Business continuity plan, management of the Bondholders' Group and debt recovery framework

1. Purpose and scope

The purpose of this document is to describe the measures implemented by Bricks.co, a Crowdfunding Service Provider (CSP) authorized by the French Financial Markets Authority (AMF), to ensure:

• the orderly continuity of its essential activities in all circumstances;
• the protection of investors and the proper performance of crowdfunding contracts;
• the legal representation and defense of the collective interests of bondholders (the "Bondholders' Group");
• and the rigorous management of payment monitoring, handling of arrears and recovery of receivables.

This framework applies to all crowdfunding operations offered by Bricks.co, whether structured as bonds or participatory loans.

2. Regulatory framework

The policies and procedures described below are established in accordance with:

• Regulation (EU) 2020/1503 of 7 October 2020 on European crowdfunding service providers;
• Delegated Regulation (EU) 2022/2112;
• Articles L.548-1 et seq. of the French Monetary and Financial Code;
• Articles L.228-46 et seq. of the French Commercial Code (relating to the Bondholders' Group);
• Recommendations and guidelines of the AMF and the ACPR relating to continuity plans, wind-down arrangements and information obligations applicable to CSPs.

3. Business Continuity Plan (BCP)

3.1. Objectives

Bricks.co's Business Continuity Plan (BCP) aims to guarantee the orderly and secure continuation of the platform's critical functions, in particular:

• the management of ongoing investments, repayments and contracts;
• the continuity of financial flows operated via Lemonway, a payment institution authorized by the ACPR (CIB 16568);
• investors' continuous access to their contractual data and individual account;
• transparent communication with supervisory authorities and investors.

3.2. Segregation and protection of funds

Funds entrusted by investors are held in individualized payment accounts opened in their name at Lemonway.

These accounts are legally and accounting-wise segregated from Bricks.co's own accounts, ensuring the full protection of funds, even in the event of a platform failure.

In the event of unavailability or liquidation of Bricks.co, Lemonway remains responsible for returning uninvested funds and continuing the flows related to existing contracts.

3.3. Technical and organizational resources

• Secure infrastructure: hosting of systems in the European Union, redundancy, daily backups and an ISO 27001-certified disaster recovery plan;
• Reliable archiving: storage of contractual documents (subscription forms, contracts, registers) in an NF Z42-013-certified digital vault;
• Continuous supervision: real-time monitoring of service availability and an escalation plan in the event of a major incident;
• Backup plan: temporary transfer of operations to an approved third-party provider (Capsens) in the event of prolonged unavailability.

4. Wind-down arrangement

4.1. General principle

In accordance with AMF regulations, Bricks.co has implemented a wind-down arrangement entrusted to its partner Capsens, in order to ensure the orderly continuation of financing operations in the event of:

• bankruptcy or court-ordered liquidation;
• withdrawal of CSP authorization;
• voluntary cessation of activity.

4.2. Role of Capsens

If the wind-down plan is triggered:

• Capsens ensures the continuity of contract and repayment management, without any action required from investors;
• Repayment schedules are maintained and financial flows executed by Lemonway;
• Investors retain access to their data and documents via a secure interface;
• Information obligations towards the AMF, the ACPR and investors are fulfilled.

4.3. Supervision and audit

Capsens acts under the control of:

• the Financial Markets Authority (AMF);
• the court-appointed liquidator, where applicable;
• and Lemonway for the financial part.

An annual joint audit by Bricks / Capsens / Lemonway verifies the technical reversibility and compliance of the arrangement.

5. Management of the Bondholders' Group

5.1. Constitution and powers

In accordance with Articles L.228-46 et seq. of the French Commercial Code, the holders of bonds of the same issue are automatically grouped into a Bondholders' Group (Masse des Obligataires), endowed with civil legal personality.

The Group is represented by a Representative of the Group appointed in the bond contract, holding in particular the following powers:

• to receive notifications of payment default;
• to approve the activation of guarantees or security interests;
• to bring legal action on behalf of the collective body of bondholders;
• to negotiate or approve a settlement plan;
• and to convene general meetings of bondholders.

Unless otherwise decided, Bricks.co acts as representative of the Group until the maturity of the bonds.

5.2. Substitution in the event of Bricks.co's failure

In the event of Bricks.co's failure:

• the representation of the Group is automatically transferred to Capsens, within the framework of the wind-down plan;
• Capsens becomes the legal representative of the Group, with the same powers and obligations;
• Bricks.co, or its court-appointed administrator, transmits under AMF control all registers, contracts and guarantees;
• Capsens continues the monitoring of repayments, the management of security interests and communication with investors until full extinction of the commitments.

5.3. Functioning of the Group

• Decisions of the Group are taken by a two-thirds majority of the votes cast;
• Each bond confers one vote;
• Meetings may be held in person, remotely or by written consultation (including electronic);
• The Representative may be given a mandate to: bring or pursue legal action; accept or reject a settlement plan; activate or substitute guarantees; consent to a contract extension within set limits.

6. Payment monitoring, handling of arrears and recovery

6.1. Automated monitoring of repayments

Each bond or loan contract is subject to automated monitoring of payment dates via Bricks.co's internal system.

This system checks the proper receipt of payments and generates alerts in the event of delay.

A complete overhaul launched in 2025 aims to fully automate the detection, follow-up and investor information process, while maintaining permanent human oversight.

6.2. Progressive recovery procedure

In the event of non-payment, a strict procedure is triggered:

6.3. Penalties and late-payment interest

In accordance with the contractual clauses:

• late-payment interest may be applied at the contractual or statutory rate;
• a fixed penalty may compensate for the costs related to the incident;
• judicial or recovery costs may be charged to the defaulting debtor.

6.4. Enforcement of guarantees

In the event of prolonged non-payment, the Representative of the Group:

• activates the guarantees (security trust, mortgage, lender's lien, etc.);
• acts for the recovery of receivables on behalf of the collective body of investors;
• coordinates judicial proceedings with the relevant trustees, notaries or court-appointed agents;
• ensures the redistribution of recovered sums via Lemonway.

6.5. Information and transparency

Investors are informed at each stage:

• as soon as the default is detected;
• during reminders and formal notices;
• at the launch of the vote and during the recovery phase;
• via the project page and personalized notifications.

6.6. Reminder of risks

The recovery framework aims to protect investors, but does not eliminate the risk of capital loss inherent in any crowdfunding investment.

Bricks.co recommends diversification and investing amounts suited to each investor's risk profile.

7. Governance and review of the framework

The Business Continuity Plan, the Wind-down Arrangement and the Recovery Framework are reviewed annually by Bricks.co's Compliance & Financial Security Department.

Each year, a continuity test is carried out to verify:

• the integrity and availability of hosted data;
• and the compliance of repayment and communication procedures.

8. Contacts and supervision

Bricks.co – Compliance & Financial Security Department

📩 contact@bricks.co 📞 +33 (0)4 81 68 17 22 🏢 90 Rue Maryam Mirzakhani – 34000 Montpellier

Wind-down provider: CAPSENS Payment institution: LEMONWAY (ACPR authorization No. 16568) Supervisory authority: Financial Markets Authority (AMF)