Code of conduct and management of conflicts of interest

The importance of the code of ethics

In Startupxplore, we believe that investment in high-potential companies is a business that must always be considered in the long term. Confidence and transparency should prevail in it, and is that it's absolutely essential to be guided by the highest ethical standards in our relationship with all players involved in this ecosystem.


We believe that trust is built through relationships in which recurrent transparency, honesty and clarity come first. Integrity as we understand it in Startupxplore assumes that the construction of our competitive advantages and commercial success must derive from a form of conducting our business in a superior way, and never on the basis of the use of manipulative or ethically questionable practices.


In an investment related business such as Startupxplore it is usual to have access to information of a sensitive nature, whether commercial, personal, or intellectual. The Startupxplore team will give you the steps it deems reasonable to protect such information from any improper disclosure.


We work hard to ensure that our processes are fully engaged and to avoid situations of inequality among the various participants, especially among investors and promoters, or between any of them and Startupxplore, but if such inequality be produced at some point, we will resolve this situation in accordance with the principles of respect, equity, and the highest ethical standards.


Management of conflicts of interest

It is considered that there is a conflict of interest when there is a contrast between the interests of Startupxplore, including Subject Persons or those related to it, and customers, or between several customers among themselves, which can lead to impairment of the interests of some of them.

For customers, it is understood both promoters and investors who invest through Startupxplore.

People that are considered subject:

  • Administrators, directors, and senior executives of Startupxplore.
  • Startupxplore employees and attorneys, as well as any other person whose services are made available and under the control of Startupxplore and that participate in the provision of investment services in Startupxplore

People that are considered as related:

  • Spouses, children, relatives, or people with equivalent affective relations to the people involved
  • Any legal person or any business in which the person or persons referred to in the previous point play a managerial position or which is directly or indirectly controlled by the person subject or whose economic interests are largely equivalent to those of the person subject

For the purposes of identifying possible conflicts of interest, will be taken considered as minimum criteria, if Startupxplore, Subject Persons or persons related to these can be found in any of the following situations:

  • That can obtain a financial benefit, or avoid a financial loss, at the expense of the Customer;
  • To have an interest in the outcome of the funding requested through Startupxplore that may be different from the customer's interest, and that is not subject to financial profit that Startupxplore obtains for the arranging contact between developers and investors;
  • That have financial or other incentives to promote the interests of a client to the interests of another client;
  • That the professional activity be identical to that of the Customer; or
  • That receive or will receive from a person other than the investor an incentive in connection with a service provided to the promoter, in the form of money, goods, or services.

To consider the existence of a conflict of interest, it is not necessary for such impairment to be produced, but it will be enough for the possibility of it taking place in the future. It will also not be sufficient for Startupxplore to obtain a benefit, unless there is also a possible injury to a client, or that a client can make a profit or avoid a loss if there is no possibility of a concomitant loss for another customer.

All Subject Persons must inform Startupxplore of any situation that might constitute a conflict of interest. Such communication shall take place, without delay, from the moment that such circumstance is known on the part of the person in particular, before the decision-making that may be affected by the potential conflict of interest.

It is not considered that there is a conflict of interest in family relations when, not affecting related people, kinship exceed the fourth degree by consanguinity or affinity.

In any case, it will be considered that there is a potential conflict of interest arising from personal assets, when such a conflict arises in relation to a company or an asset in whose capital or ownership the person subject participates, either alone or jointly with people with consanguinity relationship as defined in the previous paragraph, in more than 10% (always in relation to unlisted companies) of political or economic rights, or, when, without reaching such percentage, may designate a member, at least, of its board of directors.

The information referred to above shall be kept up-to-date, taking account of any modification or cessation of the situations previously communicated, as well as the emergence of new potential conflicts of interest.

In the event of the existing a conflict of interest, the persons concerned must observe the following general principles of action:

  • Independence. They must act at all times with freedom of judgment, with loyalty to Startupxplore and its partners, refraining from rewarding their own interests at the expense of Startupxplore's or those of any clients at the expense of others.
  • Abstention. They should refrain from intervening or influencing the decision-making that may affect persons or entities with which conflict exists and to access or use confidential information that affects such conflict, staying away from the decision-making or advisory bodies during the process of discussion and decision-making that may affect people or entities with which conflict exists.
  • Communication. All Subject Persons must inform Startupxplore about the potential conflicts of interest that are involved because of their activities outside of Startupxplore, their family relationships, personal assets or for any other reason, with regard to Startupxplore or its customers.

Related Projects:

Only the Subject Persons will be able to participate in financing requests in the terms described below and, should a conflict of interest exist, only to the extent that there is no conflict of interest or that this has been disclosed to the client, and the client has expressly approved their participation.

Startupxplore may only participate in projects published on its website in accordance with the following requirements:

  • Its participation may not exceed 10% of the funding target for each project nor will be allowed to control the company, on the terms set forth in article 42 of the Code of Trade.
  • It must inform investors in a clear and accessible way of the amount of its participation in each project, or that of managers, senior executives, and partners with meaningful participation, as well as of that of spouses or persons with whom they live with similar emotional relationship, and their relatives up to the second degree of consanguinity or affinity. In addition, it will publish in the internet the criteria of its internal policy to decide on its participation in the projects.

The Company may only publish projects of which it is a promoter on its own web site subject to the following requirements:

  • The aggregate funding target of such projects shall not exceed in each financial year, the 10% of the funds actually collected by all participatory financing projects published on its website in the fiscal year immediately preceding it.
  • It shall immediately inform investors in a clear and accessible way about the projects being promoted by Startupxplore or managers, senior executives, and partners with meaningful participation, as well as the spouses or persons with whom they live with similar emotional relationship, and their relatives up to the second degree of consanguinity or affinity.
  • Startupxplore may not participate in projects published by other PFPs.

(This document is a summary of the Internal Rules of Conduct, which is available on request to anyone interested).