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 https://geneocapitalentrepreneur.com 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 - contact@geneocapitalentrepreneur.com
The person responsible for publication is an individual or a legal entity.
Webmaster: Claire Alexandre, contact@geneocapitalentrepreneur.com
Host: OVH - 2 Rue Kellermann, 59100 Roubaix - 09 72 10 10 07
2 General conditions of use of the site and the services offered
The use of the https://geneocapitalentrepreneur.com 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 https://geneocapitalentrepreneur.com 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 https://geneocapitalentrepreneur.com 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 https://geneocapitalentrepreneur.com 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 https://geneocapitalentrepreneur.com 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 https://geneocapitalentrepreneur.com is given for information purposes only, and is subject to change. In addition, the information on https://geneocapitalentrepreneur.com 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 https://geneocapitalentrepreneur.com 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 https://geneocapitalentrepreneur.com. 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 Main laws concerned
Regulation (EU) 2016/679 of the European Parliament and of the Council and of April 27, 2016 known as the RGPD Regulation.
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.
8 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).
9 Applicable law and jurisdiction
Any dispute related to the use of the https://geneocapitalentrepreneur.com 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 operational process for handling conflicts of interest is described in the Conflicts of Interest Procedure.
A non-exhaustive summary version of the Conflicts of Interest Management Policy is available here. The full version of this policy is available 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
To download the report on the implementation of the 2023 shareholder engagement policy, 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.
The person in charge of handling complaints may be contacted (i) by post with acknowledgement of receipt to GENEO Capital Entrepreneur, Service Réclamations, 7 rue Auber, 75009 Paris, (ii) by e-mail to the following address: solutions@geneocapitalentrepreneur.com or (iii) by telephone on 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: //www.amf-france.org/fr/le-mediateur
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: //finance.ec.europa.eu/consumer-finance-and-payments/retail-financial-services/financial-dispute-resolution-network-fin-net/fin-net-network/members-fin-net-country/fin-net-members-france_fr
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
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