Complaints

A “complaint” is defined as a declaration recording the customer’s dissatisfaction with the Management Company. It is important to note that a request for information, advice, clarification, service, or performance is not a complaint.

Initiative & Finance Gestion has established and maintains an operational procedure for handling complaints submitted by its clients. The procedure is available upon request at the company’s headquarters.

Complaints can be submitted free of charge:

• In writing: by registered mail or electronic message to the following adress – egc@initiative-finance.com.

• Orally : by phone at 01.56.89.97.00. The complaint will then be transcribed in writing and forwarded to the persons authorized to handle it. A copy will also be sent to you.

Initiative & Finance Gestion is committed to processing any complaint addressed to it within the following timeframes:

• A maximum of ten business days from the date the written complaint is sent, to acknowledge receipt, unless the response itself is provided to the client within this period;
• A maximum of two months, unless special circumstances duly justified, between the date the written complaint is sent and the date the response is sent to the client.

Initiative & Finance Gestion will nevertheless strive to provide you with a response as quickly as possible. Furthermore, if the complexity of the resolution leads to an extension of this period, the Management Company will notify you in advance.

All clients can seek mediation if the response to their complaint does not satisfy them. The AMF mediator can also be contacted for a dispute falling within the scope of the AMF’s competence when it concerns a professional and their client, a legal entity not acting for professional purposes, as a saver or investor. The address of the AMF mediator is as follows:

AMF Mediator
Autorité des Marchés Financiers
17, place de la Bourse
75082 Paris cedex 02

For more information: http://www.amf-france.org/en/the-mediator

Link to the AMF mediation charter: https://www.amf-france.org/en/the-amf-mediator/mediation-process/how-mediation-works

Link to the AMF mediation request: https://www.amf-france.org/en/the-amf-mediator/your-mediation-file/submit-your-mediation-request

In case of recourse to the AMF mediator, a free service, your choice is final.

Conflict of Interest Policy

A conflict of interest is a situation in which the interests of the management company or its personnel conflict directly or indirectly with the interests of its funds, their holders or their principals. It may also take the form of a conflict between funds or between holders/principals.

The prevention and management of conflicts of interest at Initiative & Finance Gestion is in line with the general principles of the French Monetary and Financial Code and the General Regulations of the French Financial Markets Authority (AMF), which specify in particular that the management company has the following obligations:

• Establish a policy for managing conflicts of interest ;
• Detect conflicts of interest ;
• Keep a register of conflicts of interest that have been proven to exist or could arise ;
• Inform investors when it has not been possible to resolve conflicts.

Our conflict-of-interest prevention and management policy involves establishing procedures to detect and manage conflicts that may occur during our collective and individual asset management activities and our investment advisory activities.

The aim of this policy is to ensure the protection and primacy of the interests of stakeholders in the various funds and mandates we manage or recommend.

For further information, please contact the management company.

Shareholder engagement

The policy on shareholder engagement, votes, and abstentions is available upon request at the company’s headquarters.