Conflict of interest policy

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Under laws and regulations, financial institutions are required to have procedures and measures to prevent and deal with conflicts of interest. Below you can read how Vive has incorporated the conflict of interest policy into its business operations and the measures that Vive has taken to protect the client's interests. At all times, it is paramount that the applicable laws and regulations prevail and are also the guide in case of conflicts of interest.

Policy principles‍

Vive has created the policy under its license as an investment firm. The policy applies to all companies affiliated with Vive Group.

The policy

Vive acknowledges that, like any other investment firm, there may be possible (potential) conflicts of interest. Vive's policy is aimed at protecting the client's interests, so that a client cannot suffer material damage. In this policy, Vive has defined the circumstances that may lead to a conflict and what measures have been taken to manage and/or prevent these conflicts.

Possible conflicts of interest

Conflicts of interest may arise, among other things, in the following (not exhaustive) listed situations:

• Having an interest in the result of a service or transaction provided for the client that is different from the client's interest in this result;
• A conflict of interest between clients.
• Having a financial or other incentive to let the interests of one client or group of clients prevail over the interests of other clients;
• Providing services by affiliated companies; The structure and (financing of) the business activities

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Because Vive's services are highly automated, the chance that Vive, or a Vive employee, will have an inappropriate influence on how asset management is carried out for a single customer, or group of customers, is considered extremely small. Where the clients may have a conflict of interest among themselves, or otherwise have different interests, this will be reported to the Compliance Officer.

Although the risk of this conflict of interest is considered low, given the services and the extensive method of automation, the Compliance Officer will appoint persons to represent the interests of these customers who may have conflicting interests.

In the event of conflicting interests, the Compliance Officer will weigh interests together with the board member who is not responsible for commercial matters.

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With regard to the services provided by affiliated parties, decision-making is organized in such a way that, in the event of a conflict of interest, the interests of the affiliated party are secondary to the interests of (the customers of) Vive.

To ensure this, the Compliance Officer, together with Vive's management, will decide that the person in whom the affiliated party is or may be represented does not participate in decision-making.

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Vive has created various measures, procedures and policies to recognize, prevent and manage a conflict of interest. The following is a non-exhaustive list of a number of measures that Vive has taken to ensure the client's material interest.

Internal supervision

Vive has a board member who is ultimately responsible for compliance issues. In addition, the Compliance Officer monitors compliance with the conflict of interest policy. Agreements with affiliated parties will be assessed by the management jointly with the Compliance Officer on the “at arms length” principle, where the ultimate responsible decision-making authority lies with the board member who is not involved with the affiliated party. Periodically, at least annually, the effectiveness of the anti-conflict of interest policy shall be reviewed and, where necessary, updated. In the event that a conflict of interest occurs that is not provided for in the policy, the Compliance Officer will immediately adjust the policy accordingly.

Remuneration policy

A specific remuneration policy has been established where the service model and how reimbursements are passed on to customers are not based on services that are not in the customer's interest. Employees who can influence investment decisions do not receive variable remuneration. That is why the integration of sustainability risks into remuneration policy does not apply.

Private investment transaction

The personnel policy states that, if an employee wants to make a private investment transaction, this must be reported to the Compliance Officer in advance.

Donations

In addition to the private investment transactions scheme, personnel policy includes the donation scheme and ancillary activities scheme to manage conflicts of interest.

Commission

Vive does not receive commissions, commissions, or monetary or non-monetary benefits paid or provided by a third party.

Market abuse

To prevent Vive employees from using (price) sensitive information for their own profit, Vive has drawn up a private investment transaction scheme. The scheme must ensure that (the appearance of) insider trading and the mixing of business and private interests are prevented.

‍Separation of duties

To ensure that people can abuse the system, segregation of duties is ensured. There is a separation between functions in which investment services are provided and functions in which the operational processes are handled for the purposes of the activities.

Communication

Any (possible) conflict of interest within Vive will be reported to the Compliance Officer and he will inform the Executive Board about this. Compliance will investigate the reports in consultation with the Management Board. Each report is assessed against the conflict of interest policy. Each relevant report is recorded in writing, with Vive indicating how the conflict of interest was dealt with.

Given the specific nature of conflicts of interest, Vive will review each report on an individual basis. If the organizational and administrative arrangements put in place by the investment firm to prevent or manage a specific conflict of interest are not sufficient, this will at least be made known to the clients involved in this case.

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