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Samen Lenen
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Conflict of Interest Policy

Last updated: 3 August 2026

For the use of the Platform – version 3 August 2026

1. Introduction and scope

1.1 Purpose of the Policy

This conflict of interest policy (hereinafter: the "Policy") has been drawn up by the Platform Operator and aims to transparently describe the measures taken by the Platform Operator to identify, prevent and, where appropriate, manage potential Conflicts of Interest in the context of the operation of the Platform.

The Platform Operator endorses the principles of integrity, transparency and fair treatment of Users, even though the Platform Operator does not provide any financial service subject to a licensing requirement under the Platform. This Policy is adopted voluntarily as a good governance instrument.

1.2 Demarcation from the Licensed Activity

The Platform Operator holds a license or registration with the FSMA for other activities (the "Licensed Activity"), which is kept completely separate operationally, contractually and accounting-wise from the SaaS services under the Platform. The conflict of interest policy applicable to the Licensed Activity is a separate document and is not undermined or replaced by this Policy.

The present Policy relates exclusively to the activities of the Platform Operator in its capacity as provider of SaaS services under the Platform and has been drawn up from a purely good governance approach, without this being interpreted as an acknowledgement that the activity would qualify as a regulated financial service.

2. Definitions

In this Policy, the following terms, each written with a capital letter, whether used in the singular or plural, have the following meaning. The terms not defined below have the same meaning as in the Terms of Use:

  • “Conflict of Interest”: a situation in which the interests of the Platform Operator, a director, a shareholder, an assistant or a Connected Person of the Platform Operator, directly or indirectly conflict or may conflict with the interests of a User, or in which the interests of two or more Users may conflict with each other, in such a way that there is a risk that the interests of a User may be harmed.
  • “Policy”: this conflict of interest policy of the Platform Operator.
  • “Campaign”: the financing initiative set up by an Entrepreneur via the Platform, including the Campaign Page, the requested financing amount, the offered terms and the Model Agreement.
  • “Campaign Page”: the digital page on the Platform that displays the information of a specific Campaign, which is not publicly accessible and which is exclusively accessible via a Personal Link.
  • “Compliance Officer”: the person appointed within the Platform Operator to oversee compliance with the regulatory framework and internal policies, including this Policy.
  • “User”: any natural person or legal entity that consults or uses the Platform, including Entrepreneurs and Investors.
  • “Terms of Use”: the document containing the conditions under which the User may use the Platform.
  • “Investor”: a User, belonging to the Network of an Entrepreneur, who considers or decides via the Platform to enter into a Loan Agreement with the Entrepreneur.
  • “Network”: the limited circle of personal and business relations of the Entrepreneur (such as friends, family members, customers, suppliers or business relations) who are selected, approached and invited by the Entrepreneur themselves to participate in the Campaign.
  • “Entrepreneur”: a User that is a business and that sets up a Campaign via the Platform to raise financing within their Network.
  • “Launch Fee”: the one-off fee due by the Entrepreneur to the Platform Operator for the launch and activation of a Campaign.
  • “Platform”: the software platform made available by the Platform Operator as Software-as-a-Service via www.samenlenen.be, including all associated functionalities, content and infrastructure.
  • “Platform Operator”: WinWinner Crowd BV, a company under the laws of Belgium, registered in the register of legal entities of Ghent, with its registered office at Oudenaardsesteenweg 21, 9000 Ghent and with company number 0723.682.356, which develops, maintains, operates and makes the Platform available.
  • “Relevant Person”: any director, partner/shareholder or assistant of the Platform Operator, as well as any other natural person whose services are made available to the Platform Operator and who participates in the activities of the Platform Operator in the context of the Platform.
  • “Service Fee”: the periodic fee due by the Entrepreneur to the Platform Operator if, after the Campaign, it continues to use the Platform for the hosting of the Campaign environment, the administrative follow-up of the repayments to the Investors and the associated support services.
  • “Connected Person”: a person who, with respect to a Relevant Person, qualifies as (i) spouse, legal cohabitant or de facto cohabiting partner, (ii) relative by blood or marriage up to the second degree, (iii) a legal entity in which the Relevant Person has a controlling interest, or (iv) a person with whom the Relevant Person maintains financial or business ties on a lasting basis.
  • “Licensed Activity”: the activity of the Platform Operator for which it holds a license or registration with the FSMA, and which is kept completely separate operationally, contractually and accounting-wise from the SaaS services under the Platform.
  • “Extension Fee”: the fee due by the Entrepreneur to the Platform Operator for extending the duration of a Campaign.

3. Identification of potential Conflicts of Interest

The Platform Operator has, based on an internal risk analysis, identified the following situations in which a Conflict of Interest may occur. This list is not exhaustive and is reviewed periodically.

Own financial interest in a Campaign A Conflict of Interest may arise when the Platform Operator, a Relevant Person or a Connected Person acts as an Investor themselves in a Campaign offered on the Platform, or has a financial interest themselves in the success of a specific Campaign.

Ties with an Entrepreneur A Conflict of Interest may arise when a Relevant Person or Connected Person has a personal, family or business tie with an Entrepreneur using the Platform.

