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Conflict of Interest
Handling of Conflicts of Interest - Measures to Avoid Conflicts of Interest
Avoidance of conflicts of interest in connection with (potential) project creators.
CONDA Capital Market does not allow the following individuals to be project creators:
- Own shareholders holding at least 20% of the capital shares or voting rights,
- Members of the management or employees,
- Any person connected by close control relationships or hierarchical relationships to the aforementioned shareholders or employees of CONDA Capital GmbH (definition according to Article 4(1)(35)(b) of Directive 2024/65/EU).
CONDA Capital Market has identified the following legal entities that could result in a conflict of interest:
- CONDA GmbH with a 100% ownership in CONDA Capital Market
- D&D Holding GmbH with a 100% ownership in CONDA GmbH
- Horakel Ventures GmbH with a 42.04% ownership in D&D Holding GmbH
- Tannenberg Partners GmbH (DE) with a 42.04% ownership in D&D Holding GmbH
Additionally, indirectly involved in CONDA Capital GmbH (below 20% ownership):
- EVWB3 GmbH (Share: 7.0299%)
- FMTG - Falkensteiner Michaeler Tourism Group AG (Share: 3.5149%)
- Locker Capital GmbH (Share: 1.7891%)
- Gartner Michael (Share: 0.8946%)
- MeinController GmbH (Share: 0.8946%)
- Turki Karin, Mag. (Share: 0.8946%)
- Tutsch Peter, Mag. (Share: 0.8946%)
Avoidance of conflicts of interest with investing individuals.
Shareholders, members of the management, and employees of CONDA Capital GmbH are not generally prohibited from investing in projects.
To minimize potential conflicts of interest, these individuals are subject to maximum investment limits of EUR 5,000 per offered project.
If a fundamental conflict of interest is identified because one of these individuals invested in a project, the following applies:
For investments < EUR 2,500:
- If relevant, performance-related fees are suspended if a conflict of interest is identified, and the remuneration in connection with the investment gives the impression of a conflict of interest;
- Avoidance of influencing the project/project creator; and
- Avoidance of circumstances that may constitute a conflict of interest.
For investments > EUR 2,500:
- Informational exclusion; and
- Separate supervision of relevant individuals whose main duties involve carrying out activities on behalf of customers or providing services to customers whose interests may conflict, or who otherwise represent different interests that may conflict, including the interests of CONDA Capital GmbH.
General measures to avoid conflicts of interest.
To ensure compliance with rules to avoid conflicts of interest, a due diligence process is conducted as part of the project onboarding. This includes checking for the presence of conflicts of interest.
If employees have privileged information about a project creator that is not available to investors, these employees are excluded from the investment opportunity.
CONDA Capital GmbH also conducts internal training on the topic of conflicts of interest.
The rules for avoiding conflicts of interest are reviewed and assessed annually. Updates are published here and can be viewed.