ESG & Sustainability-related Disclosures
In accordance with the Disclosure Regulation (Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector), sustainability risks are integrated into Galion.exe's investment policy.
The Management Company’s investment team takes ESG criteria into account in investment
decisions, however not in a preponderant manner as it falls under the category of financial products as outlined in Article 6 of the SFDR Regulation.
Although ESG and sustainability risk is important to Galion.exe and we take it seriously, we do not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the Disclosure Regulation.
The Management Company has however implemented a series of exclusion-based policies to manage the most severe sustainability risks. Such exclusion policies result in the Management Company limiting investment into prohibited sectors, companies and underlying assets.
This is our current position, which we will keep under review.
Download the Article 29 LEC Report.
Claims Management Policy
Galion.exe has implemented and maintains an operational procedure in order to quickly and efficiently process complaints made by its clients. Any information on this procedure for handling complaints may be obtained by sending a written request to the company.
Any complaint may be referred to Galion.exe, 81 rue Reaumur, 75002 Paris, France. The management company will acknowledge receipt of the complaint within a maximum of ten working days from the date it was sent, unless a response has been issued to the client in the intervening period. Except in duly justified exceptional circumstances, a response will be issued to the client within two months of receipt of the complaint.
In the event of an ongoing dispute, the client may contact a mediator, such as the AMF Ombudsman, at the following address: Autorité des marchés financiers, Madame Marielle Cohen-Branche, Médiateur de l’AMF, 17 place de la Bourse, 75082 Paris Cedex 02. The AMF mediation request form at the Mediation Charteur is available online at amf-france.org.
Shareholder Commitment Policy
Please read our Shareholder commitment Policy.
Conflicts of Interests Policy
Galion.exe has implemented a conflicts of interest management policy, available on its website, aimed at preventing, identifying, and resolving such situations. Members of the Galion.exe team are required to adhere to and comply with the France Invest Code of Ethics, which includes specific provisions regarding conflicts of interest. This policy is also accessible at the management company's headquarters and can be provided to any shareholder upon request. Additionally, the fund managed by Galion.exe is equipped with an advisory committee (Comité Consultatif), the operation and details of which are outlined in the fund's by-laws.
As an asset management company operating in the private equity sector, Galion.exe is committed to upholding the principles of professional ethics applicable to it. This involves constant vigilance to identify, prevent, and effectively resolve any conflict of interest situation, to the extent possible.
In the event of a potential or confirmed conflict of interest during investments or exercise of voting rights, a declaration must be made to the Compliance and Risk Officer (RCCI - Responsable de la Conformité et du Contrôle Interne). The RCCI will analyze the situation and take appropriate measures to resolve the conflict, in collaboration with the management of the management company. Potential conflict of interest situations are documented in a dedicated mapping, updated at least once a year. No suspicious declarations were made in 2022.
Confirmed conflicts of interest are mentioned in the annual report of the FPCI. Galion.exe ensures regular reminders of confidentiality rules to its investors.
The Galion.exe Remuneration Policy can be provided upon request from email@example.com, as deemed appropriate.
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