Investments in Crowdfunding Projects via Capital Circle
Capital Circle is part of the KOM Group and, as a legal entity and licensed crowdfunding service provider, is prohibited from making investments in any crowdfunding offers listed on its own platform.
Investments in Crowdfunding Projects by Parties Involved with KOM Group B.V.
Shareholders, directors, and employees of KOM Group B.V., as well as related third parties (hereafter collectively referred to as “Involved Parties”), are permitted to invest in crowdfunding offers published on the KOM Group B.V. crowdfunding platform.
Involved Parties may invest a maximum of €2,500 per crowdfunding offer, with an annual limit of €25,000.
Involved Parties receive no preferential treatment in subscribing to crowdfunding offers and are subject to the same order of registration as regular investors. Investments are accepted on a first-come, first-served basis. KOM Group B.V. ensures that such investments are made under the same terms and conditions as those applied to other investors and that Involved Parties receive no privileged access to information or preferential treatment.
KOM Group B.V. makes the fact that Involved Parties are accepted as investors on the platform fully transparent on its website, including information about the specific crowdfunding projects they have invested in.
Related third parties are defined as: spouses/partners, relatives by blood or marriage up to the second degree, members of the same household, authorised representatives, asset managers, legal entities, or investment clubs in which an employee, (indirect) shareholder, or (indirect) director has control or influence.
Prohibition on Acting as a Project Owner
The following persons or legal entities are prohibited from acting as project owners in relation to the crowdfunding services offered via the KOM Group B.V. platform:
- KOM Group B.V. itself
- Shareholders of KOM Group B.V. holding 20% or more of the share capital or voting rights
- Directors and employees of KOM Group B.V.
- Any natural or legal person linked by a control relationship to the aforementioned shareholders, directors, or employees. This includes parent-subsidiary relationships and any legal or natural person that has a similar controlling connection. Subsidiaries of subsidiaries are also considered to be subsidiaries of the ultimate parent entity.
Monitoring, Disclosure, and Evaluation
All investments made by Involved Parties are identified and registered internally by the Executive Board of KOM Group B.V. Any other circumstances that could potentially lead to an actual or perceived conflict of interest are also identified and documented, taking into account the risk of harm to the interests of investors.
The Executive Board conducts periodic and random checks to verify compliance with this policy. Involved Parties are required to cooperate fully during these audits. If an Involved Party is found to have breached the policy, a formal warning will be issued. In case of repeated violations, appropriate consequences will be determined in consultation with the offending party.
If a particular conflict of interest cannot be avoided, KOM Group B.V. will take all reasonable measures to identify and manage the conflict to protect the interests of its investors.
KOM Group B.V. will disclose the general nature and sources of any conflict of interest, as well as the measures taken to mitigate it, to its investors. This disclosure will be made in a prominent location on the KOM Group B.V. website and will include sufficient detail to allow each investor to make an informed investment decision, taking into account their experience and personal situation.
The conflicts of interest policy is reviewed annually and revised where necessary. If material changes arise during the year, the policy will be updated immediately to address any deficiencies and ensure compliance with the established rules. The most recent version of the policy is made available on the website:
👉 www.capitalcircle.nl