REGULATORY INFORMATION
I. CONFLICT OF INTEREST POLICY
The Funds RGREEN INVEST manages are open only to professional investors. The specific risks of investing in Funds are linked to: capital loss, debt securities, changing interest rates, credit risk, counterparty risk, Project risk, etc. Please contact RGREEN INVEST for a complete risk presentation. RGREEN INVEST has developed a formalized, operational policy for managing conflicts of interest, which seeks to prevent, detect and provide a framework, as applicable, for conflicts of interest which may arise in the course of its business between its own and its clients’ interests or between several clients’ interests.
Situations which could lead to conflicts of interest include, for example:
– Exercising simultaneously several functions with divergent interests,
– Concomitantly working with the same partners on different projects,
– Giving or accepting benefits or gifts,
– Variable remuneration,
– Situations concerning the existence of special connections,
– Situations concerning access to privileged information,
– Situations concerning financial dependence in the context of a contractual relationship, etc.
As part of the implementation of the regulatory provisions of the French financial markets authority (Autorité des Marchés Financiers, or AMF), RGREEN INVEST has identified situations in which conflicts of interest could arise by taking into account the size of the management company, how it is organized and the nature and complexity of its business. This conflict-of-interest risk mapping is updated periodically (at least yearly) to incorporate any developments and changes in RGREEN INVEST’s business. Conflict-of-interest management is based on the fundamental principle that client interests are paramount. Practical implementation of these principles is the responsibility of every employee, the executives and the management company under the supervision of the Compliance and Internal Control Officer (Responsable de la conformité et du contrôle interne, or RCCI).
II. INFORMATION ABOUT RISKS
The Funds RGREEN INVEST manages are open only to professional investors. The specific risks of investing in Funds are linked to: capital loss, debt securities, changing interest rates, credit risk, counterparty risk, Project risk, etc. Please contact RGREEN INVEST for a complete risk presentation.
III. OVERVIEW: POLICY FOR SELECTING FINANCIAL INTERMEDIARIES
RGREEN INVEST shall ensure that it acts in its clients’ best interests for the execution of orders resulting from investment decisions pertaining to the portfolios. For example, if RGREEN INVEST conducts transactions on markets (in future, keeping in mind that this is not standard practice at this stage), the company will select intermediaries whose execution policy will enable ensuring the best possible result when orders transmitted on behalf of its clients are executed. In order to maintain the high quality of the services offered, all intermediaries used will be subject to semi-annual appraisals.
IV. OVERVIEW: VOTING RIGHTS POLICY
RGREEN INVEST exercises the voting rights attached to the securities held by the funds it manages. A voting rights policy has been set out and its supervision provided for. The management team is in charge of gathering the information (date, organization, wording of the resolutions) for each General Meeting of the investments it monitors. The General Meeting documents are sent to the Investment Director in charge of the company in question. The Investment Director examines and analyses the resolutions submitted to the Meeting in accordance with the provisions of this Voting Rights Policy and in the shareholders’ interest. The Investment Director shall choose how to vote (for, against or to abstain). The Investment Director shall at all times be prepared to report on his or her exercise of voting rights.
V. HOW WE HANDLE CLAIMS
For RGREEN INVEST the primacy of its clients’ interests is fundamental. Hence, the management company has established a procedure for managing client claims aimed at handling all client claims effectively, transparently and with the same care. For all claims, you can reach us: By post, at the following address: RGREEN INVEST to Stephanie BEGUE, 47 Rue de Chaillot, 75116 Paris, France By email: sbegue[at]rgreeninvest.com
RGREEN INVEST will acknowledge receipt of your request within 10 business days of receipt of your claim and undertakes to respond to your request within one month of receipt of your claim. If special circumstances arise and RGREEN INVEST were unable to comply with those periods, it will inform you of the reason for that delay.If you are dissatisfied with the response given to your complaint by RGREEN INVEST, you can appeal to the Mediator of the Financial Markets Authority.
Contact the Mediator by mail:
AMF
Ms. Marielle COHEN-BRANCHE Mediator of the AMF,
17, place de la bourse 75082 PARIS CEDEX 02
An electronic referral form is also available on the AMF website https://www.amf-france.org/en/amf-ombudsman/mediation-file/request-mediation.