The www.supernovainvest.com website (the “Website”) is published by Supernova Invest, a simplified joint-stock company with share capital of 300,018 euros, registered with the Paris Trade and Companies Register under number 828 628 586, whose registered office is located at 9 rue Duphot – 75001 Paris, Telephone number: +33 (0)1 86 64 01 85 (“Supernova Invest”).
Supernova Invest is an asset management company authorized by the Autorité des Marchés Financiers (AMF) under no. GP-17000008.
The Director of Publication is: Julien Cristiani
The Website is hosted by:
1&1 Internet SARL
7, place de la Gare
57201 Sarreguemines Cedex
Tel: 0970 808 911
The Website taken as a whole, as well as each of its components, including programs, and content including data, text, fixed and animated images, brands, logos, sounds, graphics, files, databases, domain names, and trade names are the exclusive property of Supernova Invest or third parties that have granted it a license.
Any reproduction and/or representation, in whole or in part, of the Website or any of the components thereof, without the express consent of Supernova Invest, is prohibited and may incur the civil and criminal liability of its author.
The user acknowledges having read these notices and undertakes to comply with them.
The information provided by Supernova Invest on the Website is indicative and may be subject to change without notice. Supernova Invest cannot guarantee the accuracy, completeness, or timeliness of the information disseminated on the Website. Furthermore, this information does not constitute an offer of services or advice, and Supernova Invest shall not be held liable in this regard for any reason whatsoever.
The user acknowledges that he/she uses the information and tools available on the Website under his/her exclusive responsibility, has the necessary skills and means to access and use the Website, and has verified that the computer configuration used does not contain any viruses and is in perfect working condition.
Supernova Invest makes every effort to ensure that users have access to the Site at all times, with the exception of maintenance intervals. Supernova Invest cannot guarantee that the operation of the Website will be uninterrupted or free of errors, viruses, or other anomalies. Supernova Invest is not responsible for delays, difficulty of use, or incompatibility between the Website and files, your browser, or any other site access program.
Any hypertext link to the Website must be subject to prior written authorization from Supernova Invest.
In addition, the Website may establish hypertext links to third-party websites. Supernova Invest shall not be liable for the content and operation of these third-party sites or for any damage of any kind that may be suffered by the user during a visit to these sites. Users are invited to carefully read the general terms and conditions of use and/or the personal data protection charter of these third-party sites.
GENERAL APPROACH TO TAKING ESG CRITERIA INTO ACCOUNT IN INVESTMENT POLICIES AND, WHERE APPROPRIATE, RISK MANAGEMENT
The environmental criterion:
– Waste treatment;
– Reducing greenhouse gas emissions;
– Reducing energy consumption.
The social criterion:
– Staff training;
– Respect for employee rights;
– The proportion of men and women;
– Employment of persons with disabilities;
– Job creation.
– Independence of the board of directors;
– Transparency in executive compensation and anti-corruption actions;
– Transparency in information reporting.
Content, frequency, and means used to inform customers (subscribers).
As ESG criteria are an intrinsic part of the analysis of investment files, unofficial feedback on these points is obtained for each investment decision through an investor advisory committee that is set up for each of the funds. These committees meet at least on a quarterly basis.
List of UCIs concerned by the inclusion of ESG criteria and share by percentage of the assets of these UCIs in the SGP’s assets.
The list of investment vehicles involved in incorporating ESG criteria is as follows:
– CEA Investissement – 28%;
– Amorçage Technologique Investissement – 15%;
– Supernova 2 – 29%;
– Crédit Agricole Innovations & Territories – 19%; – FCPI Amundi Avenir Innovation – 9%.
Adherence of the entity and/or UCIs concerned to the relevant charters, codes, initiatives, and labels relating to the integration of ESG criteria.
To date, Supernova Invest, which takes ESG criteria into account in its overall strategy, particularly in relation to its investments, has not yet adopted a specific ESG charter or label. This decision may change over time.
