Under the laws and regulations, financial companies are required to have procedures and measures in place to prevent and manage conflicts of interest. Below you can read how Vive has incorporated the policy on conflicts of interest into its operations and the measures Vive has taken to protect the client's interest. At all times, the applicable laws and regulations take precedence and also serve as a guideline in the event of conflicts of interest.

Principles of the policy‍

Vive has established the policy in accordance with its license as an investment firm. The policy applies to all companies affiliated with Vive Group.

The policy

Vive recognizes that, as with any other investment firm, there may be potential conflicts of interest. Vive's policy is aimed at protecting the client's interest, so that a client cannot suffer material damage from this. Vive has laid down in this policy which circumstances can lead to a conflict and which measures have been taken to control and/or prevent these conflicts.

Possible conflicts of interest

Conflicts of interest can arise in the following (non-exhaustive) situations:

• Having an interest in the result of a service or transaction performed for the client that differs from the client's interest in this result;
• A conflict of interest between clients.
• Having a financial or other incentive to give priority to the interest of one client or group of clients over the interest of other clients;
• The provision of services by affiliated companies; The structure and (financing of) business operations

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

Although the chance of this conflict of interest is considered small, given the service and the far-reaching degree of automation, the Compliance Officer will appoint persons to represent the interests of these clients with potentially conflicting interests.

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

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With regard to services provided by affiliated parties, the decision-making process is structured in such a way that, in the event of a conflicting interest, the interest of the affiliated party is subordinate to the interest of (the clients 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, will not participate in the decision-making process.

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Vive has established various measures, procedures and policies to identify, prevent and manage conflicts of interest. Below is a non-limitative list of a number of measures that Vive has taken to safeguard the material interests of the client.

Internal supervision

Vive has a member of the board of directors who is ultimately responsible for compliance matters. In addition, the Compliance Officer supervises compliance with the conflicts of interest policy. Agreements with affiliated parties will be assessed by the management in conjunction with the Compliance Officer on the “at arms length” principle, whereby the final decision-making authority lies with the member of the board of directors who is not involved with the affiliated party. Periodically, at least annually, the effectiveness of the policy regarding the prevention of conflicts of interest is evaluated and updated if necessary. 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 ensuring that the service model and the method of charging fees to clients are not based on services that are not in the client's best interest. Employees who can influence investment decisions do not receive variable remuneration. Therefore, the integration of sustainability risks into the remuneration policy is not applicable.

Private investment transaction

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

Gifts

In addition to the private investment transactions policy, the gifts policy and secondary employment activities policy are included in the personnel policy to manage conflicts of interest.

Commission

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

Market abuse

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

‍Segregation of duties

To ensure that individuals cannot misuse the system, segregation of duties is guaranteed. There is a separation between functions in which investment services are performed and functions in which the operational processes are handled for the benefit of the activities.

Communication

Any (potential) conflict of interest within Vive is reported to the Compliance Officer, who will inform the Management Board. Compliance, in consultation with the Management Board, will investigate the reports. Each report is assessed against the conflicts of interest policy. A written record is made of each relevant report, in which Vive indicates how the conflict of interest was handled.

Given the specific nature of conflicts of interest, Vive will assess each notification 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 be disclosed to the clients involved in this case.

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