Legals

Remuneration Policy and Shareholders Engagement Policy

The remuneration policy and inclusion of sustainability risks

Alba Infra Partners pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account compliance with all Alba Infra Partners’ policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process.

Shareholders Engagement Policy

Alba Infra Partners has adopted a Shareholders Engagement Policy :

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Regulatory information

Conflict of interest policy

Alba Infra Partners has adopted a conflict of interest management policy in accordance with the applicable legal framework. In this respect, Alba Infra Partners maintains and operates organisational measures with a view to take reasonable steps designed to identify, prevent, manage and / or monitor conflict of interest aiming to ensure the primacy of the interests of the investment funds it manages (the “Funds“) and their underlying investors.

Identifying conflict of interest

A confict of interest situation may arise when the interests of several persons are, directly or indirectly, in competition. Alba Infra Partners takes all reasonable steps to identify conflict of interest that may arise, as the case may be, in the course of managing the Funds between:

Alba Infra Partners, including its directors, officers, employees or any person directly or indirectly linked to Alba Infra Partners by control, and a Fund managed by Alba Infra Partners or its underlying investors;
a Fund or its underlying investors, and another Fund or its underlying investors; or
a Fund or its underlying investors, and another client of Alba Infra Partners.

Alba Infra Partners’ compliance and internal controller (Responsable de la Conformité et du Contrôle Interne) is in charge of assessing situation where a conflict of interest may arise. In particular, Alba Infra Partners has processes in place aiming at detecting and monitoring situations where Alba Infra Partners or its related persons is likely to receive some advantage at the expense of a Fund, its investors or clients, or is in a situation where interests of different Funds, investors or clients might be in competition.
In this context, Alba Infra Partners has established organizational and administrative arrangements aimed to limit the risk of conflict of interest in the normal course of business, including the following measures :

Investment allocation: rules of allocation are implemented to allocate, as the case may be, the investment opportunities among the Funds;
Risk mapping: a risk mapping identifying potential conflict of interests has been drawn up and is periodically updated;
Employees training and awareness: the relevant employees are periodically trained on Alba Infra Partners ‘ policies, the regulatory and legal requirements for preventing and identifying conflict of interest;
Gift & benefits: the receipt of gifts or similar benefits from business relationship is limited and monitored; and
Personal dealing: Alba Infra Partners’ employees are subject to disclosure obligations and restrictions in relation to their personal transaction in the financial markets.

Managing conflict of interest

For each case identified, the conflict of interest procedure provides a course of action and measures to be taken in order to manage a conflict of interest when it arises.
Where Alba Infra Partners organisational or administrative arrangements are considered by Alba Infra Partners not sufficient to ensure with reasonable confidence that the risks of damage to the interests of a Fund or its underlying investors resulting from a conflict of interest are prevented, Alba Infra Partners will inform the concerned investors of the general nature and/or source of the conflict of interest.
These situations, if they occur, are recorded in a conflict of interest register maintained by Alba Infra Partners.

Client complaint management policy

Alba Infra Partners drawn up and operates a specific procedure in order to manage client complaints, in accordance with the applicable legal framework.

Definition of ‘complaint’

A complaint is defined as a claim caused by the client’s dissatisfaction with the investment service provider. A request for information, advice, clarification or service is therefore not considered to be a complaint.

How to send your complaint?

You are able to send a complaint relative to investment services provided by Alba Infra Partners or relative to a subscription into a fund managed by Alba Infra Partners. You can contact your usual representative or send a written complaint to the Compliance Officer at Alba Infra Partners, 134 rue du Faubourg Saint Honoré, 75008 Paris, France, or at the following email address: contact@alba-ip.com.

Processing your request

Once your complaint has been received, you will be issued:

a confirmation of receipt within 10 working days, unless the answer is provided to you in the meantime;
an answer within 2 months of receipt of your complaint (unless duly justified circumstances require a longer period).

Processing of your request will be free of charge. We will respond to any request for information on the processing of your claim.

