Conflicts of Interest

Identification

Volum Invest AS (Org.nr 937 601 883) is a Norwegian aksjeselskap providing general investment recommendations through quantitative signal services. The company is not licensed as an investment firm by Finanstilsynet, as its services constitute general recommendations, not personalised investment advice.

The person responsible for the production of recommendations:

• Sander Pettersen Heio, CEO / Daglig leder

Methodology

All recommendations are generated by systematic quantitative models using multi-factor composite scoring. Factors include price momentum metrics, volume dynamics, and volatility structure indicators. Stocks are ranked cross-sectionally based on composite scores. No discretionary judgment is applied to individual signals.

Key sources of information: price, volume, and volatility data from public market data providers (Yahoo Finance via the yfinance API, with dividend-adjusted OHLC data). Backtests use the same data with point-in-time corrections where possible.

Nature of the recommendation

The service produces systematic buy, sell, and trim signals derived from a cross-sectional quantitative ranking of the universe. Each stock is scored and ranked from highest to lowest composite score, and the buy / sell / trim label follows from where that score sits relative to the model's entry and exit thresholds. These signals are general investment recommendations within the meaning of MAR Article 20: they are generated by algorithm, applied uniformly to all subscribers, and do not constitute personalised advice to buy or sell for any specific individual.

Meaning of each signal. Buy — the model's entry conditions are live. Sell — the model has exited the position. Trim — price has reached the upper band; a partial reduction, not a full exit. The model uses no fixed holding period: a position stays open until the first of five defined exit conditions fires, so realised holding periods vary from days to months. The full distribution, per closed position, is published at /episodes and described at /methodology.

The general / personal boundary

The service is deliberately built so that no output is selected, ranked, or filtered on the basis of an individual subscriber's holdings or circumstances. Every subscriber on a given tier sees the same signals, the same scores, and the same rankings.

The site does provide tools that operate on a portfolio the subscriber enters themselves — pairwise and portfolio correlations, concentration warnings, beta, realised volatility, and currency exposure. These return measurements, not selections: they tell the subscriber what the relationship is between instruments they have chosen, and the subscriber decides what to do with that. No instrument is proposed to a subscriber because of what they hold.

This boundary is load-bearing. A recommendation that names specific instruments and is selected on the basis of a particular person's circumstances is a personal recommendation under MiFID II (Commission Delegated Regulation (EU) 2017/565, Article 9) and therefore investment advice — a licensed activity under verdipapirhandelloven § 2-1 which Volum Invest AS does not hold, and one that falls outside MAR Article 20 entirely. Two features that crossed this line — a "BUY suggestions" panel that ranked non-held instruments by their correlation to the subscriber's own portfolio, and a "best diversifiers for your book" list built the same way — were removed on 2026-08-12. Any future feature that selects or ranks instruments per subscriber requires legal review before release.

Holdings of Volum Invest AS and its principals

Volum Invest AS and its principals may hold positions in securities covered by the signal service. A current, dated list of all such positions is maintained at /holdings and updated whenever a position is opened or closed. The holdings page is publicly accessible and is the authoritative source for the company's current and recent positions.

Volum Invest AS and its principals hold no net long or short position exceeding 0.5% of the total issued share capital of any issuer covered by the service. Positions are held for the company's and principals' own account in ordinary market size. Volum Invest AS is not a market maker or liquidity provider in any covered instrument, holds no position acquired through an underwriting or placement, and is not party to any agreement with an issuer relating to the production of recommendations.

Compensation and commercial relationships

Volum Invest AS derives revenue from subscription fees paid by subscribers to the signal service. This creates a general interest in the perceived quality of the signals but does not create a conflict specific to any individual security recommendation.

Volum Invest AS has not received compensation from any issuer of securities covered by the service, and has no investment banking or corporate finance relationship with any such issuer.

Other conflicts

No other material conflicts of interest exist at the date of this disclosure.

Review

This conflict of interest disclosure is reviewed and updated at least quarterly, or whenever a material change occurs.

Last updated: 2026-08-12