Regulatory Information

Claims

Quadrille Capital has implemented and maintains a procedure to quickly and efficiently handle complaints made by its investors.

 A complaint is defined as “a statement of dissatisfaction by a client toward the professional. A request for information, opinion, clarification, service or provision is not a complaint” (AMF instruction n°2012-07 of 13 July 2012 as modified).

 Any complaint may be sent to the Compliance Officer (RCCI) of the company at its registered office (16 Place de la Madeleine, 75008 Paris, France. The management company will acknowledge receipt of the complaint within ten working days of the date on which it was received and a response will be issued to the client within two months of receipt of the complaint.

 In France: In the event of an ongoing dispute, the client may contact a mediator, such as the AMF Ombudsman. The address of the AMF Ombudsman is: Autorité des Marchés Financiers, The AMF Ombudsman, 17 place de la Bourse, 75082 Paris CEDEX 02, France. The AMF mediation request form and the Mediation Charter are available online at www.amf-france.org

Conflict of interest policy

Quadrille Capital maintains and operates an effective policy to identify, prevent, manage and monitor conflicts of interest situations that may adversely affect its customers. Quadrille Capital also holds a register that lists situations in which a conflict of interest has arisen, whenever applicable. A copy of the policy is available free of charge upon request. 

Best Execution Policy and Best Selection Policy

An investment service provider must take all reasonable measures to obtain for its client the best execution of its order. Quadrille Capital does not carry out direct trading neither execution of orders with counterparties. In this context, Quadrille Capital only implemented a Best Selection Policy and selected intermediaries whose execution policy allows the best possible result when executing orders.

The criteria applied to select intermediaries that guarantee the best execution of stock market orders are both quantitative and qualitative. They depend on the markets for which the intermediaries provide services, in terms of geographical area (global, European or local intermediaries), type (large/small cap) and financial instruments traded (equity, derivatives). The analysis criteria cover the availability and proactiveness of the intermediary representatives, their financial situation, their speed, the quality and cost of the processing and execution of orders.

The intermediaries’ ratings are updated every year. Based on this, the list of selected intermediaries is also reviewed annually.

A copy of the policy is available free of charge upon request. 

Voting rights

Quadrille Capital exercises the voting rights attached to the securities held by UCIs under management when there is a risk of modification of the companies' strategy compared to its investment thesis (change of majority shareholding, merger - acquisition, restructuring, etc.). The decision to vote take into account:

Quadrille Capital’s voting policy aims to preserve the exclusive interest of the UCIs investors. Votes will favor: 

ESG Charter

 The purpose of this Charter is to set out the ways in which environmental, social, and governance (ESG) criteria are incorporated into the investment and risk management policy of Quadrille Capital and the funds under management.

 Since it was set up in 2007, Quadrille Capital has taken non-financial criteria into account in its investment processes, from the investment opportunity analysis stage to exit. The firm is convinced that extra- financial data enables value creation and promotes an alignment of interests between all stakeholders – management and employees, investors, and society in the broad sense.

 Quadrille Capital is a signatory to:

 This ESG charter thus constitutes a reference framework for the development of the firm's operations, and an in-house guideline.

 Environmental commitments

 Aware of the environmental footprint generated by its operations and through its investments, Quadrille Capital undertakes: 

Social commitments

 Governance commitments

 Good corporate governance lays the foundations for value creation and for risk reduction, and thus ensures the long-term durability of companies. 

SFDR 

Quadrille Capital makes the following disclosures in accordance with the Sustainable Risk Finance Disclosure Regulation (2019/2088) (the “SFDR”). 

Quadrille Capital invests in high-growth technology and healthcare companies, which, by nature, contribute to achieve a better and more sustainable future for all (good health and well-being, reducing inequality, decent work and economic growth, innovation, responsible consumption and production…).

 ESG criteria are a key component of Quadrille Capital’s investment policy since its creation in 2007. Quadrille Capital has already its own proven tailor-made procedures and metrics to assess the sustainability adverse impacts. Therefore, Quadrille Capital does not intend to consider the prescribed sustainability adverse impacts of the SFDR, but will follow closely the future developments related to the regulation. 

Remuneration policy and sustainability 

Quadrille Capital’s remuneration policy complies with the AIFM and UCITS directives requirements.

The remuneration policy is in line with the interests of the funds under management and their investors.

Quadrille Capital’s staff receives a combination of fixed remuneration (salary and benefits) and variable remuneration (bonus). Variable remuneration is discretionary, not guaranteed and take into account Quadrille Capital’s performance and individual objectives such as the respect of the ESG charter.

 Non-discrimination for promotions and compensation is a cornerstone at Quadrille Capital.

 A copy of the policy is available free of charge upon request.