Additional Regulatory Information

Additional Regulatory Information

The Chenavari Group (Chenavari) is committed to identifying and understanding potential and actual conflicts of interest that might occur in the course of its business. The Group considers the size, nature, scale and complexity of its organisation when identifying and mitigating of any potential conflicts of interest that may arise.

Chenavari is committed to treating its clients fairly and takes all appropriate steps to identify and manage conflicts of interest between Chenavari and its clients and relevant third parties. This includes conflicts of interest caused by the receipt of any inducement from third parties or its own remuneration and other incentives structures.

Chenavari takes all reasonable steps to manage these conflicts and where arrangements are insufficient to deal with a conflict, the nature and sources of the conflict will be disclosed to the client and a waiver will be requested. In the event a conflict is not manageable and there may be risks of damage to the Client, Chenavari will decline to act for the Client in connection with the proposed transaction.

Identification of Conflicts of Interest

Conflicts of interest are discussed at regular governance meetings and are monitored as part of the Groups’ Compliance Monitoring Programme. Chenavari maintains a Conflicts Register in order to record identified conflicts and ensure that they are being correctly managed. Each business area is also required to monitor its business and report any new actual or potential conflicts.

If at any time a conflict is identified that has not been included in the policy, or a material risk of damage to a client has been identified, Compliance is notified immediately, and the conflict is logged in the Conflicts of Interest Register for investigation or remedial action.

Analysis, Mitigation and Disclosure of Conflicts

The Group maintains and regularly updates a record of the types of transactions undertaken that may carry a material risk of damage to the interests of one or more clients, which has arisen or may arise, together with details of the mitigating actions in place to manage such conflicts.

It is the Firm’s responsibility to disclose actual or potential conflicts of interest only where it is not reasonably confident that the procedures and controls for managing the conflict or potential conflict will prevent the risk of damage to client interests.

The Compliance Department is responsible for the Conflicts policy and reviews the Groups policies and procedures to ensure Conflicts are being managed and mitigated. Conflicts are considered on an ongoing basis and any material conflicts are escalated accordingly. Records are retained for at least 5 years.

Chenavari will take all sufficient steps to obtain best execution for each of its clients in accordance with the applicable rules and as described herein, however, the Policy does not apply to non-MIFID financial instrument such as loans or physical commodities.
When executing an order on its client’s behalf, the Firm places significant reliance on its counterparties. Consequently, Chenavari does not guarantee that it will be able to achieve best execution in respect of every order.

Best Execution obligations will not apply where an order is carried out with or for an Eligible Counterparty, dealing takes place on a Request for Quote (“RFQ”) basis or when dealing with Professional clients (except in certain circumstances).

Best Execution Factors and Criteria

Each counterparty is selected based on the relative importance the Firm assigns to a variety of criteria including price, costs, speed, likelihood of execution and settlement, size, nature and any other relevant factor which the Firm considers of relevant importance.
The Firm will also focus on the quality of execution provided by counterparties and selects counterparties that provide the best result on a consistent basis by considering the above factors.

Although the Firm is obliged to deliver the best possible result when transmitting client orders in all MIFID financial instruments, a uniform procedure for Best Execution cannot be applied owing to differences in market structures and the different characteristics of each financial instrument. The application of any Best Execution obligations will therefore consider the different circumstances surrounding the execution of client orders for particular types of financial instruments, taking into account a variety of factors.

Execution venues

The Firm maintains a list of approved counterparties which it uses in respect of the various instruments in which it transmits orders. The lists of venues used is updated from time to time depending on the nature of any changes to the type of investments which the Firm manages and in the light of experience. From time to time and where appropriate, Chenavari may use execution venues that are not included on the list in order to be able to continue to meet its obligations to obtain the best possible results for its clients. Use of a non-approved counterparty is subject to approval of the Firm’s Compliance Department.
In certain circumstances, the Firm may deal directly with a counterparty or market maker in their principal capacity rather than a counterparty who is acting on an agency basis. The Firm may also occasionally also trade outside a regulated market or multilateral trading (“MTF”) facility.

