Summary of the Conflicts of Interest Policy

Van Sterling Capital Ltd (the "Company") is a Maltese investment firm authorised and regulated by the Malta Financial Services Authority under licence number VANS-IF-9616. The Company operates two platforms: smarter-investments.com, through which it provides discretionary portfolio management by way of social and copy trading, and intokia.com, through which it distributes security tokens issued on the basis of a Wertpapier-Informationsblatt approved by BaFin. This summary is provided in accordance with Article 23(2) of Directive 2014/65/EU (MiFID II) and describes the general nature and sources of conflicts of interest that may arise in the Company's business and the principal measures taken to manage them.

Sources of Conflicts of Interest

On the copy trading platform (smarter-investments.com), the Company selects the investment strategies made available on the platform and earns management and, where applicable, performance fees from clients who subscribe to those strategies. The Company also has commercial relationships with Trading Mentors whose strategies are listed on the platform. These relationships could, in the absence of adequate controls, create an incentive to promote strategies that generate the highest fee revenue rather than those most aligned with the interests of each client. Where multiple client accounts are subscribed to the same strategy and orders are aggregated, the allocation of fills must be managed fairly.

On the token platform (intokia.com), the Company distributes security tokens to investors on a non-advised, execution-only basis and simultaneously receives fees from the issuers of those tokens. These fees include a one-time setup fee, a placement commission calculated as a percentage of the subscription volume successfully raised, an annual platform and technology fee, and an ongoing client verification fee. The Company also maintains for each issuer an electronically managed register of token holders (Namensregister), creating a dual role as distributor to investors and service provider to the issuer. These arrangements create a financial incentive to maximise the volume of offerings distributed on the platform and, in the dual-role context, may give rise to situations in which the interests of investors and the interests of the issuer are not fully aligned.

The Company may in the future develop investment products or strategies that create a link between the two platforms, for example by making available on the copy trading platform a strategy whose underlying portfolio includes security tokens distributed on the token platform. Such a crossover would not impose additional costs on investors or on issuers but would mean that the Company earns revenue in both its portfolio management and its distribution capacity.

Relevant persons of the Company (directors, officers, employees and persons linked to the Company by control) may hold personal investments or have outside business interests that could conflict with the duty to act in the best interests of clients.

Measures Taken to Manage Conflicts

The Company has adopted organisational and administrative arrangements to prevent, manage and monitor the conflicts described above. These include the segregation of duties between client-facing and issuer-facing functions; information barriers that prevent the inappropriate sharing of confidential information between the two platforms; a remuneration structure that does not link the variable pay of staff involved in appropriateness assessments or order transmission to subscription volumes or issuer-specific fees; a structured due diligence and selection process for admitting issuers to the token platform, designed to ensure that listings are not driven solely by fees; fair and proportionate allocation procedures for aggregated orders on the copy trading platform; training of all relevant persons on the identification and management of conflicts; a gifts policy that prohibits the acceptance of benefits that could impair independence; ongoing monitoring by the Compliance Officer and periodic review by the Board of Directors; and the maintenance of a Conflicts of Interest Register in which all identified conflicts and the actions taken to manage them are recorded.

The existence, nature and amount of all fees received by the Company from issuers are disclosed to each investor in the Costs and Charges Disclosure prior to subscription. The Company has determined that the receipt of such fees is designed to enhance the quality of the service provided to investors and does not impair the Company's duty to act in clients' best interests, because the fees enable the Company to maintain the platform, perform regulatory and compliance functions, maintain the Namensregister and carry out ongoing customer due diligence at no direct cost to the investor.

Disclosure as a Measure of Last Resort

Where, despite the measures described above, a conflict of interest cannot be adequately prevented or managed through organisational arrangements, the Company will disclose the nature and source of the conflict to the affected client in sufficient detail to enable that client to take an informed decision. Such disclosure is a measure of last resort and does not relieve the Company of its obligation to continue to manage the conflict through all available means.

Further Information

This summary does not purport to be exhaustive. The full Conflicts of Interest Policy, which contains further detail on the Company's governance framework, is an internal governance document that is available to the Malta Financial Services Authority on request. If you have any questions regarding the Company's management of conflicts of interest, please contact the Compliance Officer at [email protected] or the Managing Director at [email protected].

Issued by Van Sterling Capital Ltd, MFSA Licence VANS-IF-9616.