Legal Notice
Publishing company
Audacia is a public limited company with a share capital of €594,256.75, registered under No. 492 471 792 in the Paris Trade and Companies Register.
SIREN No.: 492 471 792 | VAT ID: FR 46 492 471 792
Publication Director: Cédric James
Audacia is a Portfolio Management Company authorized on October 20, 2009, by the Autorité des Marchés Financiers under number GP-09000025 and a member of the French Asset Management Association.
Personal data
In accordance with Article 34 of Law No. 78-17 of January 6, 1978, concerning data processing, files, and individual liberties, you have the right to access, modify, rectify, or delete any information about you that is processed under the responsibility of Audacia, by contacting:
Audacia,
Hôtel de Bourrienne,
58, rue d’Hauteville
75010 Paris
contact@audacia.fr
01 56 43 48 00
Advertising
The purpose of this site is to provide information about Audacia. By using this site, the visitor acknowledges having had the opportunity to review this disclaimer. Investments made by Audacia carry the risk of capital loss. All risks can be found in the prospectuses available upon request from the Management Company. The tax benefits offered by some investment products managed by Audacia are generally in exchange for a lock-in period and a risk of capital loss. Please refer to the prospectus and regulatory documents of each Fund.
Audacia will strive to ensure the accuracy and updating of the information published on this site and reserves the right to correct its content at any time and without notice. It is also the visitor’s responsibility to verify the information through other means, including by contacting us. Audacia disclaims all liability and makes no guarantees regarding the content of this website or the use that may be made of it.
Intellectual Property
Any distribution, whether commercial or not, by any means is prohibited. Any reproduction, copying, duplication, representation, modification, translation, transfer, or creation of internet links in any form, referring to all or part of the information on the website www.audacia.fr, is prohibited. Furthermore, all products, trademarks, logos, and images mentioned on the website www.audacia.fr belong to their respective companies.
Hosting
This website is hosted by OVH, a SAS with a capital of €10,069,020, registered with the Lille Métropole Trade and Companies Register under number 424 761 419 00045.
Head office: 2 rue Kellermann – 59100 Roubaix – France.
Design and development
This website was designed by Post Scriptum.
Regulatory documents
Complaints handling and management policy
This policy, established in accordance with Articles 318-10 and 321-40 of the AMF General Regulation and AMF Instruction No. 2017-07, aims to describe the procedures for recording, handling, and processing complaints made by Audacia’s clients.
A complaint is a statement expressing a client’s dissatisfaction, excluding requests for information, advice, clarification, service, or assistance.
Cost
The handling of complaints is free of charge. However, the client is responsible for their own expenses (including postal, telephone, travel costs, etc.).
Internal recourse
Complaints can be addressed to:
- By post, to the following address:
Audacia
Attention: Head of Investor Relations
58 rue d’Hauteville
75010 Paris
France
- By e-mail, to the following address:
- By phone, at the following number:
01-56-43-48-00
To ensure that your complaint has reached us, it is recommended that you send it to Audacia with a request for acknowledgment of receipt.
Processing time
The complaint will be handled as quickly as possible upon receipt. Audacia has ten (10) business days from the receipt of the complaint to acknowledge it, unless a response has already been provided to the client within that timeframe.
Audacia will respond to any complaint within a maximum of two (2) months from the date of receipt of the complaint to the date the response is sent to the client, except in the case of duly justified special circumstances.
Exertal recourse
If the client is dissatisfied with the response provided by Audacia to the complaint and/or if the conflict remains unresolved, the client may refer the matter to the AMF Ombudsman through the following communication channels:
- By logging on to the AMF website at the following address:
- By post, to the following address
Autorité des Marchés Financiers
Attention: The Ombudsman
17 Place de la Bourse
75082 Paris Cedex 02
France
- By fax, to the following number:01-53-45-59-60
Conflict of Interest Prevention and Management Policy
Pursuant to the general principles laid down in Directives no. 2004/39/EC of April 21, 2004 ” MiFID ” and no. 2014/65/EU of May 15, 2014 ” MiFID II “, Audacia has formalized a policy for managing conflicts of interest and has put in place specific provisions in terms of organization and control in order to prevent, identify and manage situations of conflict of interest that could harm the interests of its customers in the context of Audacia’s provision of investment services.
