Legal information

1 Presentation of the site

Pursuant to Article 6 of Law No. 2004-575 of 21 June 2004 on trust in the digital economy, users of the website are informed of the identity of the various parties involved in its implementation and monitoring:

Owner: Owner: GENEO CAPITAL ENTREPRENEUR - SIRET: 84791474400028 - 7 rue Auber- 75009 Paris, registered with the R.C.S de Paris under the following registration number: 847 914 744
Management company: GENEO CAPITAL ENTREPRENEUR, approved by the AMF (Autorité des Marchés Financiers), whose address is 7, rue Auber, 75009 Paris under the following approval number: GP - 19000004
Creator: Creator (site editing, graphic design, development) : So Bang, 15 Rue Monsigny, 75002 Paris, 01 42 65 37 40
Publication manager: GENEO Capital Entrepreneur -
The person responsible for publication is an individual or a legal entity.
Webmaster: Claire Alexandre,
Host: OVH - 2 Rue Kellermann, 59100 Roubaix, France

2 General conditions of use of the site and the services offered

The use of the website implies full and complete acceptance of the general terms and conditions of use described below. These terms of use may be modified or supplemented at any time, so users of the website are invited to consult them regularly.

This site is normally accessible to users at any time. However, GENEO Capital Entrepreneur may decide to interrupt the service for technical maintenance purposes, and GENEO Capital Entrepreneur will then endeavour to inform users in advance of the dates and times of the service.

The website is regularly updated by the communication team. In the same way, the legal notices may be modified at any time: they are nevertheless binding on the user who is invited to refer to them as often as possible in order to take note of them.

3 Description of the services provided

The purpose of the website is to provide information about all the activities of the Management Company.

GENEO Capital Entrepreneur strives to provide as accurate information as possible on the website. However, it cannot be held responsible for omissions, inaccuracies and deficiencies in the update, whether caused by itself or by third party partners who provide it with this information.

All the information indicated on the website is given for information purposes only, and is subject to change. In addition, the information on is not exhaustive. They are given subject to modifications that have been made since they were put online.

4 Contractual limitations on technical data

The site uses JavaScript technology.

The website cannot be held liable for any material damage related to the use of the website. In addition, the user of the site undertakes to access the site using recent, virus-free equipment and with a state-of-the-art browser.

5 Intellectual property and counterfeiting

GENEO Capital Entrepreneur is the owner of the intellectual property rights or holds the user rights to all elements accessible on the site, including texts, images, graphics, logos, icons, sounds, software.

Any reproduction, representation, modification, publication, adaptation of all or part of the elements of the site, whatever the means or process used, is prohibited, except with the prior written authorisation of : GENEO Capital Entrepreneur.

Any unauthorized use of the site or any of the elements it contains will be considered as constituting an infringement and prosecuted in accordance with the provisions of Articles L. 335-2 et seq. of the Intellectual Property Code.

6 Limitations of liability

GENEO Capital Entrepreneur shall not be held liable for any direct or indirect damage caused to the user's equipment when accessing the website, resulting either from the use of equipment that does not meet the specifications indicated in point 4, or from the appearance of a bug or incompatibility.

GENEO Capital Entrepreneur cannot also be held liable for indirect damages (such as loss of market or loss of opportunity) resulting from the use of the website.

Interactive spaces (possibility to ask questions in the contact area) are available to users. GENEO Capital Entrepreneur reserves the right to remove, without prior notice, any content deposited in this space that contravenes the legislation applicable in France, in particular the provisions relating to data protection. If necessary, GENEO Capital Entrepreneur also reserves the right to hold the user liable under civil and/or criminal law, in particular in the event of a racist, abusive, defamatory or pornographic message, regardless of the medium used (text, photography, etc.).

7 Management of personal data

In France, personal data are protected by Act No. 78-87 of 6 January 1978, Act No. 2004-801 of 6 August 2004, Article L. 226-13 of the Criminal Code and the European Directive of 24 October 1995.

When using the site, the following may be collected: the URL of the links through which the user accessed the site, the user's access provider, the user's Internet Protocol (IP) address.

In any case, GENEO Capital Entrepreneur only collects personal information relating to the user for the purpose of certain services offered by the website The user provides this information in full knowledge of the facts, particularly when he/she enters it himself/herself. It is then specified to the user of the website whether or not he or she is required to provide this information.

In accordance with the provisions of articles 38 and following of the law 78-17 of January 6, 1978 relating to data processing, files and freedoms, any user has a right of access, rectification and opposition to personal data concerning him, by making his written and signed request, accompanied by a copy of the identity document with signature of the holder of the document, specifying the address to which the answer must be sent.

