Legal and regulatory information

Intellectual property

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– Whistleblowing

IDIA CI, a subsidiary of the Crédit Agricole Group, has adopted the Crédit Agricole ethical charter published in 2017, setting out the Group’s commitments to responsible behaviour towards all its partners.

To strengthen its programme for preventing unethical and criminal behaviour, the Crédit Agricole Group supports any employee, external service provider or supplier wishing to exercise their whistleblowing right in order to protect the company’s interests.

Those unable to submit a report via the usual channels (for fear of retaliation, hierarchical pressure, hierarchy involvement, etc.) can exercise their whistleblowing right (“droit d’alerte” in French) via the BKMS® SYSTEMS platform. This right must be exercised selflessly, in good faith, and corroborated by facts, information or documents, regardless of their form or medium, that substantiate the report, if available.

The BKMS® SYSTEMS platform ensures the confidentiality of the whistleblower, the facts and the persons involved. The information is encrypted and stored in a secure, independent environment. The tool allows facts to be reported and communication with the whistleblowing coordinator (via a protected dialogue box) while protecting the whistleblower’s identity.

The platform is accessible online at any time and from any location via the following link:
http://www.bkms-system.com/Groupe-Credit-Agricole/alertes-ethiques

– Regulatory information

IDIA Capital Investissement (a 100% subsidiary of the Crédit Agricole S.A. group) is a simplified joint-stock company with a capital of €5,000,010, having its headquarters at 12 Place des États-Unis – 92127 Montrouge Cedex – France, registered with the Nanterre Trade and Companies Register under number 508 667 094. IDIA CI is a portfolio management company approved by the Autorité des Marchés Financiers (French Financial Markets Authority – AMF”) under number GP-150000010. It is a member of the FRANCE INVEST association.

– Management and prevention of conflicts of interest

IDIA Capital Investissement, as a management company approved by the AMF and in accordance with applicable regulations, has formalised a policy for preventing, evaluating and managing conflicts of interest and has implemented specific organisational and control measures to prevent, identify and manage situations of conflicts of interest that could harm its clients’ interests. Information on this policy can be obtained upon written request or by email to IDIA CI (conformite.idia@ca-idia.com).

– Third-party complaints

In accordance with the provisions of Articles 318-10 and 318-10-1 of the AMF General Regulation (“AMF GR”) and AMF Instruction 2012-07, the Management Company IDIA CI has established a procedure for handling complaints received from third parties.

Definition:
A complaint is defined as a written expression of dissatisfaction from a client towards the Management Company IDIA CI, whether justified or not. A request for information, opinion, clarification or service is not a complaint.

Transmission procedure:
Complaints should be submitted in writing by post or by email to conformite.idia@ca-idia.com or during a meeting with representatives of IDIA Capital Investissement.

Processing times:
IDIA Capital Investissement ensures that complaints are processed within a reasonable time and undertakes to:

• Acknowledge receipt of any complaint within 10 working days, if no response has been provided by IDIA CI within this period.
• Provide a response within 15 days in the case of a simple issue.
• In the case of a complex issue, requiring a longer processing time, IDIA CI will inform the client in writing within 10 days and, in any case, provide a response within two months of receiving the complaint.

Mediation:
IDIA Capital Investissement does not have its own internal mediation service.
If no amicable resolution is reached, the parties may then refer the matter to the AMF Mediator at the following address:

Autorité des Marchés Financiers
Médiateur de l’AMF
17 Place de la Bourse
75082 Paris Cedex 02
France

– Best selection policy for financial intermediaries

IDIA CI has established a policy for the best selection of financial intermediaries. Information on this policy can be obtained upon written request or by email to IDIA Capital Investissement (conformite.idia@ca-idia.com).

– Shareholder Engagement Policy

In accordance with the provisions of Article L. 533-22 of the Monetary and Financial Code, IDIA CI has drawn up a Shareholder Engagement Policy setting out how it integrates its role as a shareholder into its investment strategy.
An annual report is prepared on the implementation of this policy.
These documents are made available to the AMF and the public.

– Confidentiality Clause

Except with your express agreement, IDIA Capital Investissement refrains, other than for the purposes of its assignment, from communicating or using information concerning its clients.
For more information, please refer to our Privacy Policy.
To exercise your rights or any questions regarding the Privacy Policy, please contact us at contact@ca-idia.com or by post at 12 Place des Etats-Unis – 92127 Montrouge Cedex – France.