Differential fees A Conflict of Interest may arise if the Platform Operator receives a fee from an Entrepreneur that can be influenced by the size or the success of the Campaign, in a manner that is not objectively justified.

Cross-selling with the Licensed Activity A Conflict of Interest may arise when an Entrepreneur or Investor is or would become a client of the Licensed Activity of the Platform Operator, and the Platform Operator would be inclined to link the two activities in a non-transparent manner.

Gifts and benefits A Conflict of Interest may arise when a Relevant Person would receive a gift or benefit from a User that could influence their objective judgment.

Personal transactions A Conflict of Interest may arise when a Relevant Person has knowledge of a Campaign that is not publicly available and would use this information for personal gain or for a Connected Person.

4. Measures for prevention and management

4.1 Organizational and functional separation

The Platform Operator guarantees a clear organizational, functional and information-based separation between the team in charge of the Platform and the team in charge of the Licensed Activity. This separation includes:

  • a clear division of roles and powers in the organizational chart;
  • a separate IT access management, so that information cannot circulate inappropriately between the two activities;
  • if the same persons were to work for both activities, a formal ethical-functional framework guaranteeing the separation of decisions.

4.2 Strict objective criteria for Campaign activation

The limited checks carried out by the Platform Operator prior to the activation of a Campaign Page (valid existence of the Entrepreneur, exclusion of certain sectors) are performed on the basis of pre-established objective criteria, which are applied equally to every Entrepreneur. The Platform Operator exercises no discretionary assessment in this regard that depends on an individual commercial interest.

4.3 No active matching

The Platform Operator expressly refrains from any active matching, recommendation or selection of Investors with respect to certain Campaigns. Investors are approached exclusively by the Entrepreneur themselves within their own Network. This structurally avoids the Platform Operator exercising an influence on the choices of Investors.

4.4 Own investments by Relevant Persons

Relevant Persons wishing to invest in a Campaign on the Platform personally or via a Connected Person must report this in advance to the Compliance Officer. The Compliance Officer assesses whether the Conflict of Interest can be managed (for example, by excluding the Relevant Person from any decision regarding that Entrepreneur), or whether the investment must be refused.

4.5 Remuneration structure

The remuneration received by the Platform Operator consists of the Launch Fee, the Extension Fee and the Service Fee. The Launch Fee and the Extension Fee are fixed amounts. The Service Fee is calculated as a percentage of the amount raised by the Entrepreneur, which is used solely as an objective calculation basis for the scale and complexity of the further administrative follow-up of the financing.

The Service Fee is not a commission, not a success fee and not a fee for arranging financing or for the success of the Campaign. The remuneration of the Platform Operator is in no way linked to any substantive assessment, recommendation or approval of a Campaign, an Entrepreneur or an Investor. The Platform Operator does not bring in Investors and makes no recommendations.

The use of the amount raised as a calculation basis may in theory give rise to a Conflict of Interest. This risk is managed by the measures in this Policy, including the complete functional, contractual and accounting separation of the Licensed Activity, the transparent disclosure of the remuneration structure to the Entrepreneur in the Special Conditions, and the fact that the Platform Operator is not a party to any Loan Agreement.

4.6 Gifts policy

Relevant Persons may not accept gifts, benefits or remunerations from Users above a symbolic value of 100 EUR. Any offer of a gift above that threshold must be reported to the Compliance Officer.

4.7 Information barriers and confidentiality

Relevant Persons are bound by strict confidentiality regarding the data of Users and the content of Campaigns. They are prohibited from using non-public information for personal gain or for a Connected Person.

4.8 Training

All Relevant Persons receive training upon recruitment and periodically thereafter regarding this Policy and the manner in which Conflicts of Interest must be recognized and reported.

5. Procedure for reporting Conflicts of Interest

5.1 Duty to report

Every Relevant Person who has knowledge of an actual or potential Conflict of Interest is obliged to report this promptly to the Compliance Officer, preferably by e-mail to compliance@samenlenen.be.

5.2 Assessment by the Compliance Officer

The Compliance Officer investigates every report and determines which management measures must be taken. Possible measures include:

  • the exclusion of the Relevant Person from decision-making regarding the User involved;
  • increased supervision of the transaction or the relationship;
  • providing additional information to the User involved;
  • if applicable, the refusal to continue the transaction or the relationship.

5.3 Register of Conflicts of Interest

The Compliance Officer maintains a confidential register of the reported Conflicts of Interest and the measures taken. This register is kept for at least five (5) years.

6. Communication to Users

6.1 General transparency

This Policy is publicly accessible via the Platform and is brought to the attention of the Users.

6.2 Specific notification

If, notwithstanding the measures described in Article 4, a conflict of interest cannot be prevented or neutralised with a reasonable degree of certainty, the Platform Operator shall inform the User(s) concerned thereof in advance and transparently, in such a way that these User(s) can make an informed decision regarding the continuation of the relationship.

7. Supervision and evaluation

The Compliance Officer reports at least annually to the administrative body of the Platform Operator on the application of this Policy.

The Policy is evaluated and updated at least every two (2) years, and additionally whenever a material change in the activities of the Platform Operator or in the regulatory framework justifies this.

8. Entry into force

This Policy enters into force on 3 August 2026 and replaces every previous version. The applicable version can always be consulted via the Platform.