Conflict of Interest

Conflict of Interest Policy

This policy aims to establish CIDEH's internal rules for preventing conflicts of interest.

2. Conflict of Interest

For this policy, a conflict of interest means any scenario where an individual or entity could gain an advantage, or a client could suffer a disadvantage, due to competing interests. This applies whether the benefit goes to a Covered Person (as defined below) or to CIDEH itself. In short, if someone stands to gain where a client should be prioritized—or if a client could lose out because of someone’s outside interests—that’s a conflict.Such conflicts may arise between:

When it comes to CIDEH, we need to consider the interests of both the Covered Persons and the organization's obligations to its members or promoters. It's also important to look at how the interests of different members or promoters relate to one another. Generally speaking, to spot any conflicts of interest, we should think about whether CIDEH, the Covered Persons, or any Related Parties might:

- Secure financial gains or minimize losses at the expense of a member or promoter.
- Allow personal interests to take precedence over the member’s interests during service delivery or transaction processing.
- Recommend actions or advocate for projects primarily benefiting the Covered Person, rather than serving the member’s best interests.
- Prioritize certain members or groups due to financial or other incentives, leading to unequal treatment.
- Accept benefits—such as payments, goods, or services—from third parties (not the client) in connection with the provided service, beyond standard commissions or service fees.

The head of the Customer Service Department will be someone with strong commercial and professional integrity, along with the necessary knowledge and experience to carry out their responsibilities effectively. It's important to note that integrity in business and professionalism is reflected in those who have consistently respected commercial laws and regulations governing economic activities and business practices, as well as maintaining good commercial and financial standards.

3. Subject Persons

The individuals and entities that need to follow this policy include: Members of CIDEH's governing body, whether they are individuals or organizations, along with their natural representatives (if applicable). The directors, employees, and representatives working for CIDEH. The direct and/or indirect partners of CIDEH; and Entities that are part of the same business group as CIDEH, including their directors, officers, employees, representatives, and partners, whether direct or indirect. Additionally, it's important to note that not only must these Subject Persons adhere to the guidelines of this policy, but their Associated Persons must do so as well, which includes:

For clarification, the following relationships are considered relevant: spouses or individuals maintaining an equivalent emotional connection to the Subject Person; direct family members such as parents, children, and siblings of the Subject Person, as well as those of their spouse (or comparable partner); and spouses (or similarly connected individuals) of these immediate family members. With respect to legal entities, inclusion applies where the Subject Person—either directly or through intermediaries—fulfills any of these criteria:

Holds a majority of voting rights. Possesses authority to appoint or remove most members of the governing body. Exercises control over a majority of voting rights via agreements with third parties. Has appointed the majority of the governing body through their voting power.

In scenarios involving an actual or potential conflict of interest, Subject Persons and Related Parties are required to: Abstain from participation; Avoid attempting to influence decisions; Not exploit or disclose Confidential Information; Promptly notify the Supervisory Body.

4. Associated Projects

CIDEH will not be involved in any crowdfunding offers available on its platform. CIDEH will not allow the following individuals to act as project promoters for the crowdfunding services provided on the platform: Partners holding at least 15% of the share capital or voting rights. Directors or employees. Any individual or entity connected to those partners, directors, or employees through control.

5. Supervisory Body

The Supervisory Body plays a crucial role in ensuring that the standards set out in this policy are followed and applied correctly. Its key responsibilities include: Keeping the policy current and relevant. Promoting awareness, understanding, and adherence to the policy. Offering guidance on any questions that may come up regarding the policy's application; and Suggesting corrective actions and procedures to enhance compliance with the policy. It's essential for Bound Persons to follow the requirements set by the Supervisory Body to maintain adherence to the standards outlined in this policy.

6. Communication and Resolution of Conflicts of Interest.

As mentioned earlier, Bound Persons are required to notify the Supervisory Body about any situations that could lead to a conflict of interest related to a performance, service, or operation. These communications should be made in writing as soon as the situation is known or should have been known, and definitely before any decisions are made that might be influenced by the potential conflict of interest.

Subject Persons need to keep the information mentioned above current, making sure to report any changes or the end of the situations they’ve reported. If there’s any uncertainty about whether a conflict of interest exists, Subject Persons must notify the Supervisory Body about the situation, including the specific details of the transaction that could lead to a potential conflict. This way, the Supervisory Body can figure out the best course of action.

The Supervisory Body will handle any conflicts of interest that arise. If a conflict involves any member(s) of the Supervisory Body, it will be reported to the CIDEH administrative body, which will take charge of resolving it. All conflicts of interest will be addressed according to this policy and the following principles:

1. CIDEH should not prioritize financial gain over the interests of its members and/or promoters. 2. The legitimate interests of members and/or promoters must come first, with actions taken in good faith, loyalty, neutrality, and discretion. 3. No member or category of member should receive preferential treatment over others.

7. Communication to Members

CIDEH will keep its members in the loop about the general nature and sources of any conflicts of interest, along with the steps taken to address them. The disclosures mentioned earlier will be shared promptly, giving members the chance to make informed decisions regarding the services related to the conflict of interest. This will be done with consideration for the members' backgrounds, especially whether they are seasoned or new investors.

8. Non-compliance

If anyone fails to follow the rules laid out in this Policy, disciplinary actions as per current laws will be enforced. The repercussions of non-compliance won't just impact the individual at fault; they will also extend to those Subject Persons who, through their actions or lack thereof, have contributed to the non-compliance.