Legal
Conflicts of interest
Handling conflicts of interest – measures to avoid conflicts of interest
Avoiding conflicts of interest with (potential) project owners
The following persons are not admitted as project owners by CONDA Capital GmbH:
- own shareholders who hold at least 20% of the capital shares or voting rights,
- members of the management or employees,
- any person connected through close control relationships or a relationship of super-/subordination to the aforementioned shareholders or employees of CONDA Capital GmbH (definition pursuant to Article 4(1)(35)(b) of Directive 2024/65/EU).
CONDA Capital GmbH has identified the following legal entities as persons that could result in a conflict of interest:
CONDA GmbH
100% stake in CONDA Capital Market
D&D Holding GmbH
100% stake in CONDA GmbH
Horakel Ventures GmbH
42.04% stake in D&D Holding GmbH
Tannenberg Partners GmbH (DE)
42.04% stake in D&D Holding GmbH
In addition, the following hold indirect stakes in CONDA Capital GmbH (below 20%):
EVWB3 GmbH
7,0299 %
FMTG – Falkensteiner Michaeler Tourism Group AG
3,5149 %
Locker Capital GmbH
1,7891 %
Gartner Michael
0,8946 %
MeinController GmbH
0,8946 %
Turki Karin, Mag.
0,8946 %
Tutsch Peter, Mag.
0,8946 %
Avoiding conflicts of interest with investing persons
Shareholders, members of the management and employees of CONDA Capital GmbH are not generally prohibited from investing in projects. To minimise potential conflicts of interest, maximum investment limits of EUR 5,000 per offered project apply to these persons.
If a fundamental conflict of interest has been identified because one of these persons invested in a project, the following applies:
In the case of an investment < EUR 2,500
- Where relevant, performance-based remuneration is 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 influence on the project/the project owner; and
- Avoidance of circumstances that could constitute a conflict of interest.
In the case of an investment > EUR 2,500
- Exclusion of information; and
- separate supervision of relevant persons whose main tasks consist of carrying out activities on behalf of clients or providing services to clients whose interests could conflict, or who otherwise represent different interests that could conflict, including the interests of CONDA Capital GmbH.
General measures to avoid conflicts of interest
To ensure compliance with the rules for avoiding conflicts of interest, due diligence is carried out as part of the project onboarding. This also checks whether conflicts of interest exist.
If employees have privileged information about a project owner 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 assessed and reviewed annually. Updates are published here and can be viewed.