Our investment fund is constituted in accordance with the laws in force in its jurisdiction of registration and conducts its activities under license from the competent financial regulatory authority.
These policies apply to all of our entities, subsidiaries, affiliates, and the funds we manage or administer.
We ensure that our investors, employees, portfolio companies, and partners can count on exemplary, responsible, and ethical conduct from us. Transparency and the disclosure of essential information are at the heart of our mission.
Business Integrity and the Fight Against Money Laundering
Our fund is fully committed to preventing all forms of financial crime:
- money laundering
- financing of terrorism
- corruption
- fraud
- illicit activities that could harm financial integrity.
We apply a risk-based approach, based on internal procedures, control systems and enhanced governance to ensure a high level of prevention within all teams: managers, employees, consultants and service providers.
Our AML/CFT Policy complies with the requirements of European directives, OECD recommendations, and any relevant regulations applicable to the investment fund sector.
It notably includes the designation of a AML/CFT Manager (MLRO – Money Laundering Reporting Officer), responsible for overseeing compliance with international laws and standards.
Anti-Corruption and Anti-Bribery
We adopt a zero tolerance regarding corruption, bribery and unethical practices.
We always operate in the following way:
- fair,
- transparent
- proportionate to regulatory obligations,
- compliant with applicable anti-corruption laws, including those issued by our regulator as well as international directives and guidelines (EU, OECD).
Our Code of Conduct and Ethics formalizes this approach and defines the expected behaviors during any professional interaction.
We demand impeccable integrity from our teams and expect the same level of compliance from all our partners, suppliers, service providers, co-investors and portfolio companies.
Anti-Fraud
We are committed to :
- prevent all forms of fraud
- to establish an internal culture of vigilance and integrity
- maintain effective controls to reduce risks
- enquêter rapidement sur toute suspicion de fraude
- take appropriate disciplinary or legal action
- analyze and improve our systems to prevent any recurrence.
We do not tolerate any form of fraud, concealment or malfeasance, whether by our employees or third parties.
Any allegation or suspicious behavior is subject to a thorough investigation.
We also provide a whistleblowing mechanism allowing anyone to confidentially report any suspicion of fraud, corruption or non-compliant behavior.
Transparency
We are committed to the highest standards of transparency, reporting and governance.
We voluntarily adhere to the principle of "Comply or explain", in accordance with applicable national governance codes.
Managing conflicts of interest
We recognize that certain situations may generate potential conflicts of interest, involving personal, professional or financial interests.
We have procedures in place to :
- declare and quickly identify any conflict
- analyze the situation impartially
- put in place the appropriate measures to prevent or mitigate the risk
- document and manage each conflict transparently.
Our goal is to ensure that all investment or management decisions are made in the sole interest of investors and in compliance with ethical rules.
To be confirmed or adapted by WIC Capital
To be adapted by WIC Capital
To be adapted by WIC Capital
To be confirmed or adapted by WIC Capital