Conflicts of interest
Last updated: 24 juin 2026
1. Introduction
Bricks.co is committed to putting its clients' interests first by implementing measures to identify, prevent and manage potential conflicts of interest. This policy is public and accessible on the Bricks.co platform.
2. Identifying conflicts of interest
Any situation in which the interests of Bricks.co's clients could diverge from those of the company, its executives, employees or partners constitutes a conflict of interest. The main conflict-of-interest situations identified include:
- Existence of privileged ties
- Simultaneous exercise of conflicting roles
- Financial or shareholding dependency
- Sharing of premises and human resources with related entities
- Relationships with service providers and delegates
- Granting or accepting benefits or gifts
- Access to privileged information or carrying out personal transactions
- Variable remuneration of staff
- Lack of independence in investment decisions
- Preferential allocation of funds
3. Preventing conflicts of interest
Bricks.co implements measures to prevent conflicts of interest, including:
- Training staff on the prevention and management of conflicts of interest
- Informing and raising awareness among staff upon arrival and every year
- Analysing potential conflicts of interest when selecting new projects
- Transparency with investors when a conflict of interest is identified
4. Detecting conflicts of interest
Three levels of controls are in place to detect conflicts of interest:
- First level: by members of the various departments and their managers
- Second level: by the compliance and internal control officer
- Third level: by the chair, who verifies compliance with procedures during selection committees
Detected conflicts of interest are recorded in a register reviewed annually.
5. Managing conflicts of interest
The compliance officer analyses the nature, causes and consequences of the conflicts of interest identified and takes the appropriate measures. If the conflict is already addressed in the management policy, supervisory measures are applied. Otherwise, the conflict is entered in the register and corrective actions are implemented.
Where the measures taken are not sufficient to ensure that the risk to clients is avoided, clients are informed of the nature and source of the conflicts of interest.
6. Information barriers
To strengthen the prevention of conflicts of interest, Bricks.co restricts the flow of information:
- Technical level: an authorisation and rights-assignment system for platform users
- Organisational level: an account manager is assigned to each project and may not handle projects from competing companies
7. Record keeping and traceability
All records related to this policy are kept for at least five years. The conflicts-of-interest register is stored securely and accessible only to the compliance officer and the chair. The content of this register is confidential.
8. Specific prohibited situations
Bricks.co does not accept as project owners:
- Its shareholders holding 20% or more of the share capital or voting rights
- Its executives or employees
- Any natural or legal person linked to these shareholders, executives or employees by a controlling relationship
9. FAQ
Conflict-of-interest situations can arise naturally in the course of the company's activities. Any decision influenced by outside interests must be reported to the compliance officer.
If a staff member is unsure whether they are in a conflict-of-interest situation, they should assess whether their decision could benefit a client, a group company, or themselves, to the detriment of the client's primary interests. When in doubt, they must immediately inform the compliance officer.
10. Speak Up
Bricks.co encourages its staff to report any conflict-of-interest situation. No retaliation will be tolerated against those who report, in good faith, a potential or actual conflict of interest.
Conclusion
Bricks.co's conflicts-of-interest management policy is essential to protect clients' interests and ensure the integrity of operations. It is reviewed periodically to ensure its effectiveness and relevance.