Terms of Use

1. Presentation of the site  

In accordance with the provisions of articles 6-III and 19 of law no. 2004-575 of 21 June 2004 known as L.C.E.N. (Loi pour la Confiance dans l’économie numérique – Law for Confidence in the Digital Economy), we hereby apprise the axio.fr site’s users and visitors of the following information: 

Mandatory legal information

Owner’s details: company 
Prefix: SAS 
Company name: AXIO
Address: 39 Boulevard Malesherbes, 75008 Paris 
Tel.: 01.40.60.43.80 
With share capital of €300,000 
SIRET (business registration) number: 800.014.664.00034 Trade & Companies Register: 800.014.664 
Intra-community VAT number: FR 67800014664 
E-mail address: contact@axio.fr 

The site’s creator is Nobilito
Illustrations : Istock 
The Publication Manager is Laurent Tesson 
E-mail the Publication Manager at contact@axio.fr 

The Publication Manager is a natural person 
The Webmaster is Laurent Tesson 
E-mail the Webmaster at contact@axio.fr 
The site’s hosting company is OVH,  2 Rue Kellermann, 59100 Roubaix 

3. ESG policy 

Preamble 

AXIO is a company that its founders wished to build on strong values. Entrepreneurial values, fairness values, but also corporate social responsibility values. 

These foundations are embodied by the etymology of the name chosen for the structure: AXIO, from Ancient Greek – ἀξία – which means “value”. 

Beyond the ethics applied by AXIO, the founders share a profound conviction that the progress made in matters of governance structuring, human & social management and the culture of respect for the environment are important factors for improving the performance and increasing the value of SMEs. 

AXIO considers that supporting the improvement process of its affiliates on these important issues is an integral part of its management mandate. 

AXIO has devised an analytical grid of companies based on ESG criteria, which is used front each investment to assess the risks, incorporate them into investment decisions and lay down priority areas for focusing improvement efforts in agreement with the company director. 

• Environment 

Axio takes a keen interest in the environmental impact of companies and in their ability to offer products and services that address environmental challenges. Environmental issues may include the treatment of carbon emissions, pollution, waste and the use of water at the level of companies. 

• Social 

Axio takes a keen interest in the impact of companies on all their stakeholders (suppliers, staff, consumers) and the increasingly demanding requirements of investors in matters of social responsibility. Social issues may include all types of abuse in matters of employment, staff turnover indicators, diversity, health and safety in the workplace, income distribution, and product safety. 

• Governance 

Axio is mindful of the value added by companies that encourage ethics in matters of governance. Governance issues may include any tendency to commit fraud and bribery, the involvement of governments and the impact on company management, the independence of the board of directors, the remuneration package of company officers, and anticompetitive practices. 

Policy 

  In accordance with ’article L.533-22-1 of the Monetary and Financial Code, Axio must inform investor of how ESG criteria are factored into the management process. Axio is by its very nature closely involved in the companies in which the funds are invested. Axio’s proximity to such companies enables equity investment managers and business development officers to be closely involved with each company they monitor, in particular through company visits and frequent meetings with their senior managers. Through their personal sensitivity, the equity investment managers are kept informed of non-financial issues – which are commonly categorized on the basis of three notions, namely Environmental, Social and Governance (ESG). The monitoring of these issues is not yet systematically formalized in the investment process and its follow-up. However, our interest in management and in our investors mobilizes us to monitor the related risks. 

Commitments vis-à-vis our investors 

We undertake to forge enduring relationships with our investors, promoting the best alignment of interests between them and the management team and the greatest degree of transparency. 

1. When assessing investments, we undertake to systematically assess “ESG” (environmental, social/societal and governance) issues in an appropriate manner according to the size of the targeted company. 

2. We fulfil all applicable obligations in matters of the fight against money laundering and the financing of terrorism. When acquiring and disposing of a company, we make sure that all the interested parties meet their obligations and comply with applicable laws regarding the fight against money laundering and the financing of terrorism 

3. To avert potential conflicts of interest, we have a conflicts of interest management and prevention procedure complying with the recommendations of France Invest as reviewed by the French Financial Markets Authority. In particular it specifies priority rules for co-investments and additional investments. 

4. The main members of Axio’s management team undertake to invest systematically in each of the managed funds. This practice reinforces the alignment of interests with the investors and senior managers of the equity investments and contributes to the stability of the management team. 

5. We regularly provide our investors with financial and non-financial information, through our half-yearly reports, briefings with the funds, annual meetings between our investors and the senior managers of our equity investments, and the various advisory boards attended by our 

  

Commitment vis-à-vis our affiliated companies 

  We undertake to be active partners in our equity investments, fostering a relationship of trust based on respect for people. In this respect, we consider that financial performance goes hand in hand with the adoption of best ESG practices. 