Where an order is executed away from a regulated market or MTF, it will be considered an over-the-counter execution. Chenavari will, unless otherwise notified by the client, seek express consent via terms of business to with the counterparty to transact in this manner.

Prior Consent

Chenavari is required to obtain client’s prior consent to a number of aspects of the Firm’s Best Execution obligations. A Professional client will be deemed to have given consent to each of the above when the Firm undertakes advisory or discretionary portfolio management unless there is an instruction in writing to the contrary.

Chenavari will take all sufficient steps to ensure that it acts in a client’s best interests when an order is transmitted to another entity for execution. The Firm will act honestly, fairly and professionally in accordance with a client’s best interests when receiving and passing client orders for execution by a third party.

Third party payments and minor non-monetary benefits

The payment or receipt of inducements (e.g. fees, commissions, non-monetary benefits, etc.) to third parties is prohibited, unless certain conditions are met (i.e. best interests of the client, disclosure to client and client enhancement).

In the context of Best Execution this means that Execution Venues and counterparties are selected on the basis of a client’s best interests rather than because the counterparty provides other services and/or payments to the Firm, Chenavari will not receive any payment, remuneration, commission or non-monetary benefit from third parties, where the Firm charges more than one participant in a transaction, it will inform the client of the value of any benefits received by the Firm, and all hospitality provided to or received from investment firms and counterparties involved in providing Best Execution to Chenavari and its clients will constitute a ‘minor non-monetary benefit’ as described in the Conflicts of Interest Policy.

The Chenavari Group (Chenavari) has a Remuneration Policy that is appropriate to the size, legal structure, internal organisation and the nature, scope and complexity of its activities. Chenavari has established, implemented and maintains gender neutral Remuneration Practices in accordance with the requirements of the applicable Remuneration Codes under which it operates. The Policy also includes the integration of sustainability risks in Chenavari’s remuneration procedures, as required by the EU Sustainable Finance Disclosure Regulation (“SFDR”)

General

Chenavari’s remuneration practices must be consistent with, and promote sound and effective, risk management, be in line with the business strategy, objectives and long-term interests of Chenavari and any variable remuneration must not affect Chenavari’s ability to ensure a sound capital base. It should not encourage excessive risk taking and aims to address conflicts of interest.

Remuneration may include fixed salary, discretionary bonus, incentive plans, discretionary incentive and retention awards. For Partners, this may comprise monthly drawings and, where applicable, partnership profit allocation, deferred discretionary payments, deferred profit allocations.

Remuneration is subject to appropriate performance adjustment requirements. The input of Chenavari’s risk management, compliance, internal audit and human resources (“HR”) functions as well as relevant business units is sought in developing and applying Chenavari’s Remuneration Practices.

Chenavari carries out an annual assessment of staff’s performance based on quantitative criteria e.g. financial performance of the individual, staff member, business unit, and Chenavari) and qualitative criteria (e.g. compliance with policies and procedures). It may also include an assessment of whether the relevant individual member of staff has complied with Chenavari’s Responsible Investment Policy.

Fixed and Variable Remuneration

Chenavari aims to ensure that the fixed and variable components of total remuneration are appropriately balanced and that the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration, including the possibility of paying no variable remuneration component.

Eligibility to be considered for variable remuneration is entirely discretionary and is not guaranteed. Performance related remuneration may be subject to multi-year performance assessments, longer term performance targets and variable payment periods depending upon the role and jurisdiction of the staff member.

Discretionary Bonus Award Scheme

Chenavari operates a Discretionary Bonus Award Scheme and applies a range of measures to ensure Chenavari’s total variable remuneration does not affect Chenavari’s ability to ensure a sound capital base.

The Discretionary Bonus Award Scheme is applicable to staff members. Eligibility to be considered for such an award is entirely discretionary and is not guaranteed and the operation of the Discretionary Bonus Award Scheme or any award or payment under the scheme in one year will not confer the right to future participation or award or payment.

