Client complaints policy
The client complaints policy specifies the terms and conditions of complaints management by EM8 Private Equity, in compliance with the principles enacted in the “Règlement Général de l’AMF” (art. 318-10 RGAMF).
A complaint is a declaration made by the client acknowledging his discontentment towards EM8 Private Equity, or in relation to an investment service provided by EM8 Private Equity. A request of information, opinion, or clarification on EM8 Private Equity’s products or services do not constitute a complaint.
The complaint processing is free. The complaint can be received by mail or email at:
EM8 Private Equity - 4 rue Cambon - 75001 Paris - France
Upon reception of a complaint, EM8 Private Equity will send back a registered letter with acknowledgement of receipt within 10 business days, unless an answer has been provided before that. Unless duly justified specific circumstances arise, EM8 Private Equity will send its answer to the client under a period of maximum 2 months starting from the complaint reception date. The client has the possibility to write his complaint using his Member State’s official language or using the official language of one of the Member States where EM8 Private Equity commercializes its products or investment services. Such client will receive his reply in the same language.
For further information, the client is invited to contact the management company.
If the response provided does not appear satisfying, EM8 Private Equity invites the client to contact the AMF mediator (“le médiateur de l’AMF”) at the following address:
Autorité des Marchés Financiers - Service Médiation - 17 place de la Bourse, 75082 Paris Cedex 02.
For more information on the AMF mediator, please consult: https://www.amf-france.org/fr/le-mediateur/presentation
In accordance with the decree n°2015-1850 dated 29 of December 2015, EM8 Private Equity implements an ESG policy that is part of its investment strategy. EM8 Private Equity has also been a signatory of the UNPRI label since 19 of January 2021.
Notes related to the use of personal data
This website do not use personal data.
EM8 Private Equity general principles regarding conflicts of interests
In order to manage EM8 Private Equity Funds’ stakes in the best interests of its investors, the management company takes all useful measures to identify and settle situations of conflict of interests in a transparent way.
Generally, the fund of funds activity run by an independent management company has a low probability to produce conflicts of interests.
Investment and divestment decisions remain at the hand of the Investment Committee, the management company’s directors will endeavour to:
(a) Prevent any situation of potential conflict of interest from the dealflow selection by implementing an identification process before any investment, divestment or service provider selection;
(b) Take, when necessary, all measures and additional or substitutional procedures to ensure the degree of independence required to complete the management company’s operations.
Finally, the management company’s annual report will disclose, when applicable, all the conflicts of interests that have arisen during the financial year, as well as the procedures and solutions applied for each one of them.
The RCCI (“Responsable du Contrôle et de la Conformité Interne” i.e. the internal head of control and compliance) revises all documents of procedures. He is in charge of writing the prevention of conflicts of interests policy, and will also rely on France Invest recommendations (France Invest is the French professional association dedicated to Private Equity sector).
The information circulated by the RCCI to all members of the management company is subject to control and countersignature of the President of the management company. EM8 Private Equity also takes care of the implementation and update of a register of conflict of interests. The management company assesses and updates its policy of conflicts of interests prevention at least on an annual basis.
Applicable rules that apply to managed funds regarding conflicts of interests
The allocation rules are described in the constitutive documentation of each managed fund, and are brought to the attention of each managed fund subscribers before their subscription.
Generally, the investment allocation process should not be a problem as the management company establishes objective rules regarding the deal flow allocation between managed funds of funds for which the investment period is still open and that are authorized to hold the same investments.
In accordance to these rules, the management company will not have any freedom in the allocation of investment opportunities.
Allocation rules are as follows: (i) the funds of funds with opened investment period will systematically co-invest in investment opportunities selected by the management company - providing that their own allocation rules are met. The investment opportunities will be split between funds of funds according to the planned allocations for each sub sector and in accordance with minimum amounts for each sub sector until each of them is fully allocated; (ii) if the available amount is not sufficient because of minimum amounts per unit, the older fund of funds will receive the investment opportunity allocation as a priority.
In case of conflict of interests arisen between one of the managed fund and one or various other managed funds, or any member of the management company, EM8 Private Equity will be able to consult the Advisory Board of one or several managed funds in order to obtain an opinion on the situation creating such conflict of interests. The management company will follow the recommendation of this or these Advisory Board(s).
Please click on the following link to access EM8 Private Equity’s policy regarding conflicts of interests.
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As soon as the first fund of funds has reached a sufficient size, the level of fixed remuneration allocated to each member of the team will be set in line with market standards.
Remunerations ensure a sufficient living standard and do not encourage the team members to develop a maximization strategy of the variable compensation that would lead to risk taking. The potential wage increases are decided annually in theory, as well as the allocation decision of variable remunerations.
In order to match the fund management with the investors interests, the directors of the management company and some of its members will invest in their personal capacity in each of the managed funds.
Shareholder engagement policy
The funds managed by EM8 Private Equity do not directly invest in private companies and have no connection with such companies.