Definition
A conflict of interest is defined as ” a prejudicial conflict between the interests of the company and those of its clients, or between the interests of several of the company’s clients “. Thus, a conflict of interest may arise when Audacia or one of the portfolios it manages, or one of its employees or related parties :
- is likely to make a financial gain or avoid a financial loss at the expense of one of the managed portfolios or one of the partner companies;
- has an interest in the outcome of a service provided to the client or a transaction carried out on behalf of one of the managed portfolios that differs from the interest of the managed portfolio or the partner company in the outcome;
- is incentivized, for financial or other reasons, to favor the interests of one of the managed portfolios over the interests of one or more other managed portfolios;
- engages in the same professional activity as a partner company;
- receives a benefit from a person other than the managed portfolio in connection with the service provided to the managed portfolio, in any form other than the commission or fees normally charged for that service.
Prevention
Placing the highest importance on the interests of its clients, and to prevent potential conflicts of interest, Audacia has established a policy and framework that allows it to conduct its activities independently while respecting the primacy of client interests and the confidentiality of information.
The prevention of conflicts of interest is based on the rules of conduct outlined in Audacia’s internal regulations and code of ethics. These provisions, which employees confirm they have reviewed upon joining the company, aim to ensure adherence to principles related to the primacy of client interests and the prevention of conflicts of interest: each employee is required to act with loyalty and fairness in the interest of clients while upholding integrity, transparency, independence, and market security.
This awareness among all employees of the internal rules and codes of conduct is complemented by various measures implemented by Audacia to prevent potential conflicts of interest. In particular, these include strict rules and procedures related to:
- the protection of confidential information, insider information, and professional secrecy;
- personal transactions conducted for their own account;
- to external mandates and functions performed;
- to benefits and gifts received from clients or intermediaries.
Detection
Audacia has established an organization to identify situations that could lead to conflicts of interest affecting client interests. This is achieved through the creation of a conflict of interest map that identifies potential types of situations and activities or operations that could generate conflicts, the associated risks, and the procedures in place for managing them.
Gestion
Conflicts of interest are managed in accordance with the principle of client interest primacy, meaning in a fair manner and by providing complete and appropriate information. Thus, depending on the situation, Audacia is authorized to:
- carry out the activity or transaction provided that the organization adequately manages the potential conflict of interest situation;
- inform the client if certain conflicts of interest may persist and provide the necessary information about their nature and origin;
- where appropriate, refrain from carrying out the activity or transaction that gives rise to the conflict of interest.
Corrective actions are proposed to avoid similar conflict situations in the future as much as possible.
Confirmed conflicts of interest are recorded in a register that identifies the conflicts encountered and the appropriate measures taken to resolve them.
Controls
The oversight of the conflict of interest prevention and management system within the management company is the responsibility of the Compliance Officer (RCCI), ensuring adherence to applicable legal, regulatory, and ethical provisions.
The Compliance Officer (RCCI) also conducts an annual review of all activities to identify situations that may lead to conflicts of interest and implements appropriate procedures to manage any potential conflicts in a fair manner.
Furthermore, to avoid self-monitoring, the conflict of interest prevention and management system is included in the outsourced control program. It is integrated into all other control tasks, regardless of their themes, and will be specifically mentioned in the control reports provided by the delegated Compliance Officer (RCCI).
A semi-annual Compliance and Internal Control Committee addresses all issues covered during the period and ensures the implementation of an action plan related to the recommendations made. Any anomalies and areas for improvement identified in the current system will be promptly reported to the Compliance Officer (RCCI) for corrective measures.
Client Information
In the event that Audacia determines that the measures implemented are insufficient to reasonably ensure that the risk of harming clients’ interests can be avoided, it will inform the affected clients in writing. This communication will be complete and objective, avoiding any biased arguments while clearly disclosing the constraints and risks associated with certain products or operations. The nature of the conflict will be explained to enable clients to make informed decisions based on a clear understanding of the situation.
Any additional information regarding this conflict of interest prevention and management policy can be obtained by clients by submitting a written request to Audacia or by contacting their usual representative.