Contact the “Autorité des Marchés Financiers (AMF)” ombudsman

In the event of the answer provided by Alba Infra Partners not meeting your expectations, you are also able to contact the AMF Ombudsman using the following link: www.amf-france.org or write to the following address: Médiateur de l’AMF, Autorité des Marchés Financiers, 17 place de la Bourse, 75 082 Cedex 02, France.
Additional information on the Mediation Charter are available on the AMF website.

Legals Information

This website is the property of Alba Infra Partners, a French société par actions simplifiée with capital of EUR 1,000 registered with the “Paris Registre du Commerce et des Sociétés” under number 980 226 633, and whose headquarters are located 134 rue du Faubourg Saint Honoré, 75008 Paris, France.
Alba Infra Partners SAS is registered as a management company with the AMF under number GP-20240009 – Alba Infra Partners SAS was approved by the AMF on 27 May 2024.
E-mail : contact@alba-ip.com;
Head of publication: Stéphane Grandguillaume, CEO (président) of Alba Infra Partners.
This website was created by 3Types Studio.

Terms and condition of Use

This website is intended to users who are at least eighteen (18) years old.

By using this website, you confirm that you are at least eighteen (18) years old, and you agree to these Terms and Conditions of Use (the “Terms”), which constitute a legal agreement between you and Alba Infra Partners governing your access to and use of the Website.

It is your responsibility to review the Terms and to make sure you understand and comply with them. Your compliance with the Terms is an ongoing condition to your use of the Website, and you may not use it if you are not prepared to comply with all of the Terms.

If you are a “Registered User” benefiting from a personal access to the dedicated investor portal accessible from the Website and hosted by Intralinks, Inc.’s (the “Investor Relations section”), you shall in addition comply with the provisions specifically dedicated to Registered Users set out herein and through the Investor Relations section.

Purpose of the Website

The purpose of this website is to present general information about the activities of Alba Infra Partners.
The information on the Website shall not be regarded as information of a contractual nature and nothing on the Website should be construed as an offer, recommendation, invitation or solicitation in relation to any services or products of Alba Infra Partners or any fund it manages, and generally should not form the basis for entering into any transactions, services or other legal arrangements.

Nature of the information provided on the Website

While Alba Infra Partners seeks to present information on the Website in a manner that it believes to be reliable, the information provided on the Website is provided “as is” and for information purposes only and shall not be relied upon. As a result, the users shall take all steps to verify the fairness, completeness, accuracy, quality and suitability of any and all information accessible on the Website.

Alba Infra Partners may update, complete, correct or revise contents of the Website at any time without notice, but is under no obligation to do so.

Liability

Alba Infra Partners makes no representation and accepts no liability or responsibility to you or any other party in relation to the Website, including in respect of the fairness, completeness, accuracy, quality or continued availability of any contents on the Website. Any and all warranties of any kind, express or implied, including without limitation warranties of merchantability, fitness for a particular purpose, title or non-infringement, are excluded to the fullest extent permitted under applicable law in respect of Alba Infra Partners, its directors, officers, employees, external advisers, affiliates and affiliated funds.
You agree to indemnify, defend and hold harmless Alba Infra Partners from and against all claims, liabilities, demands, damages, losses or expenses, including notably legal fees and costs, resulting from or arising out of your improper access to or use of the Website and/or any breach of these Terms attributable to you.

Local regulations

The laws and regulations of the country from which you access the Website may contain restrictions on the distribution of the information the Website contains. If this is the case, this information may not be distributed or used by any natural person or legal entity. Access to products / services of Alba Infra Partners may be restricted and therefore not provided should these products be unlawful in your resident country. You shall be obliged to inform yourself in this respect of and to observe any such restrictions.

Accessibility and use of the Website

The Website is provided “as is” and accessible according to its availability. Alba Infra Partners endeavours to ensure that the proper functioning of the Website. However, Alba Infra Partners does not provide, and expressly excludes, any guarantee regarding the right to access this Website or the fact that it is free of errors, viruses and/or malicious codes of any kind.
When using Website, you undertake not to:

make available viruses or other technologies likely to harm Alba Infra Partners or the interests or property of Alba Infra Partners’ users;
use robots, scraper or even use any other automatic process to access the functionalities of Website without being authorised to do so;
copy, modify or distribute Website content;
copy, reproduce, reverse engineer, modify, create derivative works, distribute or disclose to the public any content (except for your own information) from Website without the express prior written consent of Alba Infra Partners or, if applicable, that of the relevant third parties;
collect, accumulate, transmit to other media, make public, publish or disclose data relating to the other users of Website or concerning their activity on Website;
accessing or attempting to access the Investor Relations section if you do not or no longer qualify as Registered User.

