Legal information

Publisher 

Turenne Capital Partenaires
Simplified joint-stock company (SAS) with share capital of €547,520
Company registration number (SIRET): 428 167 910 000 44
Portfolio management company approved by the AMF under n° GP 99038 on 6 December 1999
Registered office: 9, rue de Téhéran – 75008 Paris, France

Chief Executive Officer

Christophe Deldycke

Publications director

Josépha Montana

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Information about Turenne Group companies

Turenne Capital Partenaires

Simplified joint-stock company (SAS) with share capital of €547,520
Company registration number (SIRET): 428 167 910 000 44
Portfolio management company approved by the AMF under n° GP 99038 on 6 December 1999

Registered office: 9, rue de Téhéran – 75008 Paris, France

Chief Executive Officer: Christophe Deldycke

Nord Capital Partenaires

Simplified joint-stock company (SAS) with share capital of €200,000
Company registration number (SIRET): 522 679 133 000 10

Portfolio management company approved by the AMF under n° GP 10000039 on 24 September 2010

Registered office: 77, rue Nationale –59000 Lille, France

Chairman:  Christophe Deldycke

Innovacom Gestion

Simplified joint-stock company (SAS) with share capital of €520,690
Company registration number (SIRET): 430 087 429 000 22
Portfolio management company approved by the AMF under n° GP 00017 on 26 July 2000

Registered office: 9, rue de Téhéran – 75008 Paris, France

Chief Executive Officer: Jérôme Faul

CNIL 

This website has been declared to the Commission Nationale Informatique et Liberté (CNIL) pursuant to the French Data Protection Act 78-17 of 6 January 1978.

Disclaimer 

The management company reiterates that its funds do not have guaranteed capital and there is a risk that your capital may be lost, as well as specific risks relating to unlisted companies on regulated markets, and they provide a long minimum investment period. The sole aim of information relating to investments made is to inform investors about portfolio holdings and this should not under any circumstances be considered as a recommendation to buy or sell. Past performances are not a reliable indicator of future performances and are not constant over time.

Any investments in an alternative investment fund (AIF) must be made after reading the legal documentation, comprising in particular the Key Investor Information Document (KIID) and its Regulations.

Personal data protection

Turenne Capital Partenaires undertakes to use your contact details only for the purposes of the business relationship with its clients. It therefore guarantees the confidentiality of this data, which shall not under any circumstances be transferred or made accessible to third parties. Persons providing Turenne Capital Partenaires with personal data via this website are informed that they have the right to access, amend and delete information concerning them in accordance with European regulation n°2016/679, the General Data Protection Regulation (GDPR), which came into force on 25 May 2018.

To exercise this right, please write to the following address: Turenne Capital, 9, rue de Téhéran, 75008 Paris

Intellectual property

The contents of this website are protected by applicable laws in the area of intellectual property and copyright law. They are subject to Article L. 122-4 of the French Intellectual Property Code. The reproduction, sending to a third party in any form whatsoever, deletion, amendment of all or some of the contents of our website are strictly prohibited. These contents are available only for private use.

Complaints handling policy

A “complaint” is a statement expressing the client’s dissatisfaction with the Management Company. It is important to note that a request for information, an opinion, clarification or service is not a complaint.

Turenne Capital Partenaires has implemented a system for handling client complaints that aims to deal with complaints from its clients effectively, objectively, transparently and free of charge. The aim is to ensure the protection and primacy of the interests of the Management Company’s clients in accordance with the general principles of AMF instruction n°2012-07.

This system applies to all clients regardless of the nature of investment products.

Complaints can be received via this website or by letter to the following address: Turenne Capital For the attention of Christophe Deldycke, 9, rue de Téhéran 75008 Paris

We advise you to send your request by registered letter with confirmation of receipt in order to guarantee correct execution of the procedure and ask you to state the reason for your complaint in the reference of your letter.

Once the complaint has been received, confirmation of receipt shall be sent within a maximum of 10 working days unless a response has been given before this time. A response shall be formulated to the client within a maximum of two months between the date the complaint is received and the date the response is sent to the client, apart from in duly justified specific circumstances.

Turenne Capital Partenaires shall endeavour to provide a response as soon as possible. Furthermore, if the complexity of resolving the issue means that this deadline cannot be met, the Management Company shall inform you of this in advance.

Mediation by the Autorité des Marchés Financiers

A mediator may be used by all clients if the response given to their complaint is unsatisfactory. You can contact the mediator in writing at the following address:

Médiateur de l’AMF
Autorité des Marchés Financiers
17, place de la Bourse
75082 Paris cedex 02

For more information: http://www.amf-france.org/Le-mediateur-de-l-AMF/Presentation.html

Policy for preventing and managing conflicts of interest

A conflict of interest is a situation in which the interests of the Management Company or its employees is directly or indirectly in conflict with the interests of its funds, their holders or representatives. This may also concern conflicts between funds or holders/representatives themselves.

Turenne Capital Partenaires’s policy for preventing conflicts of interest forms part of the general principles set out by the French Monetary and Financial Code and the General Regulations of the Autorité des Marchés Financiers, which specify in particular the following obligations devolved to the Management Company:

• Establish a policy for managing conflicts of interest
• Identify situations of conflicts of interest
• Keep a register of proven or potential conflicts of interest
• Inform investors where conflicts have not been resolved.

Our policy for preventing and managing conflicts of interest consists of defining procedures to detect and manage conflicts that may arise on the implementation of collective and individual investment management activities for third parties and investment advisory activities.

The aim of this policy is to ensure the protection and primacy of the interests of unitholders of the various funds and mandates it manages or advises.

For more information, please contact the Management Company.

Market intermediaries “Best Selection” policy

Within the framework of managing alternative investment funds (AIF) and mandates, Turenne Capital Partenaires sends intermediaries orders that it wishes to execute on the market and that are the result of its investment decisions. When sending these orders, it is required to act in the best interests of representatives and unitholders or shareholders of the AIFs it manages.

In order to satisfy this obligation, intermediaries are selected and evaluated on the basis of so-called “Best Selection” qualitative and quantitative criteria. Certain criteria are more important than others and are therefore taken more into account in the overall assessment. The main selection criteria are:

• intermediaries’ specialisation in small caps and their ability to offer securities suited to the investment management orientation
• knowledge of the business sectors targeted by the Management Company
• the ability to make private investments in high quality companies
• the overall price, i.e. the price of securities and the cost (fees and charges)
• the quality of order execution
• responsiveness and availability of sales teams.

An agreement with the market intermediary is drawn up once they have been selected. After signing the agreement, the list of authorised intermediaries is updated.

The intermediary is subject to a best execution obligation towards the Management Company, which passes orders on to it. In order to ensure that this obligation is upheld, Turenne Capital Partenaires assesses the services provided by the market intermediary once a year.

For more information, please contact the Management Company.