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Transparency

Conflicts of Interest Policy

Last updated: 22 June 2026  ·  Version 1.0

1. Purpose

Vestinit Ventures Australia Pty Ltd ACN 123 456 789 ("Vestinit") is committed to transparency regarding potential conflicts of interest that may affect the objectivity of information presented on the Platform. This policy identifies the types of conflicts that exist or may exist, and the measures we take to manage them.

Important disclosure: Vestinit, its principals, directors, employees and related entities have or may have financial interests in companies and opportunities featured on the Platform. This is a structural feature of a venture capital and capital introduction business. We disclose all known conflicts below. Investors must take these conflicts into account when evaluating any opportunity on the Platform and should form independent judgments.

2. Types of Conflicts

Related-Party Opportunities Disclosed

Some opportunities featured on the Platform involve companies in which Vestinit principals, directors or their related entities hold equity interests or have advisory, commercial or contractual relationships. These include but may not be limited to: AiPAYGO, FAIRYDE, Jayride Limited (ASX: JAY), MYQR.AT, and associated SPVs. These relationships are disclosed in the deal materials for each relevant opportunity. Vestinit has a financial incentive for these companies to successfully raise capital.

Success Fees and Equity Participation Disclosed

Vestinit may receive success fees (typically calculated as a percentage of capital raised), equity warrants, convertible instruments, or other economic benefits from issuers upon successful completion of a capital raise. These arrangements are disclosed in deal materials. The existence of success fees means Vestinit has a financial incentive to facilitate the completion of a raise, regardless of whether the investment is suitable for any particular investor.

Co-Investment by Vestinit and Related Parties Disclosed

Vestinit principals and their related entities may co-invest in opportunities alongside platform investors. Vestinit does not represent that its principals' investment decisions are a guide or recommendation for platform investors. Co-investment by principals may occur on different terms than those available to platform investors.

Platform Operator Interests Disclosed

As the Platform operator, Vestinit has an interest in the growth and commercial success of the Platform and in maintaining relationships with issuers. These interests may influence decisions about which opportunities to feature, how they are presented, and other Platform operations. We take steps to ensure that these interests do not prevent us from removing opportunities that are unsuitable or fraudulent.

Advisory and Consulting Arrangements Disclosed

Vestinit or its principals may provide advisory, consulting, or management services to issuers listed on the Platform. Where such arrangements exist, they are disclosed in the relevant deal materials. Such arrangements may give Vestinit access to non-public information about issuers that is not available to all platform investors.

3. How We Manage Conflicts

We manage conflicts of interest through the following measures:

  • Disclosure: All known material conflicts are disclosed in this policy and in the deal materials for each relevant opportunity
  • Informed consent: Users are required to acknowledge this Conflicts Policy as part of registration
  • Information barriers: Where practicable, we maintain separation between deal-origination activities and investor-facing activities
  • Consistent terms: We aim to ensure that the terms available to platform investors for any opportunity are not materially worse than those available to Vestinit insiders, and will disclose any material differences
  • No personal advice: Vestinit does not provide personal investment recommendations and does not direct investors toward or away from specific opportunities
  • Regular review: This policy is reviewed at least annually and updated to reflect new or changed conflicts

4. Investor Obligations

You are responsible for independently evaluating all investment opportunities, taking into account the conflicts disclosed in this policy and in deal materials. You should obtain independent financial, legal and taxation advice before making any investment decision. The existence of conflicts does not make an investment unsuitable, but it is a factor you should weigh in forming your own judgment.

5. Reporting Concerns

If you believe Vestinit has failed to adequately disclose a conflict of interest or has acted in a manner that has disadvantaged you as a result of an undisclosed conflict, please contact us at compliance@vestinit.ventures. We take all such concerns seriously and will respond within 10 business days.

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