inReg Solutions shall by law take all reasonable steps to identify and manage conflicts of interest arising from the provision of licensed services and prevent clients’ interests from being adversely affected by conflicts of interest. FinReg works continuously to identify, manage and eliminate conflicts of interest by introducing rules and building various control systems. All to contribute to a secure foundation for safe and reliable crowdfunding and that all customers should be able to feel secure in their business with us. 

FinReg Solutions works continuously to identify the conflicts of interest that may arise between Sedermera, any affiliate or any related person to them and a client or between clients in connection with the provision of investment services. 

A conflict of interest exists when there is a conflict between the interests of FinReg Solutions or the interests of persons connected with FinReg Solutions and FinReg Solutions’ obligations to a customer or between the different interests of two or more FinReg Solutions customers to whom FinReg Solutions has an obligation. Conflicts of interest that are identified shall be reported on an ongoing basis to the Chief Administrative Officer and the Conflict of Interest function. 

FinReg Solutions has a clear structure for division of responsibilities and governance to avoid conflicts of interest through a division into different organizational units for separation of business functions. FinReg Solutions has furthermore ensured through its work process that all employees of FinReg Solutions have the knowledge and competence so that no individual can take action with the aim of benefiting themselves or FinReg Solutions at the expense of a customer or other counterparty. 

FinReg Solutions manages conflicts of interest through an escalation process, which is carried out in the following steps: 

1. Identify the risks 

2. Report to the designated manager 

3. Assess and mitigate risks 

4. Control and manage residual risks 

5. Allocate the required capital so that unexpected negative outcomes can be absorbed without threatening the company’s position. 

6. Follow-up 

All staff at FinReg Solutions are also prohibited from trading in financial instruments on Spotlight Stock Market, with the exception of Spotlight Group’s share. The prohibition of trading also applies to companies with which FinReg Solutions has a customer relationship.