Legal Opinion on Hive5 Legal Status and Regulatory Requirements

For the investor to fully trust the financial company, it is necessary to answer legal and regulatory questions. Recognising this importance, Hive5 Marketplace applied for the expertise of Lithuanian and Croatian law firms (ECOVIS ProventusLaw, Kvainauskas, Andziulytė, and Partners and Divjak, Topić, Bahtijarević & Krka Law Firm). The legal opinions clarified the Company's legal status, regulatory landscape, and compliance with relevant laws.

Hive5 Marketplace Overview

• Hive5 Marketplace d.o.o., registered with the Commercial Court of Zagreb under registration number 081441259, operates out of Ulica Račkoga 8, Zagreb, Croatia.
• Business activities include listing claims from loans provided by lenders to borrowers, enabling investors to purchase such claims on the Platform by entering into assignment agreements with lenders.
• The company's registered business activity with the Commercial Court Registry refers to the financing of commercial operations.
• The Platform acts exclusively as an intermediary in selling claim rights between investors and loan originators/lenders.

Regulation in Croatia

After analysing the legal requirements, legal company Partners and Divjak, Topić, Bahtijarević & Krka Law Firm submitted a conclusion: "In our view, by performing Business Activities, hive5 currently does not perform regulated activities that would require a specific license issued by the competent Croatian authorities (such as the Croatian National Bank and the CFSA). Therefore, in our view, at the time of the issuance of this legal analysis, the Client is not obligated to have a license or supervisory approval by the Croatian competent bodies for the performance of Business Activities in the Republic of Croatia". The statement was issued on 23/01/2024. Also, a Lithuanian law firm submitted the same conclusions.

The conclusion has been assessed primarily by considering provisions of applicable Croatian laws regulating financial markets, investment services, and, subsequently, those regulating credit institutions; these are the Croatian Capital Markets Act, the Croatian Credit Institutions Act, the Croatian National Bank Act, the Croatian Financial Services Supervisory Agency Act, the Croatian Consumer Credit Act and the Croatian Factoring Act.

Business Vision

CEO of hive5 Ričardas Vandzinskas says: "If we change the business model, then we will apply for the license the new activity would require. However, there is no need for that now. Now, we focus on geographic expansion and non-project financing. It is important to note that our team consistently works with lawyers to ensure compliance with EU legal guidelines".

By addressing legal considerations, our company aims to gain trust among investors, showcasing its commitment to smooth business operations and transparent communication. If you have any questions or concerns, the hive5 team is always available at support@hive5.co