Quadrille Capital has implemented and maintains a procedure to quickly and efficiently handle complaints made by its investors.
A complaint is defined as “a statement of dissatisfaction by a client toward the professional. A request for information, opinion, clarification, service or provision is not a complaint” (AMF instruction n°2012-07 of 13 July 2012 as modified).
Any complaint may be sent to the Compliance Officer (RCCI) of the company at its registered office (16 Place de la Madeleine, 75008 Paris, France. The management company will acknowledge receipt of the complaint within ten working days of the date on which it was received and a response will be issued to the client within two months of receipt of the complaint.
In the event of an ongoing dispute, the client may contact a mediator, such as the AMF Ombudsman. The address of the AMF Ombudsman is: Autorité des Marchés Financiers, The AMF Ombudsman, 17 place de la Bourse, 75082 Paris CEDEX 02, France. The AMF mediation request form and the Mediation Charter are available online at www.amf-france.org.
Conflict of interest policy
Quadrille Capital maintains and operates an effective policy to identify, prevent, manage and monitor conflicts of interest situations that may adversely affect its customers. Quadrille Capital also holds a register that lists situations in which a conflict of interest has arisen, whenever applicable. A copy of the policy is available free of charge upon request.
Best Execution Policy and Best Selection Policy
An investment service provider must take all reasonable measures to obtain for its client the best execution of its order. Quadrille Capital does not carry out direct trading neither execution of orders with counterparties. In this context, Quadrille Capital only implemented a Best Selection Policy and selected intermediaries whose execution policy allows the best possible result when executing orders.
The criteria applied to select intermediaries that guarantee the best execution of stock market orders are both quantitative and qualitative. They depend on the markets for which the intermediaries provide services, in terms of geographical area (global, European or local intermediaries), type (large/small cap) and financial instruments traded (equity, derivatives). The analysis criteria cover the availability and proactiveness of the intermediary representatives, their financial situation, their speed, the quality and cost of the processing and execution of orders.
The intermediaries’ ratings are updated every year. Based on this, the list of selected intermediaries is also reviewed annually.
Quadrille Capital is an independent asset management company, with its capital primarily owned by its executives. Therefore, it is not dependent on any other company that could give rise to conflicts of interest. In addition, all Quadrille Capital employees have signed the Code of Ethics established in accordance with the AFG and France Invest Code of Ethics.
Monitoring of strategy, financial and non-financial performance, risks, capital structure, social and environmental impact, and corporate governance
Quadrille Capital’s Responsible Investment Policy serves as the reference framework for the development of the management company’s activities and internal guidelines. As such, Quadrille Capital excludes any investment in sectors that do not align with its beliefs (such as armaments, tobacco, and any activity that compromises the integrity of individuals or violates international norms and conventions, including human rights violations and child labor).
Quadrille Capital invests in technology and healthcare companies that, by nature, contribute to a better and more sustainable future for all (health and well-being, reducing inequalities, decent work and economic growth, innovation, responsible consumption and production…).
During the holding period, Quadrille Capital maintains constant dialogue with portfolio companies and:
- Receives regular financial reporting, often monthly or at least quarterly,
- Engages in discussions and raises awareness about good ESG practices,
- Conducts annual surveys to measure progress.
Dialogue with portfolio companies
Quadrille Capital attaches great importance to dialogue with portfolio companies as it financial and non-financial value creation. The management team regularly meets with representatives of the portfolio companies, both in person and through remote means (teleconferences, phone calls, emails). The discussions are bilateral and cover topics such as corporate strategy, performance, ESG criteria, and best practices.
Exercise of voting rights and other rights attached to shares
Quadrille Capital’s voting policy prioritizes the exclusive interests of the investors of its funds. Accordingly, regarding the voting of companies covered by the policy, votes cast by Quadrille Capital will favor:
- Establishing the foundations of effective corporate governance.
- Protecting shareholder rights and the key functions of capital holders.
- Ensuring fair treatment of shareholders.
- Recognizing the role of various parties in corporate governance.
- Promoting transparency and dissemination of information.
- Holding the board of directors accountable.
- Ensuring the sustainability and development of the company.
- Promoting sustainable development.
For securities listed on a regulated market, Quadrille Capital exercises its voting rights when it holds more than 2% of the capital or voting rights, and the investment represents more than 5% of the net assets of an investment fund.
For unlisted securities, Quadrille Capital exercises its voting rights on every occasion, without a threshold. Decisions are discussed within the management team and made based on in-depth knowledge of the company and its activities.
