Regulatory information

Complaints

A “complaint” is a declaration of the client’s dissatisfaction with the management company. It is important to note that a request for information, for an opinion, for clarification, or for a service does not constitute a complaint.

Initiative & Finance Gestion has established and maintains an operating procedure for handling complaints made by its clients.

In the event of a difficulty or disagreement concerning an investment service provided by Initiative & Finance Gestion, you can contact your usual contact person, or the General Secretary, or send a letter to the company’s head office.

Upon receipt of the complaint, acknowledgment of receipt will be sent within 10 working days, unless a response has been given within that timeframe. A response will be sent to the client within 2 months of the date on which the complaint is received, unless duly proven special circumstances arise.

Initiative & Finance Gestion will nevertheless endeavor to respond as quickly as possible. Furthermore, if, due to the complexity of the issue to be resolved, this time limit is exceeded, the management company will notify you in advance.

Recourse to a mediator is possible for all clients if they are not satisfied with the response to their complaint. You may refer a matter to the mediator by writing to the following address:

Médiateur de l’AMF

Autorité des Marchés Financiers

17, place de la Bourse

75082 Paris cedex 02

For further information: http://www.amf-france.org/fr/le-mediateur

The complaints policy is available on request from the company’s head office.

Conflict of Interest Policy

A conflict of interest is a situation in which the interests of the management company or its personnel conflict directly or indirectly with the interests of its funds, their holders or their principals. It may also take the form of a conflict between funds or between holders/principals.

The prevention and management of conflicts of interest at Initiative & Finance Gestion is in line with the general principles of the French Monetary and Financial Code and the General Regulations of the French Financial Markets Authority (AMF), which specify in particular that the management company has the following obligations:

  • Establish a policy for managing conflicts of interest ;
  • Detect conflicts of interest ;
  • Keep a register of conflicts of interest that have been proven to exist or could arise ;
  • Inform investors when it has not been possible to resolve conflicts.

Our conflict-of-interest prevention and management policy involves establishing procedures to detect and manage conflicts that may occur during our collective and individual asset management activities and our investment advisory activities.

The aim of this policy is to ensure the protection and primacy of the interests of stakeholders in the various funds and mandates we manage or recommend.

For further information, please contact the management company.

 

Voting Rights

The voting and abstention policy is available on request from the company’s head office.

 

ESG Policy

The company’s strategy on the consideration of ESG information is based on the following elements:

  • The general approach to taking account of ESG criteria in the company’s investment and risk management policy is based on a systematic evaluation of ESG risks during the investment selection process, most often via a specialist external service provider hired to carry out Due Diligence. Some sectors may also be excluded from the investment policy (negative screening);
  • Once a year, investors who so request will receive the ESG data concerning the portfolio companies of the funds in which they have invested. e.g. absenteeism, number of women on governance bodies, etc.
  • The funds for which ESG criteria are taken into account are Initiative & Finance FPCI II and Initiative & Finance FPCI III, representing [x]% and [x]% respectively of Initiative & Finance’s exposure.