Conflicts of Interest Policy

1. What is a Conflict of Interest?

A conflict of interest arises when ZimCrowd's interests, or those of our directors, officers, employees, or agents, conflict with the interests of our customers. This includes situations where:

• Personal interests may influence professional decisions
• Financial incentives may affect impartiality
• Relationships may compromise objectivity
• Duties to different parties may conflict

2. Types of Conflicts

2.1 Business Conflicts

• Ownership interests in competing businesses
• Financial incentives tied to specific outcomes
• Referral arrangements with third parties
• Cross-selling opportunities

2.2 Personal Conflicts

• Family relationships with customers or partners
• Personal financial interests in customer transactions
• Gifts or entertainment from business partners
• Outside employment or consulting arrangements

2.3 Operational Conflicts

• Internal departments with competing objectives
• Performance incentives that may influence decisions
• Resource allocation decisions
• Technology or vendor selection processes

3. Identification and Assessment

3.1 Ongoing Monitoring

We continuously monitor for potential conflicts through:

• Regular conflict assessments
• Employee reporting requirements
• Automated conflict detection systems
• Periodic compliance reviews

3.2 Risk Assessment

Each identified conflict is assessed for:

• Potential impact on customers
• Likelihood of occurrence
• Effectiveness of mitigation measures
• Need for disclosure or avoidance

4. Management and Mitigation

4.1 Avoidance

Where possible, we avoid conflicts by:

• Prohibiting certain activities or relationships
• Implementing information barriers
• Separating conflicting duties
• Declining business opportunities that create conflicts

4.2 Controls and Procedures

We implement controls including:

• Independent oversight and approval processes
• Documentation and audit trails
• Regular training and awareness programs
• Escalation procedures for complex conflicts

4.3 Disclosure

When conflicts cannot be avoided, we disclose them by:

• Clear communication to affected customers
• Documentation in transaction records
• Public disclosure in relevant policies
• Reporting to regulatory authorities when required

5. Specific Conflict Scenarios

5.1 Loan Approval Process

Personal relationships or financial interests in loan outcomes are strictly prohibited. All loan decisions must be based solely on creditworthiness and platform policies.

5.2 Secondary Market Trading

ZimCrowd does not participate in secondary market trading to avoid conflicts between our interests and those of lenders.

5.3 Third-Party Relationships

Relationships with payment processors, credit bureaus, and other service providers are managed to ensure they do not influence customer treatment.

5.4 Employee Personal Lending

Employees and their immediate family members may not borrow through the platform to avoid conflicts in loan approval processes.

6. Reporting and Whistleblowing

6.1 Internal Reporting

Employees must report potential conflicts to their supervisors or the compliance team immediately.

6.2 Anonymous Reporting

We provide anonymous channels for reporting concerns about conflicts of interest.

6.3 Protection

Individuals who report conflicts in good faith are protected from retaliation.

7. Training and Awareness

All employees receive regular training on:

• Identifying conflicts of interest
• Reporting procedures
• Ethical decision-making
• Customer protection principles

8. Monitoring and Review

8.1 Regular Audits

The compliance team conducts regular audits of conflict management procedures.

8.2 Policy Updates

This policy is reviewed annually and updated as needed to address new risks or regulatory requirements.

8.3 Effectiveness Assessment

We regularly assess the effectiveness of our conflict management measures.

9. Consequences of Violations

Violations of this policy may result in:

• Disciplinary action up to termination
• Civil or criminal penalties
• Regulatory sanctions
• Reputational damage

10. Contact Information

For questions about conflicts of interest or to report concerns:

• Email: compliance@zimcrowd.com
• Phone: +263 710 467 317
• Address: Compliance Department, ZimCrowd, 123 Samora Machel Avenue, Harare, Zimbabwe