Cooperation with other shareholders
Understanding the other shareholders of unlisted investments in the portfolio and engaging in dialogue with co-investors are essential to Quadrille Capital. The asset management company prioritizes aligning interests and works collaboratively with co-investors.
On a case-by-case basis, Quadrille Capital may participate in collective engagement initiatives aimed at improving environmental, social, and governance practices of an investment.
Communication with relevant stakeholders
Quadrille Capital maintains contact with various parties to:
- Promote its business and entrepreneurship.
- Discuss and exchange views on financial and non-financial challenges faced by companies.
The stakeholders include:
- The regulator (AMF).
- France Invest.
- Suppliers and brokers.
- Charitable associations.
Prevention and management of actual or potential conflicts of interest regarding their engagement
Quadrille Capital ensures that the client’s interests take precedence over any other considerations. In this regard, Quadrille Capital has established a policy to detect and prevent any conflicts of interest that may arise. A mapping of potential conflicts of interest has been identified, and a mechanism for their resolution has been implemented within the company. A register of conflicts of interest is maintained by the RCCI ( “Chief Compliace FI
Employees are made aware of the risks of conflicts of interest and adhere to the erules defined in the conflict of interest management procedure and the Code of Ethics. These rules cover:
- The exercise of corporate mandates and external roles outside of Quadrille Capital.
- Personal transactions.
- Gifts, gratuities, and other exchanges.
Quadrille Capital makes the following disclosures in accordance with the Sustainable Risk Finance Disclosure Regulation (2019/2088) (the “SFDR”).
Quadrille Capital invests in high-growth technology and healthcare companies, which, by nature, contribute to achieve a better and more sustainable future for all (good health and well-being, reducing inequality, decent work and economic growth, innovation, responsible consumption and production…).
ESG criteria are a key component of Quadrille Capital’s investment policy since its creation in 2007. Quadrille Capital has already its own proven tailor-made procedures and metrics to assess the sustainability adverse impacts. Therefore, Quadrille Capital does not intend to consider the prescribed sustainability adverse impacts of the SFDR, but will follow closely the future developments related to the regulation.
Remuneration policy and sustainability
Quadrille Capital’s remuneration policy complies with the AIFM and UCITS directives requirements.
The remuneration policy is in line with the interests of the funds under management and their investors.
Quadrille Capital’s staff receives a combination of fixed remuneration (salary and benefits) and variable remuneration (bonus). Variable remuneration is discretionary, not guaranteed and take into account Quadrille Capital’s performance and individual objectives such as the respect of the ESG charter.
Non-discrimination for promotions and compensation is a cornerstone at Quadrille Capital.
Report on Intermediation Costs
Management companies are required to prepare a report on intermediation costs when they use external services for investment decision-making (financial analysis and research) and order execution services, and when intermediation costs amount to more than 500,000 euros for the fiscal year.
The scope of this report encompasses the assets present in the UCITS managed by Quadrille Capital during the fiscal year ending on December 31, 2022.
Order Execution and Research Policy
Quadrille Capital utilizes two types of intermediaries:
- Brokers used solely for execution purposes.
- Brokers that provide both research and order execution services.
Quadrille Capital has entered into a Commission Sharing Agreement (“CSA”) with an intermediary (“ICSA”). Under the terms of the agreement, when ICSA provides order execution services, a portion of the intermediation costs is allocated to third parties for investment decision-making services.
According to the CSA, a percentage of the total volume of fees paid for intermediation is allocated to third-party providers of investment decision-making and research services.
A portion of the total volume of fees paid under the CSA agreement may remain unused during a year and can be carried forward to the following year.
Intermediation costs comprise two categories:
- Execution costs, which correspond to fees related to order execution services which are paid to various intermediaries.
- Research costs, resulting from intermediaries or providers that supply investment decision-making analysis to the investment teams.
The breakdown for the transactions during the 2022 fiscal year is as follows:
- Order execution costs accounted for 90% of the total intermediation costs.
- Costs related to investment decision-making services accounted for 10% of the total intermediation costs.
Prevention of conflict of interest
Quadrille Capital has implemented a policy for preventing and managing conflicts of interest. A mapping exercise identifies potential conflict situations between the management company and its third parties to cover and mitigate potential risks.
During the year 2022, Quadrille Capital did not identify any conflicts of interest arising from the selection of intermediation service providers.