Conflict of Interest Management Policy

• Startupxplore PSFP has no participation whatsoever in the crowdfunding offers published on its platform.
• Startupxplore PSFP does not accept as the sponsor of a project published on its platform any of the following persons:

1. Its partners holding at least 20% of the share capital or voting rights;
2. Its executives or employees;
3. Any natural or legal person linked to such partners, executives or employees by control as defined in Article 4, paragraph 1, point 35, letter b) of Directive 2014/65/EU.

• If at any time Startupxplore PSFP were to accept as an investor in a project published on its platform any of the persons mentioned in the preceding paragraph, points 1), 2), and 3), it will publicly disclose on its website that it accepts such person as an investor, including information on the specific crowdfunding projects in which that person has invested. It will also ensure that such investments are made under the same conditions as those of other investors and that such person does not receive preferential treatment or privileged access to information.

• Startupxplore PSFP takes all appropriate measures to prevent, detect, manage, and disclose conflicts of interest between, on the one hand, Startupxplore PSFP, its partners, executives or employees, or any natural or legal person linked to the company by control as defined in Article 4, paragraph 1, point 35, letter b) of Directive 2014/65/EU, and, on the other hand, its clients, or between two clients.

Investment in projects by persons linked to the PSFP

In order to ensure strict compliance with Article 8 of Regulation (EU) 2020/1503 (ECSPR) and its incorporation into Spanish law, the entity adopts the following specific measures:

1. Principle of neutrality and prohibition of participations

   • The PSFP, its partners holding ≥ 20% of voting rights, executives and employees may not act as sponsors of projects published on the platform.

   • When any of these persons invests as an investor, equality of conditions with the rest of the participants and the absence of preferential treatment will be ensured. The investment will be publicly disclosed under the terms required by Article 8.2 of the ECSPR.

2. Permanent “Linked Persons” Portal
   To reinforce the required transparency, the following information is made accessible to any interested party:

   • Complete and updated list of linked persons (significant shareholders, directors, executives and employees) who have participated in the transactions.

   • Chronological history of all investments made by such persons in recent years, detailing project, amount and date.

   • Access to the list of linked persons is available at the following link.

3. Governance and internal controls

   • Effective internal rules are incorporated to prevent, detect, manage and disclose potential conflicts of interest, in accordance with Article 8.3 ECSPR.

   • The Compliance Department will prepare a semi-annual report on the adequacy of these controls and propose improvements.

   • The Board of Directors will approve and document any exceptions, recording the justification and the fair treatment of investors.

To report a possible conflict of interest, the first thing you can do is download the following TEMPLATE.

Once completed, you can send it to us by one of the following means:

• Email: complaints@startupxplore.com
• Postal mail: C/ Baldoví, 2 Ofic 11D 46002 Valencia

Procedure we will follow to resolve the case.

In an ideal scenario, we will resolve it immediately, but that will not always be possible. Therefore, those that cannot be resolved immediately will follow this procedure:

1. Client and incident identification

The communication of a possible conflict of interest must necessarily be made through the aforementioned TEMPLATE, duly completed and submitted through the means provided for this purpose, together with a copy of the supporting documents.

2. Acknowledgement of receipt

Once you have notified us, we will acknowledge receipt (within a period not exceeding 15 days) to the email from which we received such notification, or the one indicated in the Template submitted to our registered office, confirming that we are aware of the communication of the possible conflict of interest and to request more information if necessary.

3. Admission and processing

Objective aspects such as the persons affected, their relationship with STARTUPXPLORE PSFP, the existence of a conflict of interest under the REGULATION (EU) 2020/1503 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, and the measures to be implemented, if applicable, to avoid such conflict and its consequences will be analyzed.

Startupxplore may request from the client the data or additional information it deems relevant to adopt its resolution. If this is not provided within 10 calendar days, the case will be closed. If, once closed, the client provides the necessary documentation, Startupxplore will reopen the file.

The period taken by the client to correct errors or complete the documentation will not be counted towards the 2-month period for Startupxplore to resolve the case.

4. Notification of resolution

The resolution will be notified to the client by email or another electronic or telematic messaging system within a maximum period of one month.