CONFLICT OF INTEREST PREVENTION AND MANAGEMENT POLICY
In accordance with the regulations in force resulting from the transposition of the Markets in Financial Instruments Directive (MiFID Directive), Delegated Regulation (EU) no. 231/2013 of the Commission of 19 December 2012, and the AMF General Regulation, Supernova Invest establishes and maintains a conflict of interest management policy and implements specific provisions in terms of organization (means and procedures) and controls in order to prevent, identify, and manage conflicts of interest that may affect the interests of its customers.
A conflict of interest is defined as a situation that implies having to choose:
– between the interests of the management company and the persons concerned on the one hand, and the customer’s interests on the other;
– between the interests of one customer and the interests of another customer.
The prevention of conflicts of interest involves raising awareness among all Supernova Invest staff of internal and market-wide rules and codes of conduct, as well as the implementation of strict procedures with a compliance and internal control system, the manager of which is responsible for ensuring compliance with the rules and procedures.
Supernova Invest has a code of ethics that its employees must follow. It is intended to ensure compliance with the principles relating to the primacy of customers’ interests and the prevention of conflicts of interest. Each employee is required to behave honestly and act fairly in the interests of customers while respecting the integrity, transparency, and security of the market.
Supernova Invest has set up a framework for personal transactions, external functions or mandates, external equity interests, and gifts and benefits received or offered.
Compensation management system:
Supernova Invest has set up a system for identifying and classifying the benefits and remuneration it receives and pays to ensure compliance with the applicable provisions.
Supernova Invest has also established a remuneration policy for its employees in accordance with the common requirements of the AFG, France Invest (formerly AFIC), and the ASPIM on remuneration policies within management companies.
Identification of conflicts of interest:
An annual review of activities is carried out in order to detect conflicts of interest likely to harm the interests of customers by formalizing a conflicts of interest risk map. This map specifies the types of activities for which a conflict of interest is likely to occur and lists the mechanisms and procedures put in place to prevent any risk of such a conflict.
Management of conflicts of interest:
In accordance with the regulations, the RCCI maintains and updates a register containing, as necessary, the types of investment services or related services or other activities carried out by Supernova Invest or on its behalf for which a conflict of interest has occurred. A note explaining the context and how the conflict was managed is systematically drafted.
Finally, in the event that Supernova Invest finds that the measures implemented are insufficient to ensure, with reasonable certainty, that the risk of harming the interests of customers can be avoided, the company will inform the customers concerned in writing of the nature of the conflict or its source so that they can make an informed decision.
PROCESSING OF COMPLAINTS
Complaints may be sent to any Supernova Invest employee by:
– A written letter to the following address: Supernova Invest, 9 rue Duphot, 75001 Paris.
– An e-mail to the following address: email@example.com or firstname.lastname@example.org specifying the term “Complaint(s)” in the subject-matter of the e-mail.
– A telephone call to the head office (01 86 64 01 85), it being specified that written confirmation by e-mail or letter is necessary for the complaint to be handled methodically.
The RCCI will acknowledge receipt of the complaint to the customer within 10 working days of receipt. In coordination with the Chairman or Chief Executive Officer, the RCCI responds to this complaint within a maximum of two months from the date of receipt unless there are specific and duly justified circumstances. Only executives have the authority to sign the response letter to this complaint.
Given its size, the Management Company does not itself have an internal mediation service. However, the matter may be referred to the AMF Ombudsman to resolve a dispute amicably in order to avoid legal proceedings. The mediator can be contacted by the customer in two ways:
– Log on to the AMF’s website at the following address: www.amf-france.org , go to the link indicated at the bottom of the screen entitled “The AMF Ombudsman,” select the tab “The Ombudsman, guide,” choose “Contact the Ombudsman,” and complete the ” Mediation request form.”
– Contact the AMF Ombudsman by mail at the following address: Le Médiateur, Autorité des marchés financiers, 17 place de la bourse, 75082 Paris Cedex 02
The AMF mediation charter is available on the website: http://www.amf-france.org in the “AMF Ombudsman” area.