Regulatory information

Complaint Handling Policy

In accordance with articles RGAMF 318-10 and 318-1, the company has implemented a procedure summarized below:

  1. Methods of Contacting the Management Company

The complaint can be addressed in writing to the company or verbally, by phone or during an appointment, to any employee of AgilaCapital. Only statements recording the Client's dissatisfaction with the professional are concerned, excluding requests for information, advice, clarification, service, or performance.

  1. Person in Charge of Handling Complaints at AgilaCapital:

Mrs. Véronique Cayrol – Veronique.cayrol@agila-capital.com 

  1. Complaint Handling Timeframes

AgilaCapital undertakes to send the client an acknowledgment of receipt within 10 days, in the event that their complaint cannot be processed more quickly. The request will be processed within a period not exceeding 2 months after the client sends the complaint.

  1. AMF Mediator

Agila Capital does not have an internal mediation service due to its size. However, the AMF mediator can be contacted to settle a dispute amicably to avoid legal proceedings. This mediator can be contacted by mail: Mrs. Marielle Cohen-Branche, AMF Mediator, Autorité des marchés financiers - 17 place de la bourse, 75082 Paris Cedex02. It is also possible to fill out the online mediation request form via the AMF website. The AMF mediation charter is available on the website: www.amf-france.org , "Mediator" section.

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Conflict of Interest Policy


The prevention and management of conflicts of interest at AgilaCapital are part of the general principles set out by Directive 2004/39/EC on Markets in Financial Instruments (MiFID) transposed into French law in Article L.533-10 of the COMOFI and Articles 313-18 to 313-22 of the RGAMF. Therefore, at AgilaCapital:

  • A conflict of interest management policy
  • Appropriate procedures to detect conflict of interest situations and handle potential or actual conflict situations,
  • A register of conflict of interest situations encountered; Preventive measures have been put in place. They concern, among others:
  • The ethics of employees
  • The protection of confidential information, privileged information, and professional secrecy,
  • Transactions carried out by employees for their own account,
  • Benefits and gifts received by employees from clients or suppliers,
  • The use of IT communication means by employees.
  • The regular review of all activities carried out to detect situations likely to produce conflicts of interest. Finally, in the event that AgilaCapital finds that the measures deployed are insufficient to reasonably ensure that the risk of harming clients' interests can be avoided, the company would inform the concerned clients in writing of the nature of the conflict or the source so that they can make their decision with full knowledge of the facts. Any additional information on this conflict of interest prevention and resolution policy can be obtained by clients by sending a request to AgilaCapital.

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ESG Policy

AgilaCapital does not systematically promote environmental or social characteristics and does not aim for sustainable investment, in accordance with Article 6 of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR). However, in accordance with its risk management policy for managed funds and its internal procedures, AgilaCapital integrates sustainability risks (i.e., an environmental, social, or governance (ESG) event or situation that, if it occurs, could have a significant negative impact on the value of an investment) into its investment selection and management processes. This ESG risk management approach focuses exclusively on identifying significant financial risks and does not constitute a promotion of environmental or social characteristics within the meaning of Article 8 of the SFDR. This approach is consistent with the company's fund strategy, which acts as a minority shareholder, and aims to generate high returns while proactively managing risks. In this context, AgilaCapital is committed to respecting the standards established by the International Labour Organization (ILO) Conventions and the United Nations Guiding Principles on Business and Human Rights, and also commits not to invest in sectors excluded by the Principles for Responsible Investment (UNPRI), such as:

  • Controversial weapons: nuclear, biological, chemical weapons, anti-personnel mines, cluster munitions,
  • Fossil fuels: coal, oil, tar sands, Arctic drilling,
  • Tobacco: production and distribution,
  • Adult entertainment: pornography and associated services,
  • Alcohol: particularly when linked to irresponsible marketing or social harm,
  • Deforestation-related products,
  • Human rights violations: companies operating in conflict zones or with poor labor practices,
  • Severe environmental damage: repeated violations of environmental laws or major pollution events,
  • Corruption and bribery: companies with a history of governance failures. However, the Management Company reserves the right to reconsider the opportunity to integrate sustainability risks into a Fund's investment decisions as soon as the invested company is engaged in a sustainable approach, and in agreement with potential investors.

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Shareholder Engagement Policy and Voting Rights

The "Shareholder Rights" Directive transposed into French law aims to strengthen long-term investment in companies and promote transparency of investments made by "institutional investors." AgilaCapital is required to describe and make accessible to its investors its long-term commitment to the issuers of shares in which it invests its funds. The policy implemented by AgilaCapital describes how its shareholder role is integrated into its investment strategy. It fully incorporates the voting policy and describes the additional measures put in place by AgilaCapital to strengthen the dialogue with its issuers. The AgilaCapital Shareholder Engagement Policy is available upon request from the holders of FIA shares it manages.

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Remuneration Policy

In accordance with the "AIFM" Directive No. 2011/61/EU of June 8, 2011, AgilaCapital has drafted a remuneration policy that it makes available to the holders of FIA shares it manages.