Conflict of interest policy
InfraVia Capital Partners has adopted a conflict of interest management policy in accordance with the applicable legal framework. In this respect, InfraVia Capital Partners maintains and operates organisational measures with a view to take reasonable steps designed to identify, prevent, manage and / or monitor conflict of interest aiming to ensure the primacy of the interests of the investment funds it manages (the “Funds“) and their underlying investors.
Identifying conflict of interest
A confict of interest situation may arise when the interests of several persons are, directly or indirectly, in competition. InfraVia Capital Partners takes all reasonable steps to identify conflict of interest that may arise, as the case may be, in the course of managing the Funds between:
- InfraVia Capital Partners, including its directors, officers, employees or any person directly or indirectly linked to InfraVia Capital Partners by control, and a Fund managed by InfraVia Capital Partners or its underlying investors;
- a Fund or its underlying investors, and another Fund or its underlying investors; or
- a Fund or its underlying investors, and another client of InfraVia Capital Partners.
InfraVia Capital Partners’ compliance and internal controller (Responsable de la Conformité et du Contrôle Interne) is in charge of assessing situation where a conflict of interest may arise. In particular, InfraVia Capital Partners has processes in place aiming at detecting and monitoring situations where InfraVia Capital Partners or its related persons is likely to receive some advantage at the expense of a Fund, its investors or clients, or is in a situation where interests of different Funds, investors or clients might be in competition.
In this context, InfraVia Capital Partners has established organizational and administrative arrangements aimed to limit the risk of conflict of interest in the normal course of business, including the following measures :
- Investment allocation: rules of allocation are implemented to allocate, as the case may be, the investment opportunities among the Funds;
- Risk mapping: a risk mapping identifying potential conflict of interests has been drawn up and is periodically updated;
- Employees training and awareness: the relevant employees are periodically trained on InfraVia Capital Partners ‘ policies, the regulatory and legal requirements for preventing and identifying conflict of interest;
- Gift & benefits: the receipt of gifts or similar benefits from business relationship is limited and monitored; and
- Personal dealing: InfraVia Capital Partners’ employees are subject to disclosure obligations and restrictions in relation to their personal transaction in the financial markets.
Managing conflict of interest
For each case identified, the conflict of interest procedure provides a course of action and measures to be taken in order to manage a conflict of interest when it arises.
Where InfraVia Capital Partners organisational or administrative arrangements are considered by InfraVia Capital Partners not sufficient to ensure with reasonable confidence that the risks of damage to the interests of a Fund or its underlying investors resulting from a conflict of interest are prevented, InfraVia Capital Partners will inform the concerned investors of the general nature and/or source of the conflict of interest.
These situations, if they occur, are recorded in a conflict of interest register maintained by InfraVia Capital Partners.
Client complaint management policy
InfraVia Capital Partners drawn up and operates a specific procedure in order to manage client complaints, in accordance with the applicable legal framework.
Definition of ‘complaint’
A complaint is defined as a claim caused by the client’s dissatisfaction with the investment service provider. A request for information, advice, clarification or service is therefore not considered to be a complaint.
How to send your complaint?
You are able to send a complaint relative to investment services provided by InfraVia Capital Partners or relative to a subscription into a fund managed by InfraVia Capital Partners. You can contact your usual representative or send a written complaint to the the Compliance Officer at InfraVia Capital Partners, 42 rue de Washington, 75008 Paris, France, or at the following email address: firstname.lastname@example.org.
Processing your request
Once your complaint has been received, you will be issued:
- a confirmation of receipt within 10 working days, unless the answer is provided to you in the meantime;
- an answer within 2 months of receipt of your complaint (unless duly justified circumstances require a longer period).
Processing of your request will be free of charge. We will respond to any request for information on the processing of your claim.
Contact the “Autorité des Marchés Financiers (AMF)” ombudsman
In the event of the answer provided by InfraVia Capital Partners not meeting your expectations, you are also able to contact the AMF Ombudsman using the following link: www.amf-france.org, or write to the following address: Médiateur de l’AMF, Autorité des Marchés Financiers, 17 place de la Bourse, 75 082 Cedex 02, France.
Additional information on the Mediation Charter are available on the AMF website.