Data protection and cookie policy

Please note that information enabling to identify you directly or indirectly (hereinafter “Personal Data”) is processed by Alba Infra Partners in relation to your use of the Website, including by means of cookies.
To know more about the processing of Personal Data implemented by Alba Infra Partners as well as its use of cookies, please refer to Alba Infra Partners’ privacy policy and cookies policy.

Intellectual property rights

The general structure as well as software, texts, graphs, animated or non-animated images, videos, photographs, sounds, know-how, databases, brand names, logos and all other components of this Website are the exclusive property of Alba Infra Partners or of third parties from which Alba Infra Partners was granted the necessary rights.
Any representation, reproduction, or utilisation, whether in whole or in part, of any of the above-mentioned elements that is not expressly authorised by Alba Infra Partners, is prohibited and will constitute an infringement of its intellectual property rights pursuant to the relevant provisions of the French Intellectual Property Code. The authorisation to access and/or use granted to the user does not entail any transfer of intellectual or material property.

Links to third party websites

This Website may display links redirecting to pages and websites published by third parties. In this respect, please note that Alba Infra Partners neither has any control over the content published by such third parties nor monitors such content. For instance, if you are a Registered User, you will be redirected to Intralinks, Inc.’s portal for accessing the Investor Relations section.
As a result, Alba Infra Partners shall in no event be held liable in respect of any content published by third parties whatsoever.
You are hereby invited to read the terms and conditions governing third party websites you access after clicking on hypertext links displayed on the Website.

Link by third parties to this Website

Links redirecting to the Website are only allowed subject to the express prior written consent of Alba Infra Partners.

Assignment

Alba Infra Partners reserves the right to assign all or part of its rights and obligations under these Terms to any third party of its choice.

Severability

In the event any part of these Terms is found to be unenforceable or invalid by a competent court, such decision shall not invalidate or void the remaining provisions thereof.
In such a case, the Terms shall be deemed amended to the extent necessary to render them enforceable and valid while preserving their intent.

Electronic communications

In accordance with the provisions of Articles 1365 and subsequent of the French Civil Code, you acknowledge and agree that information exchanged between you and Alba Infra Partners in electronic format (notably by email) shall be deemed valid means of proof, equivalent to information in paper format.

Registered Users

As a Registered User, you are entitled to access the Investor Relations section of the Website. Please note that access to and use of the Investor Relations section is conditional upon your status as Registered User, which is discretionarily determined by Alba Infra Partners. In other words, from the moment you no longer qualify as Registered User, you must refrain from accessing (or trying to access) the Investor Relations section.
In any event, please note that the obligations imposed upon you, pursuant to the Terms, while you use the Website shall apply mutatis mutandis to you while you use the Investor Relations section as a Registered User and any reference to the Website shall be deemed to refer to the Investor Relations section, without prejudice to any special terms applying specifically to the Registered Users.
Subject to your strict compliance with the Terms and any special terms applying specifically to the Registered Users, Alba Infra Partners grants you a personal, worldwide, free of charge, non-assignable, non-sublicensable and revocable license to use the Investor Relations section. As a result, you shall use the Investor Relations section for your personal purposes only, excluding notably any commercial use.
For sake of clarity, please note that the Investor Relations section is operated by a third-party service provider: Intralinks, Inc. Thus, where you are willing to access the Investor Relations section, you are going to be redirected to Intralinks, Inc.’s portal in order to log in. Intralinks, Inc. will administer your login and password to the Investor Relations section.
In the event you forget your password, you may recover a new password by using the dedicated link on the Intralinks, Inc.’s portal. In any event, Alba Infra Partners invites you to read Intralinks, Inc.’s terms and conditions available on Intralinks, Inc.’s portal and requires that you comply with them prior to logging into the Investor Relations section.
As a Registered User, you shall bear sole responsibility for use of your login and password to the Investor Relations section.
You shall comply with the following obligations:

You commit to take all appropriate measures to ensure that your login and password to the Investor Relations section remain confidential, personal and safe, notably by refraining from sharing your login and password to the Investor Relations section with anyone else (including, without limitation, your colleagues and co-workers); and
if you become aware that your login and/or password to the Investor Relations section are lost, stolen and/or accessed by any unauthorized third-party, you shall inform Alba Infra Partners immediately by sending an email to Alba contact@alba-ip.com so that Alba Infra Partners can deactivate the access to the Investor Relations section linked to your login and password.

