Regulatory notices

1. Shareholder engagement policy

SWEN Capital Partners has developed a “shareholder engagement policy” covering all of its assets and which reflects its commitment through a voting policy at general meetings of companies in which it has a direct stake, but also the maintenance of continuous dialogue with companies or management companies - GPs (regular meetings on ESG issues), monitoring of the extra-financial performance of invested assets, definition of ESG clauses (side letter, shareholders' agreement) and / or participation strategic decisions by taking part in fund or company committees.
Download the report on the implementation of the 2020 shareholder engagement policy, click here

2. Conflicts of interest policy

SWEN Capital Partners has developed a “policy for preventing and managing conflicts of interest” that is suited to its size, its organisational set-up, and the nature, extent and complexity of its business activity.
This policy aims to prevent, identify and manage conflict-of-interest situations that could harm our clients’ interests.
To find out more, click here

3. Best selection policy

SWEN Capital Partners has developed a “policy for selecting and evaluating intermediaries and counterparties” allowing it to select, for each category of financial instrument, those intermediaries whose execution policies allow SWEN Capital Partners to meet its obligation of best serving its clients’ interests and promoting market integrity.
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4. Client complaints policy

SWEN Capital Partners has developed an efficient and transparent process for the reasonable and prompt handling of customer complaints.

  • DEFINITION
    A complaint is defined as a statement of dissatisfaction by a client or fundholder to a professional. A request for information, an opinion, a clarification, or the performance of a service is not a complaint.
  • TRANSMISSION
    Complaint shall be sent by registered mail with return receipt to the following address :
    SWEN Capital Partners – Service Réclamations
    20-22 rue Vernier – 75017 PARIS
  • PROCESSING TIME
    SWEN Capital Partners ensures that complaints will be processed promptly and fairly and pledges :
    • to confirm receipt of all complaint within 10 business days through any means of its choice. A reply to the complaint within 10 days releases SWEN Capital Partners from the obligation of confirming receipt ;
    • to reply to any complaint within two months barring special, duly justified circumstances.
  • OMBUDSMAN
    SWEN Capital Partners does not itself have an in-house ombudsman.
    However, if its response is not satisfactory, it is possible to appeal to 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 form for appealing to the AMF ombudsman and the ombudsman charter are available at: www.amf-france.org.

5. Data protection policy

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6. Remuneration Policy

SWEN Capital Partners has defined and formalized a remuneration policy in accordance with the provisions of the AIFM Directive. Its scope extends from General Management and other Directors and Managers of the various internal departments to business managers and financial and ESG analysts (considered to be the “risk takers”). It is validated annually by the Board of Directors. Also and in accordance with the Disclosure Regulation, the policy sets in particular rules relating to the consideration of risks, including sustainability, in the allocation of remunerations. Information on how the policy is adapted to the integration of sustainability risks can be found in the sustainability policy of SWEN Capital Partners

7. Anti-corruption code of conduct

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