Discretionary Bonuses are awarded for the previous performance year, (1 January to 31 December). The award of any discretionary bonus is subject to any deferral, clawback, performance adjustment and forfeiture arrangements as are put in place from time to time by Chenavari.

Discretionary Bonuses for all eligible employees are awarded in accordance with financial and non-financial factors and are based on the performance and conduct of the employee, performance of the business unit concerned and the overall performance results of Chenavari for the relevant performance year.

Determination of pools of variable remuneration include adjustments for all types of current and future risks and the cost of the capital and liquidity required. The allocation of variable remuneration components within Chenavari takes into account all types of current and future risks. Total variable remuneration is generally reduced, including through malus or clawback arrangements, where the financial performance of Chenavari is subdued or negative.

Deferral and Forfeiture

Chenavari may defer certain Variable Remuneration awarded, where the award exceeds a certain threshold. Chenavari may adopt alternative deferral arrangements as it sees appropriate from time to time and the period of deferral applicable to any award will be determined by Chenavari with reference to the nature and cycle of the business and the risks and activities of the relevant staff member. Chenavari also permits deferred compensation to be invested in the funds it manages to promote alignment of interests.

Deferred payments will be cancelled and forfeited if, the member of staff is no longer in the employment of Chenavari, is no longer a partner, has been given notice of termination of employment or has given notice of termination of their employment or is under investigation and/or subject to disciplinary proceedings or if it is reasonably determined that they no longer meet or will continue to meet the required standards required by any applicable regulatory body in respect of the role they perform.

If the member of staff is under investigation in relation to any disciplinary matter at the date on which the remuneration would be paid, the payment date is suspended until the investigation and any associated disciplinary proceedings are completed. If the employee is not subject to a disciplinary sanction the remuneration that would have otherwise been payable will be provided at an appropriate later date, provided the employee has met all other requirements for payment of the remuneration in question. If the employee is subject to a disciplinary sanction, such payment is cancelled and forfeited, at Chenavari’s discretion.

Malus and Clawback

Chenavari applies malus (adjustment) and clawback (recovery) provisions to staff’s variable remuneration in accordance with the applicable regulatory Remuneration Code requirements.

Malus will apply to variable remuneration where staff may have participated in or were responsible for conduct which resulted in significant losses to Chenavari or relevant business unit, where the staff member failed to meet appropriate standards of fitness and propriety and where the staff member participated in or was responsible for conduct which resulted in a material failure of risk management at business unit or Group level.
Clawback will apply to variable remuneration where the staff member participated in or was responsible for conduct which resulted in significant losses to Chenavari, where the staff member failed to meet appropriate standards of fitness and propriety, where there may be cases of fraud or other conduct with intent, or severe negligence which lead to significant losses to Chenavari.

Control Functions

Chenavari aims to ensure that staff performing control functions are independent from the business units they oversee, have appropriate authority and are remunerated in accordance with the achievement of the objectives linked to their functions, independent of the performance of the business areas they control.

The remuneration of the senior officers in Chenavari’s Risk Management and Compliance Functions is directly overseen by the Executive Management.

Avoidance

Chenavari will not pay variable remuneration through financial vehicles or methods that facilitate non-compliance with any applicable Remuneration Code.
Staff are not permitted to use personal hedging strategies, or to take out insurance contracts, in respect of any variable compensation award or remuneration.

Equality and Diversity
Chenavari acknowledges that it has statutory duties in relation to equal pay and non-discrimination and is committed to complying with those duties in relation to this Policy and its general Remuneration Practices.

Chenavari Complaints Policy

Chenavari Credit Partners LLP  is committed at all levels to addressing and resolving complaints in a fair and efficient manner.
Please click here to access the Complaints Policy, as required by the UK Financial Conduct Authority DISP 1

Chenavari Investment Managers (Luxembourg) s.a.r.l Complaints Policy

Chenavari Investment Managers (Luxembourg) S.a r.l is committed at all levels to addressing and resolving complaints in a fair and efficient manner.

