Legal notice

General information

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

Publishing, design and hosting

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

Web design and creation:

La Quincaillerie – la-quincaillerie.fr

Front-end web development:

La Quincaillerie – la-quincaillerie.fr

Hosting:

Platform – 131 Bd de Sébastopol, 75002 Paris

Website content

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

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.

Intellectual property law

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.

French Data Protection Law

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 privacy@hiinov.com or a letter to Hi Inov S.A.S. 30 Bis Rue Sainte Hélène 69002 LYON – France

For more information, please see our data protection policy here

Cookies

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:

For Internet Explorer (8+) :

1. Click on “Tools”, then select “Internet Options”.
2. Click on the “Privacy” tab.
3. Under “Settings”, slide the cursor to the top to block all cookies.

For Firefox :

1. Click on the “Firefox” menu, then select “Options/Preferences”.
2. Click on the “Privacy & Security” tab.
3. Under “History” > “Firefox will”, select “Use custom settings for history”.
4. Deselect “Accept cookies”.

For Chrome :

1. Click on the “Chrome” menu, then select “Settings”.
2. Click on “Advanced settings”.
3. Under the “Privacy and security” section, click on “Content settings”.
4. Under “Cookies”, select the “Block third-party cookies” box.

For Safari :

1. Click on the “Safari” menu, then select “Preferences”.
2. Click on the “Privacy” tab
3. In the section “Block cookies and other website data”, select “Always” However, please note that access to certain services and sections of the Website may be altered or rendered impossible if cookies are deleted.

 

Liability

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.

 

Regulations

Policy for preventing and managing conflicts of interests

AMF General Regulation Book III Articles 317-8, 318-1, 318-12 to 318-19, 318-21, 318-39, 319-3.

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).

 

Application

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.

 

Voting policy

Discover our Report on Shareholder Engagement Policy

Reporting on article 29 LEC

 

 

Client information regarding complaints handling

Hi inov has set up a policy to respond to customer complaints.

Definition of a customer complaint:

A customer complaint is a statement of dissatisfaction with the management company.

A request for information, advice, clarification, service, or performance is not a claim.

Handling your complaint:

Your complaint will be handled by the RCCI. All complaints should be addressed to Hi inov at the following address: complaints@hiinov.com or Hi inov S.A.S. 30 bis rue Sainte Hélène 69002 LYON – France

Processing times:

Hi inov ensures that the claims processing phase is carried out swiftly and fairly towards its customers and undertakes:

• to acknowledge receipt of the complaint within a maximum of ten (10) working days from the date of dispatch of the written complaint, unless the response itself is provided to the customer within this period;
• to respond to the customer within a maximum period of two (2) months from the date of dispatch of the claim, unless special circumstances arise and are duly justified.

The processing of a claim by Hi inov is free of charge, and the customer will not incur any specific costs (administrative, research, or other fees, etc.) in connection with the processing of its claim.

AMF Mediation:

If you are not satisfied with the response to your complaint, you may contact the AMF Ombudsman free of charge, preferably by electronic form on the AMF website:

• electronic form on the AMF website, to access the form please click here
• or by post to 17 place de la Bourse 75082 Paris cedex 2

Mediation is free of charge, but it should be stressed that the customer’s choice is final.