Conflict of Interest Management Policy

Divio Capital implements a system for preventing, identifying, and managing conflicts of interest in order to safeguard investors’ interests at all times. Risk situations are identified, mapped, and managed through organizational and ethical measures (segregation of duties, information barriers, post-trade controls). A conflicts of interest register is maintained and kept up to date.

The full policy is available upon request from the management company.

Remuneration Policy (AIFMD)

Employee remuneration is designed to promote sound and effective risk management, prevent conflicts of interest, and align staff interests with those of investors, without encouraging excessive risk-taking. Fixed and variable components are governed by dedicated oversight and governance structures.

The full policy is available upon request from the management company.

Voting / Engagement Policy

When the managed vehicles hold instruments that confer voting rights, Divio Capital exercises those rights exclusively in the interests of investors, following formalized voting principles (governance, financial integrity, ESG factors, and protection of minority shareholders).

The voting policy and, where applicable, the shareholder engagement policy are available upon request.

Best Selection / Best Execution Policy

The selection of intermediaries and the pursuit of best execution aim to achieve, on a consistent basis, the best possible outcome for investors, taking into account price, costs, speed, likelihood of execution, and other relevant factors.

The full policy is available upon request from the management company.

Complaints Handling Policy

Divio Capital provides a free and accessible complaints-handling process. You may contact us by email at reclamations@divio-capital.com or by mail at Divio Capital – 75 Boulevard Haussmann, 75009 Paris.

An acknowledgment of receipt will be sent within 10 business days, and a response will be provided within a maximum of 2 months, unless specific circumstances justify a delay.

If disagreement persists, you may contact the AMF Ombudsman free of charge via the online form available on amf-france.org or by mail at:

Médiateur de l’AMF
17 place de la Bourse
75082 Paris Cedex 02, France

The internal complaint management procedure is available upon request from the management company.

Data Protection (GDPR)

Divio Capital processes personal data in compliance with the GDPR and applicable regulations. Data are collected for specific purposes (client–investor relationship management, regulatory obligations, anti–money laundering, security) based on appropriate legal grounds, and are retained for limited periods. Data subjects have rights of access, rectification, erasure, restriction, objection, and portability, which can be exercised by contacting contact@divio-capital.com.

The privacy and data protection policy is available upon request from the management company.