of interest:
If there is any doubt about the remit or how to resolve the conflict, the FELLOW FUNDERS Internal Code of Conduct Control Body may be consulted.
Subject Persons must inform FELLOW FUNDERS’ Internal Code of Conduct Control Body of any situation in which a conflict of interest could arise regarding a specific action, service or operation. Communications must be made in the shortest possible time and, in any event, before making the decision that could be affected by the possible conflict of interest. Subject Persons must keep the above information up-to-date and report any modification or discontinuation of those situations.
The Control Body must update these regulations regarding conflicts of interest based on the experience of conflicts of interest that occurred.
FELLOW FUNDERS, Subject Persons, partners with a significant shareholding in FELLOW FUNDERS, the spouses and persons with whom (both Subject Persons and partners with a significant shareholding) they live in a spousal equivalent relationship, and relatives up to the second degree of consanguinity or family relationship may only take part in projects published on its website in accordance with the following requirements:
FELLOW FUNDERS cannot participate in projects published on other participatory financing platforms.