CONFLICT OF INTEREST PREVENTION AND MANAGEMENT POLICY
During the course of our activities as a portfolio management company, Capital Export may manage investment funds such as Fonds Professionnel de Capital Investissement (FPCI – French Professional Private Equity Fund).
In accordance with existing regulations, Capital Export has taken all reasonable steps to identify potential conflicts of interest that may arise in the course of providing investment services to its clients, or as part of FPCI fund management activities:
– Conflicts between Capital Export, its employees, or any other person directly or indirectly linked to Capital Export by control, on the one hand, and its clients, on the other.
– Or conflicts between two of Capital Export’s clients.
IDENTIFYING CONFLICTS OF INTERESTS
In order to identify conflicts of interest that could adversely affect the interests of its clients, and in accordance with the AMF’s General Regulations, Capital Export has taken into account the possibility that the management company, its employees, and clients may find themselves in a conflict of interest during the course of its investment fund management activities.
Capital Export has identified the following situations which may give rise to a conflict of interest presenting a material risk of damage to the interests of one or more clients when:
– Capital Export or one of its employees is likely to make a financial gain, or avoid a financial loss, at the expense of a client
– Capital Export or one of its employees has an interest in the outcome of a service provided to the client that is distinct from the client’s interest in that outcome
– Capital Export or one of its employees has a financial or other incentive to favor the interest of another client over the interests of the client to whom the service is provided
– Capital Export or one of its employees carries on the same business as the client
– Capital Export or one of its employees receives or will receive an inducement in relation to a service provided to the client, in the form of monies, goods or services other than the standard commission or fee for that service
All the potential conflicts of interest are summarized in a Conflicts of Interest Register.
MANAGING CONFLICTS OF INTEREST
In light of the potential conflicts of interest as detailed above, Capital Export has implemented a prevention policy as summarized below, including:
– Control of the composition of the Board of Directors during the investment selection process
– Measures to monitor the services provided by Capital Export’s employees
– Measures to monitor the personal transactions of Capital Export’s employees
– A policy to declare and limit gifts and inducements from clients, suppliers, or partners
– A selection process for external service providers
– Management of confidential or privileged information
The full conflict of interest prevention and management policy is available upon request by contacting Capital Export at firstname.lastname@example.org.
ENVIRONMENTAL, SOCIAL, AND GOVERNANCE (ESG) CRITERIA AS PART OF THE INVESTMENT POLICY
Pursuant to article L.533-22-1 of the Monetary and Financial Code, management companies must inform investors of the ways in which environmental, social, and governance (ESG) criteria are incorporated into the company’s management process.
To date Capital Export does not include environmental, social, and governance (ESG) criteria as part of its investment policy.
COMPLAINT HANDLING POLICY
As a portfolio management company, Capital Export must adhere to the principle that the interests of its clients come first. The management company has therefore established a procedure to handle all client complaints efficiently, transparently, and fairly.
To lodge a complaint please contact us:
By mail at the following address:
CAPITAL EXPORT, 5 quai Hippolyte Jaÿr – 69009 Lyon
Capital Export will acknowledge receipt of your request within 10 working days and will respond to your complaint within two months following receipt of the complaint. In the event that circumstances arise that prevent us from meeting this deadline, we will provide you with the reason for the delay.
If you are unhappy with our response, you may also contact the AMF Ombudsperson at the following address:
Autorité des Marchés Financiers
17 Place de la Bourse
75082 PARIS CEDEX 02
The AMF’s Mediation Charter is also available on their website: