ROUTINE FOR IDENTIFYING AND HANDLING CONFLICTS OF INTEREST

1. Purpose

The purpose of this routine is to describe how Lind Finans identifies, assesses, and manages situations that may create conflicts of interest between the company and clients, between clients and partners, or between clients themselves. The routine shall ensure that the client’s interests are always prioritized and that the risk of harm to the client’s interests is minimized.

2. General

Lind Finans shall implement appropriate measures to identify and handle conflicts of interest, including:

• Risks arising from remuneration from partners or clients

• Internal structures that may result in prioritization of the company’s own interests over those of the client

It shall be assessed whether the company, its employees, or associated persons:

• Can obtain financial gain at the expense of the client

• Have an interest different from the client in the outcome of arranging financing

• Have financial or other reasons to prioritize the interests of other clients

In case of conflicts of interest, the client’s interests shall always be prioritized, and no client shall be favored at the expense of another.

3. Identification and Handling of Conflicts of Interest

3.1 Potential Conflicts of Interest

Conflicts of interest may arise in various situations, including but not limited to:

• Simultaneous handling of similar projects

• Company involvement in decisions affecting clients or investments

• Remuneration or benefits from partners or other third parties

3.2 Measures for Handling Conflicts of Interest

To minimize risks, Lind Finans has established the following measures:

• Confidentiality: The board and any employees of the company shall handle confidential information securely and avoid disclosure to third parties.

• Secondary employment: Any potential employees must obtain written approval before engaging in other activities that may conflict with the company’s interests.

• Compensation schemes: Remuneration structures shall not create incentives that prioritize the company’s or potential employees’ interests over the client’s.

• Insider information: If the company receives insider information, it shall be handled in accordance with applicable laws and regulations.

• Agreements with related parties: The company shall ensure that services to related parties do not provide unfair advantages.

• Role conflicts: Potential conflicts arising from overlapping roles shall be continuously assessed.

3.3 Remuneration from Third Parties

Lind Finans may receive remuneration from partners (lenders) if:

1. No separate financing assignment agreement has been entered into with the business/client. In such cases, Lind Finans may only receive remuneration from the principal in accordance with Finansavtaleloven Act § 3-58.

2. Lind Finans has assessed more than one of the financial services available in the market for the relevant product category.

All documentation of such remuneration shall be recorded internally.

3.4 Information about Remuneration

Clients entering into a financing assignment agreement shall be informed in writing about the nature and calculation method of remuneration before the service is delivered. If the amount cannot be determined in advance, the client shall be informed of the final amount after the service has been performed.

4. Operational Processes

Lind Finans manages conflicts of interest through a systematic process:

1. Identification: If the company employs staff other than the general manager, employees shall identify potential conflicts and notify the general manager.

2. Notification: Notification shall take place immediately.

3. Assessment: The general manager assesses the scope, significance, and necessary measures related to the conflict.

4. Resolution: Measures are taken to manage the conflict, protect the client’s interests, and prevent harm.

5. Reporting/recording: All cases are recorded in a conflict register that is continuously updated and retained for at least 5 years.

The general manager reports to the board at least annually on all registered cases.

5. Information to Clients

If it is not possible to eliminate a conflict of interest, clients shall be informed in writing about the conflict and the measures implemented to reduce the risk. The information shall be clear and provide the client with a basis to make an informed decision.

6. Management Control

The general manager is responsible for ensuring that systems, controls, and procedures effectively identify and manage conflicts of interest. Management shall evaluate routines and measures at least once per year and ensure updates and improvements where necessary.