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:

• the size of the investment: ownership should represent more than 2% of a company,
• and the weight of the investment in a UCI portfolio: the investment should weight more than 5% of the UCI NAV,
• and the cost of the exercise of the vote.

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

• the establishment of a basis for effective corporate governance,
• shareholders’ rights and the main functions of holders of capital,
• fair treatment of shareholders,
• the role of different stakeholders in corporate governance,
• transparency and distribution of information,
• the responsibility of the Board of Directors,
• the adherence and promotion of ESG policies.

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:

• the Charter of Commitments for Investors in Growth, drawn up by the Association Française des Investisseurs pour la Croissance (France Invest);
• the UN Principles for Responsible Investment (UN PRI);
• the France Invest Gender Equality Charter.

 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: 

• when an environmental risk is identified during the course of an investment due diligence, to request an audit in order to assess the impact of the investment in question and to encourage the target to prevent any potential damage that has been identified as regards the environment;
• to promote best practices in terms of environmental protection – energy and water use reduction, and the reduction of waste in relation to its investments. In addition, the firm also implements waste recycling and energy reduction policies.

Social commitments

• Due to its convictions, Quadrille Capital does not invest in pornography, alcohol, tobacco, gambling, arms and, in general, any business activities that infringe the integrity of persons or that contravene international standards and conventions (e.g., that violate human rights, child labor). In accordance with the Ottawa and Oslo Conventions that have been signed by France, Quadrille Capital ensures, prior to any investment it makes, that the potential investment does not give rise to the production or the sale of anti-personnel mines, cluster munitions, or associated components or equipment;
• Before making each investment, the firm reviews its strategies for distributing the added value created and for aligning interests with  respect to the investments in question – this  entails drawing up capitalization tables that feature all the employees of the companies, drafting a policy for distributing stock options that are not earmarked for managers, and the allocation of carried interest arising from funds;
• Quadrille Capital implements responsible human resources management and places great emphasis on quality of life at work through various initiatives that further team cohesion (e.g., offsites, team events, access to management coaches, etc.). This means that employees can take part in training courses of their choosing and get the benefit of biannual appraisal interviews and of company profit- sharing (through year-end bonuses and carried interest);
• Quadrille Capital promotes diversity but does not have a specific policy to promote gender equality. But it nevertheless happens that women account for 41% of the firm's total workforce, and one-third of its investment team staff.

 Governance commitments

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

• Before each investment is made, detailed analysis of the governance of target companies is carried out. Quadrille Capital has declined investments in the past based solely on this criterion;
• The firm makes sure that it complies with the laws, conventions and regulations that apply to it;
• Quadrille Capital ensures that it complies with anti-money laundering, anti-corruption and anti- terrorist financing regulations as regards matters that are within its control;
• It has a voting policy and a general policy for preventing and dealing with conflicts of interest.
• Quadrille Capital always acts in the interests of investors;
• The firm provides reports to investors on our operations and to further the goal of transparency, in particular with regard to the economic, environmental, social and governance impacts of its investments. 

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.