Please click here to access the AIFMD Complaints Policy, as set out in accordance with Regulation 16-07.

Chenavari Asset Management Complaints s.a.s Policy

in France, Chenavari Asset Management has designed an efficient and transparent procedure to promptly and reasonably address and resolve complaints filed by its clients or investors by implementing a system allowing fair and harmonised handling of complaints.

In accordance with Instruction n° 2012-07 of the Autorité des Marchés Financiers (AMF), a complaint is defined as the expression of the client’s dissatisfaction towards Chenavari Asset Management. It should be noted that a request for information, advice, clarification or service is not a claim.

Complaints are processed by Chenavari Asset Management free of charge.

Complaints should be sent by e-mail to the attention of the Responsible de la Conformité et Contrôle Interne at complaints@chenavari.com

Should you have invested in one of Chenavari funds upon advice of an intermediary that does not belong to the Chenavari group, it is recommended that you file your complaint directly with such intermediary.

Chenavari Asset Management maintains the utmost confidentiality while handling complaints and commits to:
– acknowledge reception of the complaint within a maximum 10 working days, unless a response has been provided before,
– provide a response within a maximum 2 months from the date the complaint has been sent unless specific duly justified circumstances arise between the date of reception and the date of response.

Clients or investors may submit a complaint in the official language or one of the official languages of the Member State in which the fund is marketed or the investment service provided.

Chenavari Asset Management commits to handle your complaint with care and diligence, however, should you not be satisfied with the response, you may file a complaint to the AMF Ombudsman free of charge.

The AMF Ombusman https://www.amf-france.org/fr/le-mediateur The Ombudsman – Autorité des Marchés Financiers
17, place de la Bourse75082 PARIS CEDEX 02

A mediation charter designed by the AMF is available on the website www.amf-france.org under the heading “The AMF Ombudsman”.

Conflicts of Interest Policy

The Chenavari Group (Chenavari) is committed to identifying and understanding potential and actual conflicts of interest that might occur in the course of its business. The Group considers the size, nature, scale and complexity of its organisation when identifying and mitigating of any potential conflicts of interest that may arise.

Chenavari is committed to treating its clients fairly and takes all appropriate steps to identify and manage conflicts of interest between Chenavari and its clients and relevant third parties. This includes conflicts of interest caused by the receipt of any inducement from third parties or its own remuneration and other incentives structures.

Chenavari takes all reasonable steps to manage these conflicts and where arrangements are insufficient to deal with a conflict, the nature and sources of the conflict will be disclosed to the client and a waiver will be requested. In the event a conflict is not manageable and there may be risks of damage to the Client, Chenavari will decline to act for the Client in connection with the proposed transaction.

Identification of Conflicts of Interest

Conflicts of interest are discussed at regular governance meetings and are monitored as part of the Groups’ Compliance Monitoring Programme. Chenavari maintains a Conflicts Register in order to record identified conflicts and ensure that they are being correctly managed. Each business area is also required to monitor its business and report any new actual or potential conflicts.

If at any time a conflict is identified that has not been included in the policy, or a material risk of damage to a client has been identified, Compliance is notified immediately, and the conflict is logged in the Conflicts of Interest Register for investigation or remedial action.

Analysis, Mitigation and Disclosure of Conflicts

The Group maintains and regularly updates a record of the types of transactions undertaken that may carry a material risk of damage to the interests of one or more clients, which has arisen or may arise, together with details of the mitigating actions in place to manage such conflicts.

It is the Firm’s responsibility to disclose actual or potential conflicts of interest only where it is not reasonably confident that the procedures and controls for managing the conflict or potential conflict will prevent the risk of damage to client interests.

The Compliance Department is responsible for the Conflicts policy and reviews the Groups policies and procedures to ensure Conflicts are being managed and mitigated. Conflicts are considered on an ongoing basis and any material conflicts are escalated accordingly. Records are retained for at least 5 years.

