Atlantic Vantage Point is an asset management company authorized by the Autorité des Marchés Financiers (AMF) under n° GP16000006.

Its registered office is located at 10 boulevard Haussmann 75009 Paris.

Article 4(1)(b) of Regulation (EU) 2019/2088, enacted by the European Parliament and the Council on 27 November 2019, concerning sustainability-related disclosures in the financial services sector (“SFDR”), requires fund managers to disclose a statement on how they consider the principal adverse impacts of their investment decisions on sustainability factors.

With respect to each of the funds it manages, AVP uses an approach to sustainability risks that is derived from the integration of ESG criteria in its investment process and investment monitoring. It has integrated sustainability risks in investment decisions based on its sectorial and normative exclusion policies.

Sectorial exclusion policies are one of the pillars of AVP’s approach to sustainability risks. Exclusions aim to enable AVP to exclude from its contemplated investments the assets exposed to significant sustainability risks or that may have a significant adverse impact on sustainability factors.

Except for the exclusions mentioned in the Responsible Investment Policy, AVP does not currently systematically take into account the adverse impacts specified in the EU SFDR regulation, due to the limited availability of normative data inherent in Venture Capital investments (start-ups).

AVP has implemented a Conflict of Interest Policy, placing particular emphasis on the interests of the fund unit holders. As a member of the association, AVP is required to adhere to the France Invest Code of Ethics.

A conflict of interest exists when a party’s private interest interferes or even appears to interfere in any way with the interests of another party. AVP has detected the following examples of Conflicts of Interest:

• Potential conflicts of interest between Funds
• Potential conflicts of interest between portfolio companies
• Potential conflicts of interest between Investors
• Potential conflicts of interest between AVP or a Fund and an employee
• Potential conflicts of interest between AVP and a portfolio company

To manage conflicts of interest effectively, AVP has implemented the following measures:

• Disclosure: Employees must disclose any actual, potential, or perceived conflicts of interest. This includes disclosing personal investments in target companies. For this purpose, employees are required to sign a code of ethics annually.
• Avoidance and Management: Employees should do their best to avoid conflicts of interest. If a conflict is unavoidable, they must take steps to manage it appropriately. This may involve recusing themselves from certain decisions or discussions.
• Escalation: Employees who find themselves in situations of conflict should escalate the matter to management and the RCCI immediately. Compliance will provide guidance on how to proceed and mitigate the conflict.

For any complaint, you can send a letter to the following address: Atlantic Vantage Point – CUSTOMER COMPLAINT – 10 boulevard Haussmann 75009 Paris or by e-mail to the following address: Marc.lewden@avpcap.com specifying in the subject: CUSTOMER COMPLAINT

We commit to acknowledge the complaint within a maximum of 10 working days from the date of sending your written complaint and to respond within a maximum of 2 months from this date.

If you are not satisfied, you can contact the AMF:

Médiateur de l’AMF
Autorité des marchés financiers
17, place de la Bourse
75 082 Paris cedex 02

Demande de médiation | AMF
Charte de la médiation

In accordance with the  Règlement Général sur la Protection des Données (« RGPD ») dated May 25, 2018 and French law n° 78-17 of January 6, 1978 (Loi informatique et liberté), the personal data collected by Atlantic Vantage Point may be used.

The purposes of the collection are as follows:

• To comply with the legal and regulatory obligations of the management company;
• To execute a contract related to its products and services;
• To preserve the public interest (fraud prevention, crime, etc.);
• To periodic communication to investors;
• To invite its customers and partners to business events.

Authorized persons have access because of their activities or mission to strictly required data. Similarly, Atlantic Vantage Point service providers may have access to all or part of this data, as part of the execution of their duties. These recipients are all based in France or within the European Union, or comply with the requirements of the Privacy Shield program concluded between the European Union and the United States.

By visiting the website, the user consents to the terms of this data privacy policy, specifically agreeing to the collection, storage, and use of their personal data as detailed above.

You benefit of an access right to your personal data for the following: information, rectification, deletion, opposition, portability, profiling and limitation use. To exercise your rights, you can send a request by email to dataprivacy@avpcap.com or by postmail to: Atlantic Vantage Point – 10 boulevard Haussmann 75009 Paris, specifying your surname, first name, address and attaching a copy of both sides of your an identity document, or send a complaint to the CNIL on its website www.cnil.fr or by postmail to: CNIL – 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07.