Shareholder Engagement Policy
With a view to promoting long-term shareholder engagement, Directive (EU) 2017/828 of the European Parliament and of the Council of May 17, 2017, known as ” shareholders’ rights “, requires asset management companies to. (i) to draw up and publish a shareholder engagement policy describing how they integrate their role as shareholder into their investment strategy, and (ii) publish an annual report on the implementation of this policy.
As part of its portfolio management activities, Audacia has established this shareholder engagement policy, which applies to all portfolios managed and invested in equity securities.
In this regard, it is specified that Audacia is a signatory of the Principles for Responsible Investment (PRI) established by the United Nations. Its approach aims to integrate environmental, social, and governance (ESG) criteria into its asset management, engage in dialogue with the companies in which it is a shareholder, and systematically exercise its voting rights attached to the shares it holds.
Introduction
The shareholder engagement policy describes how the following elements are ensured:
- Monitoring of the strategy, financial and non-financial performance, risks, capital structure, social and environmental impact, and corporate governance;
- Dialogue with the companies in which investments are held;
- The exercise of voting rights and other rights attached to the shares;
- Cooperation with other shareholders;
- Communication with relevant stakeholders;
- The prevention and management of actual or potential conflicts of interest related to their engagement.
Audacia follows, as far as possible, the various shareholder engagement criteria described below. When it does not apply them, or applies them incompletely, it explains the reasons in this policy.
The shareholder engagement policy is reviewed periodically, and as needed, by Audacia.
Monitoring of strategy, financial and non-financial performance, risks, capital structure, social and environmental impact, and corporate governance
Audacia is committed to fully exercising its shareholder responsibilities in the interest of its investors by conducting a rigorous analysis of its holdings.
Before considering potential investments, Audacia’s investment team ensures that the target company does not operate in an excluded sector (as defined by Audacia: tobacco industry, coal industry, pornography, arms production, gambling) because such sectors do not align with Audacia’s ethical and environmental principles.
The investment team then conducts an analysis of the economic and financial performance of the investments it decides to make, while paying particular attention to their governance, as well as their social and environmental impact, using internal tools (reporting, ESG questionnaires, etc.) and through discussions with the company’s management.
For Audacia, the financial and executive independence of its investments is both a governance issue and a growth factor. Therefore, before each investment, Audacia enters into an investment protocol/shareholders’ agreement with the concerned entity, which notably includes:
- an enhanced right to information, whereby the company commits to providing Audacia with a set of elements about its activities (at least semi-annual reporting containing key financial aggregates, etc.);
- an ESG action plan, determined in collaboration with the portfolio company, which may include:
- the introduction of ESG objectives,
- the inclusion of quantified deadlines,
- the implementation of an annual reporting system to measure the progress made,
- the obligation to address ESG issues during the governance body meeting at least once a year,
- regular exchanges on best practices.
This approach ensures that non-financial factors are considered alongside financial factors when making investment decisions.
Dialogue with Invested Companies
The key element of Audacia’s shareholder engagement is the ongoing dialogue it maintains with its portfolio companies.
Indeed, these companies are regularly queried, either formally or informally (through in-person meetings, video conferences, telephone calls, or emails), about their strategy, opportunities, and risks, as well as their financial and non-financial performance, beyond the annual general meetings.
If applicable, the investment team formally monitors the financial and non-financial developments of its investments during committees (such as oversight or review committees), which are held at least once a year.
Support on both financial and non-financial matters complements this framework.
Exercise of voting rights and other rights attached to shares
Audacia is systematically invited to the general meetings of the portfolio companies in which its clients or the investment funds it manages have invested.
Audacia, with its commitment and duty to best represent the interests of its investors, pays particular attention to voting on resolutions proposed at general meetings, whether ordinary or extraordinary.
The decision on how to vote is made by the investment team member responsible for overseeing the relevant investment. Each member of the investment team is tasked with reviewing and analyzing the resolutions presented for each of their monitored investments. They evaluate each resolution in light of this policy established by Audacia and their in-depth knowledge of the investment and its activities. The decision to attend general meetings is documented and tracked for each investment.
To be effective in this approach, Audacia has established quantitative criteria to determine whether it will participate in the votes in question (including Audacia’s holding threshold, among others). These criteria are theoretical, and Audacia may choose to attend a meeting and participate in the votes regardless of these criteria.