Best Execution Policy

Chenavari will take all sufficient steps to obtain best execution for each of its clients in accordance with the applicable rules and as described herein, however, the Policy does not apply to non-MIFID financial instrument such as loans or physical commodities.
When executing an order on its client’s behalf, the Firm places significant reliance on its counterparties. Consequently, Chenavari does not guarantee that it will be able to achieve best execution in respect of every order.

Best Execution obligations will not apply where an order is carried out with or for an Eligible Counterparty, dealing takes place on a Request for Quote (“RFQ”) basis or when dealing with Professional clients (except in certain circumstances).

Best Execution Factors and Criteria

Each counterparty is selected based on the relative importance the Firm assigns to a variety of criteria including price, costs, speed, likelihood of execution and settlement, size, nature and any other relevant factor which the Firm considers of relevant importance.
The Firm will also focus on the quality of execution provided by counterparties and selects counterparties that provide the best result on a consistent basis by considering the above factors.

Although the Firm is obliged to deliver the best possible result when transmitting client orders in all MIFID financial instruments, a uniform procedure for Best Execution cannot be applied owing to differences in market structures and the different characteristics of each financial instrument. The application of any Best Execution obligations will therefore consider the different circumstances surrounding the execution of client orders for particular types of financial instruments, taking into account a variety of factors.

Execution venues

The Firm maintains a list of approved counterparties which it uses in respect of the various instruments in which it transmits orders. The lists of venues used is updated from time to time depending on the nature of any changes to the type of investments which the Firm manages and in the light of experience. From time to time and where appropriate, Chenavari may use execution venues that are not included on the list in order to be able to continue to meet its obligations to obtain the best possible results for its clients. Use of a non-approved counterparty is subject to approval of the Firm’s Compliance Department.
In certain circumstances, the Firm may deal directly with a counterparty or market maker in their principal capacity rather than a counterparty who is acting on an agency basis. The Firm may also occasionally also trade outside a regulated market or multilateral trading (“MTF”) facility.

Where an order is executed away from a regulated market or MTF, it will be considered an over-the-counter execution. Chenavari will, unless otherwise notified by the client, seek express consent via terms of business to with the counterparty to transact in this manner.

Prior Consent

Chenavari is required to obtain client’s prior consent to a number of aspects of the Firm’s Best Execution obligations. A Professional client will be deemed to have given consent to each of the above when the Firm undertakes advisory or discretionary portfolio management unless there is an instruction in writing to the contrary.

Chenavari will take all sufficient steps to ensure that it acts in a client’s best interests when an order is transmitted to another entity for execution. The Firm will act honestly, fairly and professionally in accordance with a client’s best interests when receiving and passing client orders for execution by a third party.

Third party payments and minor non-monetary benefits

The payment or receipt of inducements (e.g. fees, commissions, non-monetary benefits, etc.) to third parties is prohibited, unless certain conditions are met (i.e. best interests of the client, disclosure to client and client enhancement).

In the context of Best Execution this means that Execution Venues and counterparties are selected on the basis of a client’s best interests rather than because the counterparty provides other services and/or payments to the Firm, Chenavari will not receive any payment, remuneration, commission or non-monetary benefit from third parties, where the Firm charges more than one participant in a transaction, it will inform the client of the value of any benefits received by the Firm, and all hospitality provided to or received from investment firms and counterparties involved in providing Best Execution to Chenavari and its clients will constitute a ‘minor non-monetary benefit’ as described in the Conflicts of Interest Policy.

Remuneration Policy

The Chenavari Group (Chenavari) has a Remuneration Policy that is appropriate to the size, legal structure, internal organisation and the nature, scope and complexity of its activities. Chenavari has established, implemented and maintains gender neutral Remuneration Practices in accordance with the requirements of the applicable Remuneration Codes under which it operates. The Policy also includes the integration of sustainability risks in Chenavari’s remuneration procedures, as required by the EU Sustainable Finance Disclosure Regulation (“SFDR”)

General

Chenavari’s remuneration practices must be consistent with, and promote sound and effective, risk management, be in line with the business strategy, objectives and long-term interests of Chenavari and any variable remuneration must not affect Chenavari’s ability to ensure a sound capital base. It should not encourage excessive risk taking and aims to address conflicts of interest.

