Seven2 sas
1 rue Paul Cézanne
75008 Paris
Tél : +33 1 53 65 01 00
www.seven2.eu
partners@seven2.eu
504 829 417 RCS Paris
Share capital: €1,074,155
Intra-community VAT number : FR06504829417
AMF approval No. GP08000057
Autorité des marchés financiers (AMF)
17 place de la bourse 75002 Paris
Publishing Director: Edgard Misrahi, Chairman and CEO
Managing Editor: Lauren Bardet, Communications Director
Compliance with regulations and ethical standards
The purpose of this website is to present the business of Seven2. This presentation is not for sales or marketing purpose. The information contained in the website is not a contract and is not a product offering, nor a recommendation and/or solicitation of an offer to buy, nor a public offering.
The information provided is for reference purposes only and is valid on the date of their publication. It is moreover partial and incomplete and has no contractual value. It is not a recommendation for investment or advice founded on circumstances specific to the visitors of the website or that can meet to their special requirements.
Policy on the exercise of voting rights
In compliance with Articles 319-21 of the General Regulations of the Financial Authority, Seven2 has a policy governing the exercise of voting rights that aims to define the conditions in which it exercises the voting rights attached to the securities held by the Funds that it manages. The Management Company reports on the voting policy governing the voting rights attached to the unlisted securities in the Annual Report to investors. The Management Company reports on the voting rights attached to the listed securities in the Board of Directors’ Report to the shareholders’ Annual General Meeting. This report is provided free of charge to Funds’ shareholders requesting it and may be viewed at the headquarters of the Management Company. The objective of the exercise of voting rights is to defend the rights of investors in the managed Funds. The policy governing the exercise of voting rights may be viewed at the head office of the Management Company.
Handling of complaints
The asset management company Seven2 sas has created and maintains an efficient and transparent procedure for handling complaints from customers, reasonably and rapidly.
A complaint is a statement of discontent addressed by the customer to the professional. A request for information, opinion, clarification or service is not considered a complaint.
Customers may address complaints free of charge to Seven2. Seven2 does not invoice any expenses for the handling of complaints.
Complaints may be addressed to the customer’s usual contact person at Seven2 sas by the following means:
- by post at the following address: 1 rue Paul Cézanne, 75008 Paris (France);
- by telephone at the following number: +33 (0)1 53 65 01 40;
- by email at the following address: raphael.delmarre@seven2.eu.
The Compliance and Internal Control Officer (CICO) is the person in charge of handling complaints. The CICO has the required knowledge and experience with the products, services, contracts, tools and procedures to ensure that customer complaints are handled appropriately. The CICO may seek any necessary expertise to assist him or her in handling complaints. Seven2 sas ensures that customer complaints are kept strictly confidential.
Seven2 SAS will acknowledge receipt of the complaint within a maximum of 10 working days from the date of dispatch, unless a response is made to the customer before this deadline.
A response to the customer’s complaint is prepared within two months of receipt, unless there are special circumstances, which must be explained. If a response cannot be provided within this timeframe, the customer is contacted and informed of the reason for the delay, and a new time period is indicated.
Customers may address complaints in the official language or one of the official languages of the member State in which the fund is marketed or the investment service provided.
The customer may contact the Ombudsman of the Autorité des Marchés Financiers (AMF) in the event the response to a complaint is deemed unsatisfactory, by filling in one of the forms on the following web page: https://www.amf-france.org/fr/le-mediateur-de-lamf/votre-dossier-de-mediation/vous-voulez-deposer-une-demande-de-mediation or by contacting the Ombudsman by post at the following address: Autorité des Marchés Financiers, La Médiation, 17, place de la Bourse 75082 Paris Cedex 02 (France).
Conflicts of interest
In accordance with article 318-13 of the RGAMF, Seven2 SAS takes all reasonable measures to identify conflicts of interest that may arise in the management of FIAs. The portfolio management company maintains and applies effective organizational and administrative provisions in order to take all reasonable measures to identify, prevent, manage and monitor conflicts of interest so that they do not harm the interests of the AIF and their unit holders or shareholders. Seven2 SAS has integrated the prevention of conflicts of interest into every stage of decision-making. Any potential conflict of interest must be reported to the Head of Compliance and Internal Control (RCCI), who will take the necessary steps to (i) analyze the situation and (ii) remedy it.
In the event that Seven2 SAS finds that the measures deployed are insufficient to guarantee, with reasonable certainty, that the risk of harming the interests of clients can be avoided, the company will inform the clients concerned in writing of the nature of the conflict or the source so that they can make their decision in full knowledge of the facts.
Information Technology and Individual Liberty
In accordance with the French Law on information technology and individual rights, we notified the CNIL (Commission Nationale Informatique et Libertés – the French Commission on Information Technology and Individual Rights) about our processing of personal data communicated via our website.
In accordance with the French Law on information technology and individual rights of 6 January 1978, you have the right to access, revise and delete information upon application to Seven2, 1 rue Paul Cézanne, 75008 Paris, France – partners@seven2.eu.
Information contained in this website
Seven2 is pleased to welcome you to its websites www.seven2.eu and www.apax.fr. These websites are for information and guidance only and areintended to provide information about the Company, its business and results.
The specific use of the information contained in these websites is the sole responsibility of the user.
Seven2 regularly updates these websites, but shall in no way be liable for any inaccuracies, errors or omissions.
Seven2 shall not be held liable for any damages whatsoever resulting from information contained in this website.
Seven2 reserves the right to modify this information at any time, without notice. Similarly, Seven2 reserves the right to suspend, discontinue or cancel access to all or part of these websites in the event of technical problems or force majeure.
The name “Seven2” is a registered trademark. Any fraudulent use constitutes infringement and is punishable by criminal penalties as specified in Articles L.716–1 et seq. of the French Intellectual Property Code.
All elements of the Seven2’s websites are protected by intellectual property rights. The reproduction and use of any documents published on this website are exclusively authorised for strictly personal and private purposes on condition that the source is mentioned. Any reproduction, use or distribution of copies made for other purposes is strictly prohibited and is subject to criminal penalties.
Any linking to or framing of these websites is also strictly prohibited and accordingly, no element on any page of Seven2 ’s and Apax by Seven2 websites may be partially or totally distributed, transferred or inserted in another Internet website or used to create derivative products, unless specifically authorised by Seven2’s management.
Remuneration Policies
Seven 2 has established a remuneration policy in accordance with the regulations in force.