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Melanion Capital,
17 Avenue George V,
75008 Paris
Email: contact@melanion.com

In accordance with its regulatory obligations, Melanion Capital makes the following documents available.

Melanion Capital SAS is an independent investment management company, authorized by the “Autorités des Marchés Financiers” (http://www.amf-france.org), under the number GP-13000020, and under directive n ° 2011/61 / EU (Directive AIFM) and Directive 2009/65 / EC (UCITS Directive).

Remuneration policy

The objective of the Policy is to specify the terms and conditions for determining and paying the overall amount of compensation allocated by the management body of MELANION CAPITAL for a given fiscal year to the employees concerned, this total amount including fixed compensation. and variable compensation.

The remuneration policy has been put in place in order to:

  • Actively support the strategy and objectives of MELANION CAPITAL;
  • Support the competitiveness of MELANION CAPITAL on the market in which it operates;
  • Ensure the attractiveness, development and retention of staff.

The Remuneration Policy is intended to define the criteria used by MELANION CAPITAL for the evaluation of the performance of the persons concerned and the determination of fixed and variable remuneration.

The Policy has been validated by the management body of MELANION CAPITAL, in its supervisory function. Annually, the policy is reassessed.

The policy applies to the following compensation:

  • The fixed part of the remuneration of the employee concerned which rewards the employee’s ability to meet the criteria defined for his position in a satisfactory manner,
  • The variable part of the remuneration of the employee concerned, which aims to recognize individual performance, contributions and behavior.

Compensation is individual and negotiated during the employment contract by the Management of MELANION CAPITAL. It may be revised according to the development of the employee and of the Management Company, within the limits set by the overall remuneration policy. An appropriate balance is established between the fixed part and the variable part of the employee’s total compensation.

Dividends or similar distributions received by shareholders as owners of shares in the Management Company are not covered by the policy insofar as they do not have a significant effect resulting in circumvention of the regulations.

Likewise, compensation in the form of incentive and profit-sharing for the Management Company does not fall within the scope of this policy.

The following are also excluded from the remuneration policy because they have no incentive effect on risk management:

  • Employee savings plan (ESP), Inter-Company Savings Plan and Collective Retirement Savings Plan (Perco),
  • “Article 39” supplementary retirement plans,
  • The retirement contract known as “article 83”.

The Management Company does not offer remuneration in the form of carried interest.

MELANION CAPITAL ensures that its financial situation is not adversely affected by the total compensation awarded for a given year and / or by the variable compensation paid or acquired during the year.

In accordance with the regulatory provisions of the AIFM Directive and Directive 2009/65 / EC (UCITS Directive), MELANION CAPITAL applies the principle of proportionality for the practical application of this remuneration policy.

Complaints policy:

This information has been prepared in accordance with the provisions of the General Regulations of the “Autorité des Marchés Financiers” and the instruction of AMF no. 2012-07. It is intended to inform the unitholders (hereinafter the “Client (s)”) of MELANION CAPITAL on the procedure relating to the handling of complaints. Only declarations indicating the dissatisfaction of the Client of units towards the professional are concerned, excluding requests for information, advice, clarification, service or benefit.

Person in charge of handling complaints within MELANION CAPITAL: Jad COMAIR

Any Customer wishing to make a complaint to MELANION CAPITAL is invited to send a letter to the following address:

MELANION CAPITAL Melanion Capital, 17 Avenue George V 75008 Paris, France

A complaint can also be sent to MELANION CAPITAL: – by email: rcci@melanion.com

To make sure that his complaint has reached us, we recommend that the customer send it to us asking for an acknowledgment of receipt. Processing times for declarations: MELANION CAPITAL undertakes to send the customer an acknowledgment of receipt within 10 days, in the event that his complaint could not be processed more quickly. From the date of this acknowledgment of receipt, the request will be processed within a period which may not exceed 2 months.

If you are dissatisfied with the follow-up given to your complaint, you can appeal:

– To the independent mediator of the AMF for management services on behalf of third parties and investments:

Financial Markets Authority

Mrs Marielle Cohen-Branche

AMF Mediator

17 place de la Bourse 75082 Paris Cedex 02

The AMF mediation request form as well as the mediation charter are available on the website https://www.amf-france.org/fr/le-mediateur

The procedures are confidential, free, adversarial and non-binding. Each of the parties can put an end to it when it wishes and retains the right to bring proceedings before the courts.

However, before entering the mediator, it is necessary that the customer carries out his first approach with the person in charge of the complaints within MELANION CAPITAL.

GDPR:

Implementation of Regulation 2016/679 known as “GDPR” on the protection of individuals with regard to the processing of personal data by the institutions, bodies, offices and agencies of the Union and on the free movement of such data ( …)

The management of the portfolio management company (hereinafter the “PMC”) has decided to implement the following personal data processing policy.

Management recalls that, regardless of the European Regulation, personal data is (and still is) covered by the obligation of professional secrecy.

“Personal data” is information that directly or indirectly identifies a natural person (and for example: name, email address, telephone number, postal address, etc.).