No personal information of the user of the site is published without the user's knowledge, exchanged, transferred, assigned or sold on any medium whatsoever to third parties. Only the hypothesis of the purchase of GENEO Capital Entrepreneur and its rights would allow the transmission of this information to the potential purchaser, who would in turn be bound by the same obligation to keep and modify the data with regard to the user of the website

Databases are protected by the provisions of the law of 1 July 1998 transposing Directive 96/9 of 11 March 1996 on the legal protection of databases.

8 Hyperlinks and cookies

The website contains a number of hypertext links to other websites, set up with the authorisation of GENEO Capital Entrepreneur. However, GENEO Capital Entrepreneur has no possibility of verifying the content of the sites thus visited, and will therefore not assume any responsibility for this fact.

Browsing the website may cause cookies to be installed on the user's computer. A cookie is a small file, which does not allow the identification of the user, but which records information relating to the navigation of a computer on a site. The data thus obtained are intended to facilitate subsequent navigation on the site, and are also intended to allow various measures of attendance.

Refusal to install a cookie may result in the inability to access certain services. However, the user can configure his computer as follows to refuse the installation of cookies:

In Internet Explorer: tool tab (pictogram in the shape of a cog in the top right corner) / internet options. Click on Privacy and choose Block all cookies. Confirm with Ok.

Under Firefox: at the top of the browser window, click on the Firefox button, then go to the Options tab. Click on the Privacy tab.
Set the Retention Rules to: Use the custom settings for the history. Finally, uncheck it to disable cookies.

Under Safari: Click on the menu pictogram at the top right of the browser (symbolized by a cog). Select Settings. Click Show Advanced Settings. In the "Privacy" section, click on Content Settings. In the "Cookies" section, you can block cookies.

Under Chrome: Click on the menu pictogram at the top right of the browser (symbolized by three horizontal lines). Select Settings. Click Show Advanced Settings. In the "Privacy" section, click on preferences. In the "Privacy" tab, you can block cookies.

9 Main laws involved

Law n° 78-17 of 6 January 1978, notably amended by law n° 2004-801 of 6 August 2004 relating to data processing, files and freedoms.

Law n° 2004-575 of 21 June 2004 on confidence in the digital economy.

10 Glossary

User: Internet user connecting, using the above-mentioned site.

Personal information: "information that allows, in any form whatsoever, directly or indirectly, the identification of the natural persons to whom it applies" (article 4 of law n° 78-17 of 6 January 1978).

11 Applicable law and jurisdiction

Any dispute related to the use of the website is subject to French law. The competent courts of Paris shall have exclusive jurisdiction.

Regulatory information

1 Important

GENEO Capital Entrepreneur is subject to the 2011/61/EU Directive on Alternative Investment Fund Managers (AIFM Directive). This, transposed into French law by Order 2013-676 published in the Official Journal on 27 July 2013, aims to create a harmonised framework for managers of alternative funds known as "AIF" in Europe while strengthening the protection of investors and savers. This Directive aims to increase the transparency of alternative investment fund (AIFM) managers subject to the AIFM Directive vis-à-vis their supervisory authorities, investors and other key players in order to strengthen investor confidence and to regulate the main sources of risk associated with alternative management.

The information contained on the GENEO Capital Entrepreneur website does not constitute an offer of products or services or a solicitation to buy or sell securities or other investment management products. It is presented for information purposes only and is not contractually binding.

GENEO Capital Entrepreneur manages FIAs reserved for professional or "informed" clients. Only this category of clients will have access to subscribe to our AIFs,

Investors are reminded that subscribing to units or shares of AIFs may involve risks, including the risk of capital loss. The value of investments may go down as well as up depending on market trends and the investor may not get back the amount invested, as the value of the units and shares depends on the value of the financial instruments held in the portfolio. The amount that is reasonable to invest in a fund depends on the investor's personal situation. To determine this, the investor must take into account his or her personal assets, current needs and whether he or she wishes to take risks or, on the contrary, to favour a prudent investment. It is also strongly recommended that investors diversify their investments so that they are not exposed solely to the risks of a single AIF. The tax treatment of investing in AIF units or shares depends on the individual situation of each investor and is subject to change.

2 ESG criteria applied in investment selection

GENEO Capital Entrepreneur strives to apply the Principles for Responsible Investment (PRI) recommended by the United Nations in the management of investments held by funds under management. Team members take every opportunity to integrate criteria relating to compliance with Environmental, Social and Governance Quality (ESG) objectives into the selection of investments as well as into the daily monitoring of risks and changes in the businesses of the companies in the portfolio. GENEO Capital Entrepreneur has signed the Charter of Commitment of France Invest, which is based on 4 pillars (economic, social and human, environment and governance), as well as the Code of Ethics, to get involved in the integration of ESG by French private equity players.