1. We make sure that all our equity investments comply with the standards and regulations that apply to them, particularly in environmental matters. 

2. Our commitment alongside the senior managers of our equity investments stands the test of time (5 years or more) in order to implement the drivers of growth jointly identified with them.

3. The main capital of our equity investments is human. We encourage our equity investments to progress towards better social practices and associate their staff with the fruits of the company’s development. 

Scope 

In accordance with the requirements of article 321-40 of the RGAMF (General Regulation of the Financial Markets Authority), Axio has established an effective and transparent procedure for the reasonable and swift processing of complaints lodged by the management company’s current or potential customers. A complaint is a written or oral statement recording the dissatisfaction of a business or private customer with the asset management company. A request for information, advice, clarification or service is not a complaint. 

Complaints handling process 

 Complaints can be sent to Axio at 39 Boulevard Malesherbes, 75008 Paris, France. The management company will acknowledge receipt of the complaint within ten working days, unless the response itself is sent to the customer within that deadline. Barring particular and duly justified circumstances, it will send the customer a response within two months. In the event of persistent disagreement, the customer may contact a mediator, including the AMF mediator. The latter’s contact details are as follows: Autorité des Marchés Financiers Mrs Marielle Cohen-Branche, Mediator of the AMF, 17 place de la Bourse, 75082 Paris Cedex 02. The AMF mediation request form and the mediation charter are available at http://www.amf-france.org Nouvelle fenêtre 

Personal data management 

 Regarding the handling of complaints received on the grounds of the aforementioned regulation, Axio collects the personal details of a data subject such as the identity of the person making the complaint, the person’s contact details and the subject or context of the complaint inasmuch as the latter refer to the personal details of the data subject such as the latter’s economic situation. Failure to provide any of the necessary personal data may totally or partially deprive the data subject of the benefit of regulatory requirements in matters of complaints handling. The data controller in this respect is Axio, represented by its Chair, who can be contacted using the contact details provided in this document. The data is retained for at least five years, pursuant to regulatory requirements. Persons lodging a complaint are informed that they can exercise their right of access, rectification, erasure, restriction of processing and objection to the processing of their data in a letter sent using the contact details provided in this document, and their right to lodge a complaint with a supervisory authority. 

For more information, read 2023 Report on the Energy – Climate Law, Article 29

4. Prevention and management of conflicts of interest 

Scope of the Policy 

In accordance with articles 321-46 et seq of the General Regulation of the Financial Markets Authority, this procedure sets out to define the measures put in place by Axio to prevent, manage and deal with situations of conflicts of interest arising in the course of its business: 

• between Axio and its business or private customers; or 
• between one or more Axio employees and the business or private customers of the asset management company; or 
• between two or more business or private customers of Axio. 

Are deemed Axio customers any investors purchasing units in a fund managed by Axio. This procedure applies to all Axio staff (salaried employees, temporary staff, trainees and more generally anyone on secondment and under the authority of the asset management company). 

Identification of conflicts of interest 

In the context of Axio’s activities, several situations may create conflicts of interest that could be detrimental to the customer’s interests, as defined in article 321-47 of the General Regulation of the Financial Markets Authority. There are three kinds of potential conflicts of interest: 

• conflicts of interest involving several investment vehicles managed or recommended by Axio; 
• conflicts of interest involving Axio and managed or recommended investment vehicles; 
• conflicts of interest involving Axio staff. 

Conflicts of interest may concern : 

• financial management: equity of holders, transaction between portfolios; 
• direct or indirect remuneration paid or received: transparency of information provided to holders, the choice of brokers, advantages, etc. 
• the organization of Axio: segregation of duties, remuneration of staff; 
• proprietary trading by Axio, its senior managers and employees; 
• the primacy of the customer’s interests. 

Axio Capital takes all appropriate measures to identify the sources of potential conflicts of interest. 

  

Prevention of conflicts of interest 

Axio is an entrepreneurial and independent asset management company whose business is third-party fund management. Its proprietary fund management business is limited to the management company’s financial investments. The prevention of conflicts of interest in Axio draws both on organizational measures and on procedures and audits. 

  

Organizational measures 

• Segregation of duties 

In order to guarantee the interests of customers, all decisions are made independently and Axio and its staff see to the equal treatment of them. Compliance checking and internal control duties are totally independent because they are outsourced and they permanently monitor the company’s activities in order to ensure that internal control procedures are appropriate. 