For sake of clarity, please note that any and all use of your login and password for accessing the Investor Relations section shall be deemed made by you, and you shall be liable accordingly unless You have expressly informed Alba Infra Partners in writing that your login and/or password have been lost, stolen and/or accessed by any unauthorized third party.
Unless Alba Infra Partners has not deactivated in due time your login and/or password to the Investor Relations section upon receipt of your notification, Alba Infra Partners shall not be held liable in any manner whatsoever for any incorrect or fraudulent use of your login and/or password as well as for any consequences resulting therefrom (including notably damages, losses, costs, expenses and loss of profit you or any third party may suffer).
In addition, you shall not use, share or communicate to any person, except as required by applicable law or any legal or regulatory authority, any information contained on the Investor Relations section which is designated by Alba Infra Partners as confidential or proprietary, or which you should reasonably consider to be confidential or proprietary considering all the circumstances surrounding the disclosure thereof. You shall use your best endeavours to prevent the communication or disclosure of the same.
In the event you do not comply with all or part of these Terms, and without prejudice to any other remedy it may have, Alba Infra Partners shall be entitled to suspend or revoke your right to access and use the Investor Relations section, either temporarily or definitively, as of right, immediately and without any indemnification, compensation or refund whatsoever being owed.
Alba Infra Partners’ liability shall not be incurred in the event the suspension or revocation of your rights to access the Investor Relations section results from a report by a third-party or a court order or regulatory injunction which eventually turns out to be groundless.
In the event Alba Infra Partners considers that the cause leading to the suspension or revocation of your right to access the Investor Relations section has been remedied, Alba Infra Partners may in its sole discretion decide to end such suspension or revocation but shall be under no obligation to do so.

Governing law and jurisdiction

Use of this Website is governed by French law. Any complaints or disputes relating to the Website or its use, shall be subject to the exclusive jurisdiction of the competent courts of Paris (France).

Cookie policy

About this cookie policy

This Cookie Policy explains what cookies are and how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to control the cookie preferences. For further information on how we use, store, and keep your personal data secure, see our Privacy Policy.
You can at any time change or withdraw your consent from the Cookie Declaration on our website
Learn more about who we are, how you can contact us, and how we process personal data in our Privacy Policy.

What are cookies?

Cookies are small text files that are used to store small pieces of information. They are stored on your device when the website is loaded on your browser. These cookies help us make the website function properly, make it more secure, provide better user experience, and understand how the website performs and to analyze what works and where it needs improvement.

How do we use cookies?

As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.
The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.

What types of cookies do we use?

Essential: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your account and add products to your basket, and checkout securely.
Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit, etc. These data help us understand and analyze how well the website performs and where it needs improvement.
Marketing: Our website displays advertisements. These cookies are used to personalize the advertisements that we show to you so that they are meaningful to you. These cookies also help us keep track of the efficiency of these ad campaigns.
The information stored in these cookies may also be used by the third-party ad providers to show you ads on other websites on the browser as well.
Functional: These are the cookies that help certain non-essential functionalities on our website. These functionalities include embedding content like videos or sharing content of the website on social media platforms.
Preferences: These cookies help us store your settings and browsing preferences like language preferences so that you have a better and efficient experience on future visits to the website.
The below list details the cookies used in our website.

How can I control the cookie preferences?

Should you decide to change your preferences later through your browsing session, you can click on the “Privacy & Cookie Policy” tab on your screen. This will display the consent notice again enabling you to change your preferences or withdraw your consent entirely.
In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. To find out more about how to manage and delete cookies, visit wikipedia.org, www.allaboutcookies.org.