Hi Inov S.A.S. is a management company approved by the French Financial Markets Authority (AMF) on February 21, 2012, under number GP-13000007. Autorité des marchés financiers 17, place de la Bourse – 75082 PARIS CEDEX 02 Tel : (+33 1) 53 45 60 00 – Fax : (+33 1) 53 45 61 00
Publisher: : Hi Inov S.A.S. 30 Bis Rue Sainte Hélène 69002 LYON – France, Tel.: +33 (0)4 72 15 15 00 Legal representative: Pierre-Henri Dentressangle S.A.S. with share capital of €500,000 – Lyon Trade and Companies Register No. 755 525 385
La Quincaillerie – la-quincaillerie.fr
La Quincaillerie – la-quincaillerie.fr
Platform – 131 Bd de Sébastopol, 75002 Paris
The information included on the www.hiinov.com website is strictly provided for information purposes only; Hi Inov S.A.S. reserves the right to modify the content. This site is intended to provide the user with information on Hi Inov S.A.S., its business activities and investment solutions. The information published on this website shall under no circumstances be considered an offer of products or services under a Public Offering, or the prospecting or solicitation of clients or potential investors. The website content (text, images, sounds, graphics, downloadable documents, etc.) are the exclusive property of Hi Inov S.A.S. The website content (text, images, sounds, graphics, downloadable documents, etc.) are the exclusive property of Hi Inov S.A.S. Any full or partial use or reproduction of the website shall constitute infringement punishable by the French Intellectual Property Code.
Hyperlinks to other websites as well as their content shall under no circumstances whatsoever invoke the liability of Hi Inov SAS. Hi Inov SAS authorizes other websites to set up hyperlinks to its content. This authorization applies to every website, with the exception of websites publishing controversial, pornographic or xenophobic information, or information likely to offend the majority of people.
The website content (illustrations, text, photographs, etc.) constitutes original work protected in France by the French Intellectual Property Code and abroad by applicable local laws and international treaties.
By accessing the www.hiinov.com website, you agree to adhere to the French Intellectual Property Code and, more generally, to the international treaties and agreements comprising provisions relating to the protection of copyright, creations and models and/or marks. You also agree to refrain from reproducing or representing, in whole or in part, the data, articles, photos, illustrations, logos, etc. displayed on the website via any means or medium whatsoever, without express and prior written consent of Hi Inov. The same applies to translations. Similarly, you shall refrain from adding, via any means whatsoever, data, images, photos, etc. to the Hi Inov website that would modify or that would be liable to modify the content or appearance of the data, articles, photos, etc. displayed on the website.
Non-compliance with any of these intellectual property rights constitutes infringement punishable by Article L. 335-2 of the French Intellectual Property Code.
You shall be entitled to copy articles published on the www.hiinov.com website under the following circumstances only: for your own private, not-for-profit and/or informational use. You shall also be entitled to reproduce excerpts of the website for teaching, scientific, or information purposes, in accordance with Article L. 122-5 of the French Intellectual Property Code. Please be sure to cite your sources (www.hiinov.com) and the author’s name, if stated.
Pursuant to the French Data Protection Law of January 6, 1978 no. 78-17, the information recorded is reserved for use by Hi Inov SAS and will not be disclosed to any third party under any circumstances.
In accordance with Articles 38 et seq. of Law no. 78-17, all users of the website having provided their personal data shall have a right of access, correction, modification, deletion or objection. You may exercise this right at any time by sending an e-mail to firstname.lastname@example.org or a letter to Hi Inov S.A.S. 30 Bis Rue Sainte Hélène 69002 LYON – France
Cookies are stored on your computer during your visit to the website.
Cookies do not enable us to identify you: however, they record information relating to your computer’s browsing history on our website (the pages you have viewed, the date and time they were viewed, etc.) which we can access during your subsequent visits.
The retention period for this data in your computer varies depending on your browser settings.
We hereby inform you that you can prevent cookies being stored by setting up your browser as follows:
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Hi Inov and, more generally, any service provider contributing to the design and online publication of the website shall not be held liable for any proven or alleged harm or loss resulting from or relating to the use of or trust in the content, goods or services available on this website or external sources, or due to the presence of a virus, Trojan horse or other intrusive or destructive parasites on these websites or external sources. Any hyperlinks included on the www.hiinov.com website directing users to other websites shall not invoke Hi Inov’s liability. The company has no control over external websites and sources, in particular with regard to information, advertising, etc. To set up a hyperlink to a page on the www.hiinov.com website, a prior written request for authorization must be sent to: Hi Inov S.A.S. 30 Bis Rue Sainte Hélène 69002 LYON – France
Hi Inov, which verifies the quality of the information sent, cannot be held liable for any accuracies, errors, or omissions with regard to such information. The company hereby undertakes to promptly correct any errors identified. Hi Inov reserves the right to correct and modify the website’s content without invoking its liability in this respect; in particular, Hi Inov may make improvements and /or changes to the product(s) and services described on the website.
