Legal Disclaimer

COPYRIGHT

The Keensight Capital website is protected under intellectual property rights, as are any data on the website, such as brands, logos, graphs, photographs, etc. The information contained on this website is strictly for the personal use of the website’s visitors and may not be reproduced or communicated to third parties, in whole or in part, for commercial or non-commercial purposes.

Due to the simplified nature of the website’s content, the information communicated by Keensight Capital’s website is incomplete and has no contractual value. Despite our best endeavors, technical faults may occur. These could result, for example, from restricted access or faulty reproduction of information, caused by either the website itself or the actions of third parties: Keensight Capital takes no responsibility for any loss which could result. It undertakes only, upon identification of the fault, to implement procedures to remedy such fault. The user is liable for any reproduction or, in general, any unauthorized use of the website and the information contained therein. Such use may result in legal proceedings, particularly for piracy.

REGULATIONS AND RESPONSIBILITIES

Keensight Capital is responsible for updating the website. Keensight Capital has ensured to the best of its ability that the information published on the website is correct, but it shall not be held liable for any loss or damage incurred, whatever its nature, which may result from the opinions or information published on the website, whether explicit or implicit.

LOCAL RULES AND REGULATIONS

The laws and regulations of the country from which you access this website may contain restrictions on the distribution of the information the website contains. If this is the case, this information may not be distributed or used by any natural person or legal entity. Such natural persons and legal entities shall be obliged to inform themselves of and to observe any such restrictions.

In accordance with the French Data Protection Act of January 6, 1978, as modified by the law of the 6 August 2004, you have a right to inquire about, access and rectify all of your data and to object to their processing on legitimate grounds. You can exercise these rights by sending a letter, together with a copy of an identity document to Keensight Capital by e-mail at privacy@keensightcapital.com or by mail to Keensight Capital : 64 rue de Lisbonne -75008 Paris

© 2019 – Keensight Capital. All rights reserved. The information contained on this website may not be reproduced without the permission of Keensight Capital. This Website is hosted by O2switch a Company simplified by share (société par actions simplifiée) incorporated under the laws of France with its registered office located at 222 Boulevard Gustave Flaubert, 63000 Clermont-Ferrand – France

CLAIM HANDLING POLICY

Keensight Capital has established and offers an effective procedure to ensure fast, efficient and free processing of your claims.

  1. Requests and Information

Any complaint can be sent to the Investor Relations Department by telephone at +33 (0)1 83 79 87 30 or by post at Keensight Capital, 64 rue de Lisbonne, 75008 Paris.

  1. Response protocol

Keensight Capital undertakes to respond to complaints addressed to it within a maximum of fifteen working days from the date of receipt of the request.

The answer will be on the medium corresponding to the support of the request (mail or call).

In the event of rejection or refusal to allow the claim in whole or in part, Keensight Capital shall specify in the response to the client the possible remedies.

  1. Regulatory references
  • Articles 318-10 to 318-10-1 of the AMF General Regulation.
  1. Claims management

Keensight Capital has established a claims organization that:

  • Allows the client to present their claim to their usual contact person, the management team and, if they have not received a satisfactory response from them, to the manager or the Compliance and Internal Control Officer.
  • Meets the processing times that have been communicated to the client, namely
  • Up to 10 working days from receipt of the complaint, to acknowledge receipt of the complaint, unless the response itself is provided to the customer within this period;
  • No more than two months between the date of receipt of the complaint and the date of sending the response to the customer unless duly justified special circumstances arise;
  • Provides procedures for recording claims and monitoring their processing.

CONFLICT OF INTEREST MANAGEMENT POLICY

Keensight Capital has a conflict-of-interest management policy in accordance with current regulations. Keensight Capital shall maintain and apply effective organizational and administrative arrangements, with a view to taking any reasonable measure to identify, prevent, manage and monitor conflicts of interest to prevent them from adversely affecting the interests of Funds and investors.

A conflict of interest is defined as “a prejudicial conflict between the interests of the Management Company and those of the investors in its funds or between the interests of different investors.” Conflicts of interest may arise when providing investment services.

  1. Regulatory references
  • Articles 318-12 to 318-14 of the AMF General Regulation;
  • Articles 30 to 36 of Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012.
  1. Mapping of conflicts of interest

Identifiable conflicts of interest can be of five types:

  • Conflicts of interest involving Keensight Capital (the “Management Company”) and one of its shareholders;
  • Conflicts of interest involving the Management Company and a Related Company (as defined in the regulations for the funds managed by the Company, i.e. the “Funds”);
  • Conflicts of interest involving the Management Company and an Investor client (as defined in the Fund Regulations);
  • Conflicts of interest involving the Management Company and a Partner (as defined in the Fund Regulations);
  • Conflicts of interest involving two Investors.
  1. Prevention of conflicts-of-interest

The prevention of conflicts of interest is based in particular on compliance by the Management Company’s Management Team with the codes of conduct and on compliance with the principles of the codes of ethics of ACEC and the Management Company.

The Compliance and Internal Control Officer ensures the application of these principles and is systematically associated with decisions taken upstream in the case of a sensitive operation (investment, divestment, calls for funds, set-up fees, etc.).

  1. Management of conflicts-of-interest

Managers maintain a record of conflicts of interest (potential/proven) on an ongoing basis. As soon as a conflict of interest, even a potential one, is identified, it is recorded in the conflict-of-interest register (basis of incidents) describing their nature and the measures put in place by DGs to resolve them.

Conflicts of interest are the subject of a specific item in a regular internal committee.

Where the organizational or administrative arrangements made by Keensight Capital to manage conflicts of interest are insufficient to provide reasonable assurance that the risk of undermining the interests of investors will be avoided, the company shall clearly inform the persons concerned of the nature or source of such conflicts of interest.

The Fund’s Investor Advisory Committee is informed as soon as the Management Company identifies a situation of conflict of interest qualified as i) potential but not treated and ii) proven, in accordance with the rules of good conduct specified in the Fund Regulations.

In the event of a proven conflict of interest, the Management Company shall inform the Fund’s Investor Advisory Committee (in accordance with the provisions of the Fund Regulations), the delegated Compliance and Internal Control Officer and the Statutory Auditor of the Company and the Fund(s) of the situation observed and the measures taken.