Company name:
PAI Partners SAS

Headquarters:
232 rue de Rivoli
75001 Paris- France

Share capital: €161.200
RCS: RCS PARIS 443 837 331
SIRET: 443 837 331 00026
APE Code: 6630Z
Tel: +33 1 43 16 63 00
Fax: +33 1 43 16 63 89
E-mail: pai.paris@paipartners.com

Company name:
PAI Partners S.à r.l.

Headquarters:
43-45 allée Scheffer – L-2520 Luxembourg
Grand Duchy of Luxembourg

Share capital: €500.000
RCS
:  B136689
Tel: +352 26 26 97 71 78
Fax: +352 26 26 97 30 00
E-mail: pai.luxembourg@paipartners.lu

PAI Partners SAS is a fund management company approved and regulated by the AMF in France (approval number GP-06000052). PAI Partners SAS was approved as a fund management company for private equity on December 22, 2006 and as an Alternative Investment Fund Manager on August 1, 2013 according to Directive 2011/61/UE.

PAI Partners SAS has obtained a passport for the establishment of a branch in United Kingdom (FCA Firm Reference Number: 231885).

PAI Partners S.à r.l. is a fund management company approved and regulated by the CSSF in Luxembourg. PAI Partners S.à r.l.was approved as an Alternative Investment Fund Manager on June 25, 2014 under the number N. A00000625.

Complaints Handling Procedure

PAI Partners SAS has established and maintains an effective procedure for the reasonable and prompt handling of complaints.

Should you have any issue with our services please do not hesitate to contact our Complaints Handling Officer, in English or French, through the addresses below at your convenience, with the reference “Complaint”:

Mail at:
PAI Partners SAS
Att. Complaints Handling Officer
232 rue de Rivoli
75001 Paris
Email at: compliance@paipartners.com

Please make sure that the following information are provided to ensure a prompt handling of your complaint:
– Your identity and contact details;
– Reason(s) of the complaint;
– Where relevant, copies of any documentation supporting your complaint.

You will receive an acknowledgement of receipt in writing within (10) ten business days, unless the answer itself is provided to you within this period.

Should your complaint request further investigation, a response will be sent to you within (2) two months of the receipt. In case we would not be in capacity to answer you within this delay we will provide you details with regards to when the response will be provided.

Finally, should the answer provided not be satisfying to you, please note that an out-of-court complaint resolution procedure exists with the Autorité des marches financiers.

Médiateur de l’AMF
Autorité des Marchés Financiers
17, place de la Bourse
75082 PARIS CEDEX 02

An application form for mediation is also available on the website of the AMF (www.amf-france.org). 

Complaints Handling Procedure

PAI Partners S.à r.l. has established and maintains an effective procedure for the reasonable and prompt handling of complaints.

Should you have any issue with our services please do not hesitate to contact our Complaints Handling Officer, in English or French, through the addresses below at your convenience, with the reference “Complaint”:

Mail at:
PAI Partners S.à r.l.
Att. Complaints Handling Officer
43-45 allée Scheffer
L-2520 Luxembourg
Email at: compliance@paipartners.lu

Please make sure that the following information are provided to ensure a prompt handling of your complaint:
– Your identity and contact details;
– Reason(s) of the complaint;
– Where relevant, copies of any documentation supporting your complaint.

You will receive an acknowledgement of receipt in writing within (10) ten business days, unless the answer itself is provided to you within this period.

Should your complaint request further investigation, a response will be sent to you within (1) one month of the receipt. In case we would not be in capacity to answer you within this delay we will provide you details with regards to when the response will be provided.

Finally, should the answer provided not be satisfying to you, please note that an out-of-court complaint resolution procedure exists with the Commission de Surveillance du Secteur Financier.