To let us know about any potential errors or submit your comments regarding the functioning of the website, please contact us via the Website’s contact form.
Policy for preventing and managing conflicts of interests
AMF General Regulation Book III Articles 313-18 through 313-28
Hi Inov hereby establishes and maintains in effect an efficient policy to manage conflicts of interest; it must be set out in writing and must be suited to its size, organization, nature, scale and the complexity of its business activities. Specifically, it must:
– Identify and state the various services and activities of the PMC, and the situations giving rise or liable to give rise to a conflict of interest.
> Prohibit or control the exchange of information between individuals carrying out activities involving a risk of a conflict of interest. > Distinct monitoring of individuals carrying out activities on behalf of clients that may have a conflict of interest. > Eliminate all economic ties between individuals that may have a conflict of interest. > Prohibit or restrict any person from exercising an inappropriate influence over the way in which a given person performs their activities. > Prohibit or control a person’s simultaneous or consecutive involvement in multiple investment services when such services would adversely affect the appropriate management of conflicts of interest.
– A register recording the services or activities liable to pose a conflict of interest must be kept and regularly maintained (every half-year of normal operations).
The company has limited exposure to risks of conflicts of interest, as its only activities comprise the collective management of streamlined or contractual FCPRs (retail private equity investment funds) intended for professional clients and consulting services provided to companies, which are governed by an efficient system of procedures and internal controls.
The company performs no management on its own behalf; as a type 2 management company, it does not provide the service of receiving and transmitting orders, does not publish its own financial analysis as the analysis produced is only intended for managers.
Finally, we would point out that the PMC’s primary means of compensation consists of management fees. Managers’ compensation comprises a fixed portion and a variable bonus, depending on the PMC’s net profit. Managers receive no compensation in respect of the transactions carried out, which excludes unjustified portfolio rotations. Managers are eligible to subscribe to “carried interest”, which is not liable to give rise to a conflict of interest.
By its very construction, the PMC’s exposure to a risk of a conflict of interest is therefore limited. However, the management company has identified a certain number of potential conflicts of interest presented in a risk map (Appendix 1). This table serves as a basis for half-year controls and is updated annually.
The general voting policy consists in issuing a negative opinion against resolutions that are manifestly unfavorable to minority shareholders, such as the possibility of significantly increasing the share capital during periods of public tender offers, capital increases reserved for employees covering 5% or more of the capital or providing for a discount equal to or in excess of 10% in relation to the price. Votes for resolutions relating to: – an amendment to the bylaws; – the approval of the financial statements and the appropriation of earnings; – the appointment and removal of corporate bodies; – regulated agreements; – programs to issue and buy back shares; – the appointment of statutory auditors;
Hi Inov exercises its voting rights in consideration of recommendations issued by the Association Française de Gestion Financière (AFIC). The same goes for the detection, prevention and management of conflicts of interest liable to impact the free exercise of voting rights.
Every year, the RCCI (Compliance and Internal Control Officer) drafts, within four months following the balance sheet date, a report on how the company has exercised its voting rights.
“Non-professional clients and UCITS unit-holders or shareholders may submit complaints free of charge to the investment services provider. Information on the complaints handling process is made available to non-professional clients and UCITS unit-holders or shareholders free of charge” (AMF GR Art. 313-8).
All complaints received by registered letter from unitholders will be forwarded to the RCCI, regardless of their nature and impact. Hi Inov S.A.S. hereby undertakes that a response shall be provided to all complaints within a reasonable and prompt timeframe:
– No more than ten business days as from receipt of the complaint to acknowledge receipt, unless the response itself is provided to the client within this period – No more than two months between the date the complaint is received and the date a response is sent to the client, except in duly justified special circumstances.
Complaints must be posted to the following address: email@example.com or Hi Inov S.A.S. 30 bis rue Sainte Hélène 69002 LYON – France
Complaints can also be posted to AMF mediator to the following address: 17 place de La Bourse, 75008 PARIS Cedex 02 – France