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I. GENERAL
1.1. This Policy of Avoidance of Conflicts of Interest of GoFundEstate aims to establish theccircumstances related to GoFundEstate’s crowdfunding platform business model which cause or may cause a conflict of interest violating the interests of one or several lenders and/or crowdfunding project owners, as well as the requirements which should be maintained in order to avoid a conflict of interest, and instruments, which are resorted to manage conflicts of interest.
1.2. Management bodies of GoFundEstate are responsible for putting a framework in place, and implementing systems, controls, and procedures to identify, escalate and manage conflicts of interest.
1.3. Under the same circumstances, persons associated with the crowdfunding portal may lend money on equal terms with other lenders.
1.4. Every employee of GoFundEstate is responsible for identifying and escalating potential conflicts of interest so that they may be appropriately managed and resolved.
II. CAUSING OR ABLE TO CAUSE CONFLICTS OF INTEREST
2.1. Seeking to determine potential conflicts of interest that might be able to affect financial interests of lenders and crowdfunding project owners of GoFundEstate, GoFundEstate appoints a team of dedicated employees that should observe the following minimum criteria and assess whether GoFundEstate, or any person associated with GoFundEstate, or any person in a control function directly or indirectly associated with GoFundEstate is exposed to any of the situations listed below, when GoFundEstate or related person:
2.2. Conflicts of interest relating to GoFundEstate can be broadly described as scenarios where:
2.3. Where a conflict of interest may arise, priority should be given to the interests of the lender and/or crowdfunding project owner, then to the interests of GoFundEstate.
III. MANAGEMENT OF CONFLICTS OF INTEREST
3.1. GoFundEstate takes all necessary actions to ensure that the actions taken by GoFundEstate will be exclusively based on the best interest of the lender and/or crowdfunding project owner.
3.2. In the performance of their functions, all employees of or persons related to GoFundEstate must ascertain whether there is any conflict of interest, avoid conflicts of interest or withdraw if there are any potential situations that may cause or provoke a conflict of interest.
3.3. If a conflict of interest arises, participation in crowdfunding transactions may be rendered only if the lender and/or crowdfunding project owner clearly expresses his/her consent concerning the provision of crowdfunding services.
3.4. GoFundEstate takes measures to ensure that:
3.5. GoFundEstate has appointed an employee who periodically monitors and reviews the management of conflicts of interest and the effectiveness of the current procedures. The employee responsible for the management of conflicts of interest must:
3.6. GoFundEstate collects all information that would justify the absence of a conflict of interest, as well as documents and other information that may confirm that the lender and/or crowdfunding project owner was duly informed about the current situation and agrees to further provision of services by GoFundEstate.
3.7. In the event of a conflict of interest, GoFundEstate must inform each lender and/or crowdfunding owner explicitly, clearly and against a receipt, of any conflicts of interest that may have arisen. This information can also be presented by telephone if it is being recorded and can be used as proof.
3.8. GoFundEstate must present information to lenders and/or crowdfunding operators on a durable medium and the information should be clearly understandable to them, in order to make an informed decision on potential collaboration with GoFundEstate, with respect to which a conflict of interest may arise.
3.9. In the event where a conflict of interest arises between several lenders and/or between several crowdfunding project owners, GoFundEstate coordinates such situation in such way that no lender and/or crowdfunding project owner would benefit from another lender and/or crowdfunding project owner.
IV. BREACH OF POLICY
4.1. In the event employee fails to comply with the above-outlined provisions of this Policy will result in disciplinary measures, including dismissal of GoFundEstate’s employee.
4.2. In determining the level of disciplinary measures in any particular case, the seriousness and/or frequency of an offense will be taken into account.
4.3. In addition, employees may run the risk of fines, penalties, judgments, damages, and settlements related to regulatory or legal actions against GoFundEstate and them as individuals.
V. FINAL PROVISIONS
5.1. The Policy must be reviewed and, if required, renewed at least once per year.