3 Managing conflicts of interest

In order to limit and manage conflict of interest situations, GENEO Capital Entrepreneur has formalised a set of rules and policies which are distributed to all employees, who undertake to respect them

These procedures are as follows:

  • The Code of Ethics;
  • A procedure for the personal transactions of employees;
  • A procedure for investing the management company's own funds;
  • An investment policy;
  • A market abuse monitoring policy;
  • A compensation policy for employees;
  • A procedure for identifying and classifying the benefits and remuneration paid and received by the management company.

The business process for dealing with conflicts of interest is described in the Conflict of Interest Procedure
The management company shall make available to investors a summary of the policy for the prevention and management of conflicts of interest on request

4 Shareholder engagement policy

GENEO Capital Entrepreneur has developed a "shareholder engagement policy" covering all of its assets, which translates its commitment into a voting policy at the general meetings of the companies in which it holds a stake.

For more information, click here

Download the report on the implementation of the shareholder engagement policy 2021, click here

5 The treatment of investors' rights

5.1 Handling customer complaints

GENEO Capital Entrepreneur has established and maintains an operational procedure for the prompt and efficient handling of complaints from its clients. This procedure concerns all complaints, regardless of the client, the product or service in question and the nature of the complaint. A complaint is a statement of the customer's dissatisfaction with the trader. A request for information, advice, clarification, service or provision is not a complaint. The person in charge of handling complaints is Claire Alexandre.

You may contact the person in charge of handling complaints (i) by post with acknowledgement of receipt to GENEO Capital Entrepreneur, Service Réclamations, 9 rue Scribe, 75009 Paris, (ii) by e-mail to the following address: or (iii) by telephone on the following number 09 70 77 24 80.

Upon receipt of the claim, GENEO Capital Entrepreneur undertakes to send an acknowledgement of receipt within 10 working days, and a response within a maximum of two months. If a claim cannot be processed within this period (archives to be repatriated, documentary research, technical point), GENEO Capital Entrepreneur sends the client a letter to justify this additional delay.

GENEO Capital Entrepreneur does not itself have an internal mediation service. As a last resort or in the event of dissatisfaction, a complaint may be addressed free of charge to the Ombudsman of the Autorité des Marchés Financiers ("AMF") by mail to:

AMF Ombudsman

Ms Marielle Cohen-Branche

Autorité des marchés financiers,

17, place de la Bourse

75082 Paris Cedex 02.

The mediation request form and the mediation charter are available on the AMF website: https: //

5.2 Handling cross-border complaints

The funds we manage are marketed in several European Union countries; if you are not satisfied with the response to your complaint by GENEO Capital Entrepreneur, you can contact the European Union's network of financial mediators called FIN-NET, which is designed to facilitate the redirection of requests to the mediator with geographical jurisdiction. The AMF Ombudsman can assist you in this respect, if necessary.

To make sure that your dispute falls within the AMF Ombudsman's remit, you can contact the AMF Savings Info Service from Monday to Friday, 9am to 5pm, on +33 (0) 1 53 45 62 00 or by filling in a form at this link

The European Online Dispute Resolution Platform can be accessed via the following link:

FIN-NET website: https: //

6 Risk of low liquidity and investment in unlisted companies

The Company is mainly invested in Non-Listed Assets. These Assets are illiquid or illiquid. As a result, and although the management objective is to organise the realisation of its Assets under the best possible conditions, it cannot be excluded that the Company may experience difficulties in disposing of its assets within the desired timeframe and at the desired price level.

7 Remuneration policy

GENEO Capital Entrepreneur has a formalised remuneration policy which is communicated to all employees in accordance with the requirements of the AIFM Directive.

This policy is aimed at all employees of the company, including those considered as "risk takers". The company has set up a Remuneration Committee which is responsible for the annual review of the remuneration policy. The Remuneration Committee is composed of the Chairman and the CEO. It meets annually, following the annual employee appraisal campaign. The implementation of the remuneration policy is subject, at least once a year, to a central and independent internal evaluation to verify compliance with the remuneration policies and procedures. Also, and in accordance with the Disclosure Regulation, the policy sets out, among other things, rules on the consideration of risks, including sustainability, in the allocation of remuneration. Information on how the policy is adapted to the integration of sustainability risks can be found in the remuneration policy of GENEO Capital Entrepreneur.

Remuneration policy of GENEO Capital Entrepreneur