Conflict of Interest Management Procedure

In accordance:

• To the French legislation relating to the Advisers in Participative Investments;
• To the Belgian legislation relating to Alternative Financing Platforms, in particular Article 27 of the law of 18 December 2016;

Raizers SA and Raizers SAS have established the following conflict of interest policies and procedures.

1 - Identification of conflict of interest situations

• Raizers holds securities of the Issuer prior to the transaction;
• Raizers has a business relationship with a competitor(s) of the Issuer;
• The customer's interest is divergent from Raizers' business interest
• Conflicts of interest that may involve Raizers' employees: 
  • The employee responsible for the design and implementation of the transaction holds, directly or through an intermediary, securities, whether listed or unlisted, of the issuer prior to the opening of the transaction;
  • The employee responsible for the design and implementation of the transaction has a non-legacy relationship with the issuer;
  • The employee responsible for the design and implementation of the transaction receives direct compensation and/or gifts from the issuer of the securities involved;

2 - Prevention device

The company and its employees undertake, by signing the company's code of conduct, to direct all their actions in the interest of the client and refrain from:

• To receive any remuneration, directly or indirectly, other than that indicated in the framework of the transparency hereafter explained;
• Not to have an employee analyze an offer if the employee holds securities of the issuer and/or has a non-financial relationship with the issuer.

3 - Transparency on potential conflicts 

The company informs its clients during the subscription process, through the "intermediary information sheet", of the identity of the issuers with whom it has a commercial relationship.

Thus, the description of the fees charged to the investor is followed by the following paragraph: "You may obtain a detailed description of the services provided to the issuer of the securities whose subscription is envisaged and the related fees on request from the following address RAIZERS SAS - 130 rue de Courcelles - 75017 Paris.

In addition, the company, including all the entities that make it up, its managers and employees, shall inform, at all times, all the users of the platform in a complete, accurate and comprehensible manner, of the existence, nature and amount of any remuneration, commission or benefit that it may receive.

Finally, the payment by a third party of any remuneration or the granting by a third party of any non-monetary benefit as a result of a recommendation made by the company is permitted only if it is intended to improve the quality of the advisory service provided to the client and does not interfere with the company's duty to act in the best interests of the client.

In the event that the steps taken to manage a conflict of interest do not ensure with reasonable certainty that the risk of harm to the Investor's interests will be avoided, RAIZERS will send an email to Investors describing the nature or source of the conflict of interest. RAIZERS will disclose the potential impact that the conflict of interest may have on the Investor and the consequences that the conflict may cause.

The Investor will have the choice to participate or not in the project.

4- Investment funds

The company informs its clients that it has established a partnership with Capitalium, a Swiss company, to create an investment fund.

The purpose of the investment fund is to invest in real estate transactions selected by Raizers SAS.

To guard against potential conflicts of interest, the investment fund's prospectus provides for a strict investment policy.

Thus, an automatic investment will take place, without Raizers being able to decide on the operations in which the investment fund will take part, according to investment rules from which Raizers cannot derogate in any way.