Remuneration may include fixed salary, discretionary bonus, incentive plans, discretionary incentive and retention awards. For Partners, this may comprise monthly drawings and, where applicable, partnership profit allocation, deferred discretionary payments, deferred profit allocations.

Remuneration is subject to appropriate performance adjustment requirements. The input of Chenavari’s risk management, compliance, internal audit and human resources (“HR”) functions as well as relevant business units is sought in developing and applying Chenavari’s Remuneration Practices.

Chenavari carries out an annual assessment of staff’s performance based on quantitative criteria e.g. financial performance of the individual, staff member, business unit, and Chenavari) and qualitative criteria (e.g. compliance with policies and procedures). It may also include an assessment of whether the relevant individual member of staff has complied with Chenavari’s Responsible Investment Policy.

Fixed and Variable Remuneration

Chenavari aims to ensure that the fixed and variable components of total remuneration are appropriately balanced and that the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration, including the possibility of paying no variable remuneration component.

Eligibility to be considered for variable remuneration is entirely discretionary and is not guaranteed. Performance related remuneration may be subject to multi-year performance assessments, longer term performance targets and variable payment periods depending upon the role and jurisdiction of the staff member.

Discretionary Bonus Award Scheme

Chenavari operates a Discretionary Bonus Award Scheme and applies a range of measures to ensure Chenavari’s total variable remuneration does not affect Chenavari’s ability to ensure a sound capital base.

The Discretionary Bonus Award Scheme is applicable to staff members. Eligibility to be considered for such an award is entirely discretionary and is not guaranteed and the operation of the Discretionary Bonus Award Scheme or any award or payment under the scheme in one year will not confer the right to future participation or award or payment.

Discretionary Bonuses are awarded for the previous performance year, (1 January to 31 December). The award of any discretionary bonus is subject to any deferral, clawback, performance adjustment and forfeiture arrangements as are put in place from time to time by Chenavari.

Discretionary Bonuses for all eligible employees are awarded in accordance with financial and non-financial factors and are based on the performance and conduct of the employee, performance of the business unit concerned and the overall performance results of Chenavari for the relevant performance year.

Determination of pools of variable remuneration include adjustments for all types of current and future risks and the cost of the capital and liquidity required. The allocation of variable remuneration components within Chenavari takes into account all types of current and future risks. Total variable remuneration is generally reduced, including through malus or clawback arrangements, where the financial performance of Chenavari is subdued or negative.

Deferral and Forfeiture

Chenavari may defer certain Variable Remuneration awarded, where the award exceeds a certain threshold. Chenavari may adopt alternative deferral arrangements as it sees appropriate from time to time and the period of deferral applicable to any award will be determined by Chenavari with reference to the nature and cycle of the business and the risks and activities of the relevant staff member. Chenavari also permits deferred compensation to be invested in the funds it manages to promote alignment of interests.

Deferred payments will be cancelled and forfeited if, the member of staff is no longer in the employment of Chenavari, is no longer a partner, has been given notice of termination of employment or has given notice of termination of their employment or is under investigation and/or subject to disciplinary proceedings or if it is reasonably determined that they no longer meet or will continue to meet the required standards required by any applicable regulatory body in respect of the role they perform.

If the member of staff is under investigation in relation to any disciplinary matter at the date on which the remuneration would be paid, the payment date is suspended until the investigation and any associated disciplinary proceedings are completed. If the employee is not subject to a disciplinary sanction the remuneration that would have otherwise been payable will be provided at an appropriate later date, provided the employee has met all other requirements for payment of the remuneration in question. If the employee is subject to a disciplinary sanction, such payment is cancelled and forfeited, at Chenavari’s discretion.