Person responsible for personal data

It is specified beforehand that given the lack of significant processing of personal data, the PMC has not decided to appoint a “personal data protection officer”. Nevertheless, the monitoring of the few personal data kept within the PMC and the monitoring of subcontractors is the responsibility of the RCCI. The RCCI is your natural correspondent for any question relating to the processing of your personal data.

The personal data stored by the PMC is the result of commercial actions that it initiates, either with professional intermediaries (insurance companies, private bankers, financial investment advisers, etc.) or with end investors.

Nature of personal data recorded

In the particular case of the activities of our company, and if we except business addresses (and in certain personal cases) and “e-mail” addresses, the personal data collected are only sensitive when they allow the investments made to be identified. by these people.

Right of access, rectification or deletion

Personal data is accessible to its owners on request. They can be corrected or deleted in the same way.

To exercise your rights, you must write to the PMC by contacting “Manager responsible for compliance and internal control” 17, Avenue George V, 75008 Paris.

In the event of a complaint, you can contact the CNIL for France, 3 Place de Fontenoy, TSA 80715 – 75334 Paris Cedex 07. Telephone 01 53 73 22 22.

Portability

Personal data may be transmitted to a third party if its owner so requires, provided that this information has not already been transmitted to it by any means.

Identification of treatments

The main treatments are of two kinds:

Communications and information of any kind intended for investors,

The managers’ knowledge of the quality of their clients in order to serve them in their best interests,

The checks planned as part of an assessment of the “risk of money laundering and terrorist financing” (mandatory system)

The control of “liability” (or “customer risk”) risks in the context of redemption resistance tests as part of the measurement of fund liquidity.

Personal data is neither sold nor passed on to third parties.

Retention period of personal data

The PMC directly or indirectly retains the personal data of its customers for up to 5 years after the end of their relationship, taking into account the legislative or regulatory obligations it has to comply with.

At the end of the legal or regulatory retention periods to which the asset management company is bound, personal data will be destroyed according to the assessments of the conservation risks of this data and the destruction protocols that will have been established for these purposes under the responsibility of the managers.

Website, cookies and other tracers

Cookies (and / or other tracers), if they are set, must be objectively and clearly accepted by visitors.

In any case, their only purpose is to allow or facilitate communication by electronic means.

SFDR Policy / Annual Report

Click here to download the document (French Version only)

Click here to download the document (French Version only)

At Melanion Capital, we prioritize transparency and clarity in our investment management. We have deliberately chosen not to integrate ESG criteria into our strategy (in accordance with Article 6 of the Sustainable Finance Disclosure Regulation – SFDR), favoring a traditional approach focused on financial returns and prudent risk management. Our communication is compliant with current regulations, and we are open to dialogue with our investors to address their questions and provide clarifications.

Policy for the prevention and management of conflicts of interest:

Melanion Capital makes every effort to identify conflicts of interest that may arise in the course of providing investment or related services.

In accordance with current regulations, Melanion Capital has a conflicts of interest management policy.

This policy is appropriate given the size, organization, nature, importance and complexity of Melanion Capital’s activity. It includes procedures to follow and measures to take in order to manage conflicts of interest, the aim being to ensure the primacy of clients’ interests and respect for market integrity.

 

Best Selection_Best Execution Policy

All investment service providers have an obligation to act in the best interests of their clients when executing orders that result from investment decisions for the portfolios.

To this end, in its capacity as management company, and having regard to the nature of its business, Melanion Capital is obligated to select intermediaries whose execution policy guarantees the best possible result when executing orders sent on behalf of its clients.

Melanion Capital nevertheless remains responsible for best execution with respect to the processing of transactions carried out directly on the market.

In accordance with the regulations, Melanion Capital has put in place an order execution policy that allows it to obtain the best possible result with respect to client orders. The order execution policy notably requires that orders be registered and processed in a timely and accurate manner, having regard to market conditions.

 

Shareholder engagement policy:

In accordance with articles R. 533-16 and R. 533-22 of the  Code Monétaire et Financier , Melanion Capital reserves the right to exercise or not the right of communication prior to general meetings depending on the information available to it.

Melanion Capital participates in general meetings, generally represented by the President or the Managing Director, each time it determines that this participation is in the interest of the investors of the vehicle concerned. Melanion Capital retains its freedom to vote on each of the securities making up the portfolio of vehicles it manages.

When the securities held by the AIF or the UCITS are admitted to regulated or organized markets of a State party to the agreement on the European Economic Area or a recognized foreign market, Melanion Capital may not exercise its voting rights if the percentage of rights held by the AIF(s) and UCITS managed is less than 5% of the voting rights of the meeting concerned.

 

This site has been created solely for information purposes and does not constitute a contractual item, or an investment or arbitrage proposal or solicitation.

Melanion Capital disclaims all liability for the content of the site and its use by anyone. The products and services presented on this site may be subject to regulatory and legal restrictions. It is the responsibility of interested parties to verify that their legal and tax status allows them to consider subscribing for products or services before contacting Melanion Capital to inquire about the availability of said products and services, and the applicable contractual and pricing conditions.

Past performance is not indicative of future performance and is not constant over time.