REGULATORY NOTICES
Claims processing
In the event of a complaint or dispute with Othrys Investment Management, the client is invited to submit a written request to the address:
The customer can also send his complaint by post to:
Othrys Investment Management
34 rue Tronchet
75 009 Paris
Othrys Investment Management undertakes to process the Client's complaint within two months.
The person responsible for handling complaints is the Head of Compliance and Internal Control.
With regard to disputes concerning transactions in financial instruments, in accordance with the provisions of Article L.621-19 of the Monetary and Financial Code and the mediation charter of the Autorité des Marchés Financiers, the Client may enter, free of charge, the mediator of the Autorité des marchés financiers provided that (i) the Client has effectively presented a written request to the services of Othrys Investment Management and is not satisfied with the response of Othrys Investment Management (ii) that no litigation procedure , nor any investigation by the Autorité des marchés financiers, relating to the same facts, is in progress:
Mr. Mediator of the Financial Markets Authority
17 Stock Exchange Square
75082 PARIS CEDEX 02
Policy for managing conflicts of interest
In accordance with Article 313-18 of the General Regulations of the Autorité des Marchés Financiers, Othrys Investment Management takes all reasonable measures enabling it to prevent, identify and manage situations of conflict of interest arising during the management of AIFs ( Alternative Investment Funds) or related services.
The conflict of interest management policy is available on simple request from the Management Company.
General principles
When managing AIFs or performing related services, a conflict of interest situation will generally result in a decision or behavior of the directors, partners or equivalent, or managers of Othrys Investment Management, or its employees, or companies directly or indirectly linked to Othrys Investment Management or any other intermediaries or external service providers to whom Othrys Investment Management has delegated certain functions or client with whom Othrys Investment Management has a professional relationship who may harm the interests of unitholders of shares.
Such a situation may have a structural nature due to the economic, financial, capital or contractual relations that Othrys Investment Management or its employees have with third parties, natural or legal persons, with whom Othrys Investment Management has a usual relationship (related companies, for example ) or occasionally.
In accordance with regulations, Othrys Investment Management has implemented a policy for the prevention and management of conflicts of interest.
Mechanism for preventing conflicts of interest
Othrys Investment Management has drawn up a map which lists the situations likely to give rise to a conflict of interest, as well as the related procedures. The concept of conflict of interest designates a situation in which it is reasonable to believe that a person, potentially or proven, loses the impartiality necessary for the decision-making incumbent on him or else takes advantage of this situation at the expense of others. 'another person. The mechanism for preventing and managing conflicts of interest provides for the identification of these situations.
As such, Othrys Investment Management has set up an organization to:
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Prevent the appearance of conflicts of interest, by raising awareness among all its staff of the rules and codes of good internal and market conduct, and by implementing strict rules and procedures:
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implementation of an internal control system;
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separation of functions that could generate potential conflicts;
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Constantly ensuring that Othrys Investment Management's offer corresponds to the profile and expectations of its clients, and is never in contradiction with their needs. The forced sale of products or services constitutes professional misconduct from this point of view;
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training or raising awareness of all staff on good practices in the profession.
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Identify situations of conflicts of interest that could harm the interests of clients, by establishing a risk map of these conflicts of interest. This mapping specifies the types of activities for which a conflict of interest is likely to occur. The RCCI of Othrys Investment Management is responsible in particular for ensuring that this mapping is updated.
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Managing potential conflict of interest situations:
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declare the gifts and benefits received to the RCCI according to the rules set by Othrys Investment Management;
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declare, as soon as they arise, situations of conflict of interest in which the employees or any person concerned may find themselves, if applicable, to the RCCI, which will take charge, with the persons concerned, of the resolution of this conflict.
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The purpose of this conflict of interest management policy is to indicate the main measures for achieving this conflict of interest management objective.