Regulatory information

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Shareholder engagement policy

SWEN Capital Partners has drawn up a “shareholder engagement policy” covering all its assets, which reflects its commitment through a policy of voting at the general meetings of companies in which it holds a direct stake, but also through maintaining an ongoing dialogue with companies or management companies (regular meetings on ESG issues), monitoring the extra-financial performance of invested assets, defining ESG clauses (side letter, shareholders’ agreement) and/or participating in strategic decisions by taking part in fund or company committees. To find out more, click here. To download the report on the implementation of the 2022 shareholder engagement policy, click here.

Policy for the prevention and management of conflicts of interest

SWEN Capital Partners has drawn up a “Conflicts of interest prevention and management policy” appropriate to its size, organisation and the nature, importance and complexity of its business. The aim of this policy is to prevent, identify and manage situations of conflict of interest that could harm the interests of our customers. To find out more, click here.

Intermediary and counterparty selection policy

SWEN Capital Partners has drawn up a “Policy for the selection and evaluation of intermediaries and counterparties” enabling it to select, for each category of financial instrument, intermediaries whose execution policy enables SWEN Capital Partners to meet its obligation to serve the best interests of its clients and to promote the integrity of the market. To find out more, click here.

Customer complaint handling policy

SWEN Capital Partners has developed an efficient and transparent procedure for the reasonable and prompt handling of complaints submitted by its clients.

  • Definition: a complaint is defined as a statement of dissatisfaction by the client / holder with the professional. A request for information, advice, clarification, service or provision is not a complaint.
  • Methods of transmission: complaints must be sent by post with acknowledgement of receipt, to the following address SWEN Capital Partners – Service Réclamations, 20-22 rue Vernier – 75017 PARIS.
  • Processing times: SWEN Capital Partners ensures that the claims processing phase is carried out swiftly and fairly towards its clients and undertakes 1) to acknowledge receipt of any claim within 10 working days, by any means. A response to the complaint within this period exempts SWEN Capital Partners from acknowledging receipt of the complaint; 2) to respond to any complaint within a maximum period of 2 months except in the event of duly justified special circumstances.
    Mediation: SWEN Capital Partners does not itself have an internal mediation service. However, if the response is not satisfactory, you may refer the matter to the AMF Ombudsman: 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 and the mediation charter are available at

Compensation policy

SWEN Capital Partners has defined and formalised a remuneration policy that complies with the provisions of the AIFM Directive. Its scope extends from General Management and other Directors and Heads of the various internal departments through to investment managers and financial and ESG analysts (considered to be “risk-takers”). It is validated annually by the Board of Directors. In accordance with the Disclosure Regulation, the policy also sets out the rules for taking account of risks, including those relating to sustainability, when awarding remuneration. Information on how the policy is adapted to the integration of sustainability risks can be found in the SWEN Capital Partners Sustainability Policy.

Anti-bribery and corruption code of conduct

To find out more, click here.

Publication of sustainability information

To find out more about the Declaration on the main negative impacts of investment decisions on sustainability factors, click here. To download the Article 29 LEC report, click here.