 

 Voting Rights Policy

PAI Partners SAS believes that professional corporate governance standards are an essential part of its reputation and management experience. Thus, voting at assembly general meetings is a key component of the ongoing dialogue with companies in which PAI Partners SAS invests on behalf of the managed funds and their investors and forms an integral part of PAI’s investment process. PAI Partners SAS  has set up a Voting Rights Policy, is committed to ensure consistent exercise of voting rights associated with shares held in the funds and exercises the voting rights with the sole view of preserving the interest of its investors.

 Voting Rights Policy

PAI Partners S.à r.l. believes that professional corporate governance standards are an essential part of its reputation and management experience. Thus, voting at assembly general meetings is a key component of the ongoing dialogue with companies in which PAI Partners S.à r.l. invests on behalf of the managed funds and their investors and forms an integral part of PAI’s investment process. PAI Partners S.à r.l. has set up a Voting Rights Policy, is committed to ensure consistent exercise of voting rights associated with shares held in the funds and exercises the voting rights with the sole view of preserving the interest of its investors.

Conflicts of Interest management and prevention

PAI Partners SAS maintains and operates effective organizational and administrative arrangements with a view to taking all reasonable steps designed to identify, prevent, manage and monitor conflicts of interest in order to prevent them from adversely affecting the interests of the funds and/or the investors.

 The company takes all reasonable steps to identify conflicts of interest that arise in the course of its activities between (i) the firm, including its managers, employees or any person directly or indirectly linked to PAI Partners SAS by control and the funds (managed by PAI Partners SAS or its affiliates) or their investors, (ii) one fund or its unitholders and another fund or its unitholders, (iii) a fund or its unitholders and another client of PAI Partners SAS, and (iv) two clients.

 The general principles applied to prevent conflicts of interest are integrity, fairness, impartiality and the primacy of the investors’ interests. These principles occupy a prominent place among the company’s ethical rules.

All staff members are required to comply with ethical rules and receive adequate information, training and guidelines to this effect.

 PAI Partners SAS has set up the relevant procedure and policy to which all staff members must adhere, identifies and updates the main categories of situations where potential conflicts of interest may materialize and identifies, records, documents and handle actual conflicts of interest. Where organizational arrangements made by the company to identify, prevent, manage and monitor conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to investors’ interests will be prevented, the company clearly discloses in a durable medium the general nature or sources of conflict to the concerned parties giving sufficient information with respect to the service/transaction in the context of which the conflict arises. The efficiency and adequacy of the overall conflicts of interest prevention and management framework is reviewed and updated at least annually.

Conflicts of Interest management and prevention

PAI Partners S.à r.l.  maintains and operates effective organizational and administrative arrangements with a view to taking all reasonable steps designed to identify, prevent, manage and monitor conflicts of interest in order to prevent them from adversely affecting the interests of the funds and/or the investors.

The company takes all reasonable steps to identify conflicts of interest that arise in the course of its activities between (i) the firm, including its managers, employees or any person directly or indirectly linked to PAI Partners S.à r.l.  by control and the funds (managed by PAI Partners S.à r.l.  or its affiliates) or their investors, (ii) one fund or its unitholders and another fund or its unitholders, (iii) a fund or its unitholders and another client of PAI Partners S.à r.l. , and (iv) two clients.

The general principles applied to prevent conflicts of interest are integrity, fairness, impartiality and the primacy of the investors’ interests. These principles occupy a prominent place among the company’s ethical rules.

All staff members are required to comply with ethical rules and receive adequate information, training and guidelines to this effect.

PAI Partners S.à r.l. has set up the relevant procedure and policy to which all staff members must adhere, identifies and updates the main categories of situations where potential conflicts of interest may materialize and identifies, records, documents and handle actual conflicts of interest. Where organizational arrangements made by the company to identify, prevent, manage and monitor conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to investors’ interests will be prevented, the company clearly discloses in a durable medium the general nature or sources of conflict to the concerned parties giving sufficient information with respect to the service/transaction in the context of which the conflict arises. The efficiency and adequacy of the overall conflicts of interest prevention and management framework is reviewed and updated at least annually.