• Circulation, exchanges and protection of information 

The IT system put in place with independent networks between teams, with restricted access depending on staff, limits clearances solely to those concerned by certain subjects. Barriers to the circulation of information designed to prevent the circulation of confidential or inside information are in place to separate activities liable to generate conflicts of interest (activities that are sources of non-public information or having conflicts of interest between them). Moreover, specific operating procedures manage the circulation of confidential or inside information and remind staff included on lists of holders of inside or confidential information of their duty of discretion and non-intervention with regard to such information (see the collection of procedures, market abuse and personal transaction procedures). 

  

Procedures and controls 

Adopted measures and controls are adapted in matters of prevention and management of conflicts of interest and inter alia include the following measures. 

• An internal management of conflicts of interest policy including instructions that staff must follow in order to identify, prevent and manage conflicts of interest 

The ethical regulation of companies intervening in the private equity of AFG and AFIC (two French associations accredited to represent asset management companies), supplemented by numerous targeted enforcement procedures, mitigate the risk that Axio Capital staff profit from information they hold at the expense of customers or act according to interests that may be contrary to those of customers (procedure raising staff awareness of ethical rules, procedures governing personal transactions, gifts policy, market abuse procedure, etc.). 

  

Management of conflicts of interest 

Treatment of situations of potential or actual conflicts of interest Any member of Axio staff observing a situation of potential or actual conflicts of interest must immediately so inform the Compliance and Internal Control Officer. The Compliance and Internal Control Officer must then assess the situation and tell the member of staff concerned of what conduct to adopt. 

  

Register of conflicts of interest 

In accordance with the provisions of article 321-50 of the General Regulation of the Financial Markets Authority, Axio has put in place a register recording the activities exercised by the asset management company or on its own account for which a conflict of interests presenting an appreciable risk of harming the interests of one or more of its customers has taken place or is likely to take place. The register lists all potential or actual conflicts of interest and the measures for treating the conflicts of interest that were taken. 

  

Customer information 

When a situation of a potential conflict of interests is identified and the measures taken by the management company do not suffice to guarantee with reasonable certainty that the risk of harming the interests of customers will be averted, the senior managers of the management company are informed at the earliest opportunity so that they can take all appropriate measures to guarantee that the asset management company will act in all cases in the best interests of the alternative investment funds and its unitholders. Similarly, if Management considers, on the recommendation of the Compliance and Internal Control Officer, that a conflict of interests has not been resolved, the affected unitholders or customers will be informed by Axio in a durable medium. 

5. Voting policy 

Scope of the voting policy 

  In accordance with the requirements of articles 314-100 et seq of the General Regulation of the Financial Markets Authority, Axio has drawn up a voting policy, updated as and whenever necessary, that sets out the conditions under which it intends to exercise the voting rights attached to the securities held by the fund it manages. 

  

Organization of Axio for exercising voting rights 

Laurent Tesson and Florian de Gouvion Saint-Cyr are responsible for appraising and assessing the resolutions put to the vote. They are in a position to decide what votes to exercise. 

  

Voting criteria 

Axio exercises voting rights for the annual general meetings of the companies in which it is a shareholder, with due regard for current regulations and safeguarding the interests of the unitholders. Axio may refrain from exercising its voting right if the shareholding threshold for the portfolios it manages is below 5% of the capital and if the portfolios do not hold at least one million euros. Axio will assess on a case-by-case basis the resolutions submitted to the annual general meetings, in particular: 

1. a) Decisions entailing a modification of the articles of association; 

2. b) Approval of the accounts and appropriation of profit or treatment of loss; 

3. c) Appointment and dismissal of the company’s bodies; 

4. d) So-called regulated agreements; 

5. e) Equity securities issue and buyback programmes; 

6. f) The appointment of statutory auditors; 

7. g) Any other type of specific resolution that the asset management company wishes to identify; 

  

Identification, prevention and management of conflicts of interest 

Axio has put in place a conflicts of interest prevention and management procedure. 

  

Common mode for exercising voting rights 

On a case-by-case basis, Axio votes by attending annual general meetings, voting by proxy or by postal vote. 

  

Information 

The voting policy is provided free of charge to fund unitholders who so request. In accordance with article 314-101 of the General Regulation of the Financial Markets Authority, at the request of the AMF, abstentions or votes cast on each resolution and the reasons for such votes or abstentions are disclosed to it. Furthermore, Axio provides fund unitholders who so request free information on the management company’s exercising of voting rights on each resolution presented to the annual general meeting of an issuer, whenever the proportionate share of securities held by the fund managed by the management company reaches the shareholding threshold specified in this document. Furthermore, within four months of the end of its financial year Axio draws up a report on the exercise of its voting rights in the past year, where necessary.