If Audacia must participate in a general meeting of a company listed on a regulated or organized market (with limited application within Audacia), it will:
- ensure that the custodian provides the necessary documents for exercising the voting rights within the specified deadlines;
- generally follow the recommendations of the French Asset Management Association (AFG) when it issues voting guidelines for general meetings;
- ensure, above all, that the interests of minority shareholders, akin to its investors, are respected;
- may focus on other aspects, such as the approval of financial statements and their discharge, the approval of regulated agreements, the election of corporate officers, capital operations, or statutory amendments.
When Audacia needs to attend a general meeting of a non-listed company (which is the majority within Audacia) that does not present any particular difficulties, it prefers to vote by mail.
On the other hand, a member of the investment team will systematically attend in person those general meetings identified as sensitive, regardless of the company’s financial situation. Sensitive meetings are those with an agenda that has a significant strategic impact on the company (such as asset sales, etc.). The same applies to general meetings of companies facing temporary or structural difficulties.
In general, Audacia strives to participate in all votes to protect and best represent the interests of its investors. The goal is not to obstruct the proposed resolutions but rather to contribute to the overall improvement of the company’s interests by leveraging its expertise and experience and suggesting innovative solutions.
Audacia’s approach is clear and revolves around two major objectives:
- Preserve and defend the interests of its investors: Audacia participates in voting on proposed resolutions with a long-term vision, ensuring the financial health of the portfolio company. This involves (i) ensuring the effective payment of potential dividends when applicable, and (ii) maintaining the liquidity of the securities held at maturity and at the agreed price. Audacia carefully analyzes resolutions that may impact the financial situation or strategic direction of the company to prevent any future difficulties that could affect the liquidity of the securities it holds.
- Do not obstruct the proper functioning of portfolio companies: As a shareholder (direct or indirect), Audacia is committed to ensuring that its actions do not hinder the overall interests of the company.
Cooperation with Other Shareholders
In general, Audacia rarely cooperates with other shareholders or engages in collective actions in the investments it holds.
However, in the future, Audacia might, on a case-by-case basis and in a timely manner, join shareholder coalitions on initiatives aimed at improving the ESG practices of an investment.
Communication with Relevant Stakeholders
Audacia interacts with various stakeholders (investors, companies, regulators, professional organizations, etc.) with the goal of raising awareness among the investment team about long-term issues and understanding the full range of financial and non-financial risks that companies may face.
In particular, Audacia regularly participates in market discussions and engages in various working groups to address the expectations of different stakeholders regarding sustainable investment.
For example, Audacia hosts an annual ESG seminar open to all its portfolio companies, aiming to expose them to strategic opportunities offered by sustainable development and to share best ESG practices with them.
Prevention and management of actual or potential conflicts of interest related to shareholder engagement
In accordance with the applicable regulatory and ethical provisions, Audacia has established a policy for the prevention and management of conflicts of interest. The company has implemented specific organizational and control measures to prevent, identify, and manage situations of conflict of interest that could harm the interests of its clients in the context of providing investment services.
Audacia conducts an annual review of all its activities to identify situations that may lead to conflicts of interest. The company has also implemented appropriate measures to manage potential conflicts in a fair manner. Specifically, these measures include strict rules and procedures related to:
- the protection of confidential information, insider information, and professional secrecy;
- personal transactions conducted for their own account;
- to external mandates and functions performed;
- to benefits and gifts received from clients or intermediaries.
The control of the conflict of interest prevention and management system implemented within Audacia falls under the responsibility of the RCCI through adherence to the applicable legal, regulatory, and ethical provisions.
The conflict of interest prevention and management policy is available on Audacia’s website.
Report on the implementation of the shareholder engagement policy
Audacia publishes an annual report on its website, within six months following the end of its fiscal year, detailing the implementation of its shareholder engagement policy. This annual report includes:
- A general description of how voting rights have been exercised;
- An explanation of the choices made on the most significant votes;
- Information on the possible use of voting advisory services;
- The orientation of the votes cast during general meetings, with this information potentially excluding insignificant votes due to their nature or the size of the stake in the company;
Audacia’s Shareholder Engagement Policy Report (2022)
Report on Audacia’s Shareholder Engagement Policy (2021)
ESG Policy
Information on Audacia’s ESG (Environmental, Social and Governance) policy is available in the ” ESG ” section of this website.