Malus and Clawback

Chenavari applies malus (adjustment) and clawback (recovery) provisions to staff’s variable remuneration in accordance with the applicable regulatory Remuneration Code requirements.

Malus will apply to variable remuneration where staff may have participated in or were responsible for conduct which resulted in significant losses to Chenavari or relevant business unit, where the staff member failed to meet appropriate standards of fitness and propriety and where the staff member participated in or was responsible for conduct which resulted in a material failure of risk management at business unit or Group level.
Clawback will apply to variable remuneration where the staff member participated in or was responsible for conduct which resulted in significant losses to Chenavari, where the staff member failed to meet appropriate standards of fitness and propriety, where there may be cases of fraud or other conduct with intent, or severe negligence which lead to significant losses to Chenavari.

Control Functions

Chenavari aims to ensure that staff performing control functions are independent from the business units they oversee, have appropriate authority and are remunerated in accordance with the achievement of the objectives linked to their functions, independent of the performance of the business areas they control.

The remuneration of the senior officers in Chenavari’s Risk Management and Compliance Functions is directly overseen by the Executive Management.

Avoidance

Chenavari will not pay variable remuneration through financial vehicles or methods that facilitate non-compliance with any applicable Remuneration Code.
Staff are not permitted to use personal hedging strategies, or to take out insurance contracts, in respect of any variable compensation award or remuneration.

Equality and Diversity
Chenavari acknowledges that it has statutory duties in relation to equal pay and non-discrimination and is committed to complying with those duties in relation to this Policy and its general Remuneration Practices.

COMPLAINTS

Chenavari Complaints Policy

Chenavari Credit Partners LLP  is committed at all levels to addressing and resolving complaints in a fair and efficient manner.
Please click here to access the Complaints Policy, as required by the UK Financial Conduct Authority DISP 1

 

Chenavari Investment Managers (Luxembourg) s.a.r.l Complaints Policy

Chenavari Investment Managers (Luxembourg) S.a r.l is committed at all levels to addressing and resolving complaints in a fair and efficient manner.

Please click here to access the AIFMD Complaints Policy, as set out in accordance with Regulation 16-07.

Chenavari Asset Management Complaints s.a.s Policy

in France, Chenavari Asset Management has designed an efficient and transparent procedure to promptly and reasonably address and resolve complaints filed by its clients or investors by implementing a system allowing fair and harmonised handling of complaints.

In accordance with Instruction n° 2012-07 of the Autorité des Marchés Financiers (AMF), a complaint is defined as the expression of the client’s dissatisfaction towards Chenavari Asset Management. It should be noted that a request for information, advice, clarification or service is not a claim.

Complaints are processed by Chenavari Asset Management free of charge.

Complaints should be sent by e-mail to the attention of the Responsible de la Conformité et Contrôle Interne at complaints@chenavari.com.

Should you have invested in one of Chenavari funds upon advice of an intermediary that does not belong to the Chenavari group, it is recommended that you file your complaint directly with such intermediary.

Chenavari Asset Management maintains the utmost confidentiality while handling complaints and commits to:
– acknowledge reception of the complaint within a maximum 10 working days, unless a response has been provided before,
– provide a response within a maximum 2 months from the date the complaint has been sent unless specific duly justified circumstances arise between the date of reception and the date of response.

Clients or investors may submit a complaint in the official language or one of the official languages of the Member State in which the fund is marketed or the investment service provided.

Chenavari Asset Management commits to handle your complaint with care and diligence, however, should you not be satisfied with the response, you may file a complaint to the AMF Ombudsman free of charge.

The AMF Ombusman https://www.amf-france.org/fr/le-mediateur The Ombudsman – Autorité des Marchés Financiers
17, place de la Bourse75082 PARIS CEDEX 02

A mediation charter designed by the AMF is available on the website www.amf-france.org under the heading “The AMF Ombudsman”.

Please click here to access the French version of Chenavari Asset Management Complaints Policy.

 

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Alternative Fixed Income
Specialists in European Credit