Legal and regulatory information
Director of publication: Gautier Delabrousse-Mayoux
Publisher: This site is produced by Iroko, a simplified joint-stock company (société par actions simplifiée) with share capital of €643,081.60, registered under SIRET number 88336211300010.
Address: Iroko, 4 rue de la Pompe, 75016 Paris.
Registered office: Iroko, 4 rue de la Pompe, 75016 Paris.
Approvals: Iroko is authorised by the French Financial Markets Authority (Autorité des Marchés Financiers – AMF) as a portfolio management company subject to Directive 2011/61/EU (the “AIFM Directive”), authorised to manage AIFs as well as to manage portfolios on behalf of third parties within the meaning of Directive 2014/65/EU, under number GP-20000014 dated 8 June 2020. Autorité des Marchés Financiers, 17 Place de la Bourse, 75082 Paris Cedex 2.
Iroko is also registered with ORIAS under number 23003024, for the following ancillary activities:
- insurance brokerage, and
- non-exclusive agent in banking operations and payment services via CA CONSUMER FINANCE – CACF (SOFINCO-FINAREF).
Customer service: contact@iroko.eu – +33 1 76 44 17 49
Trademark: The Iroko and Iroko Zen trademarks are registered with the INPI (French National Institute of Industrial Property). For any question regarding the use of the site https://uk.iroko.com, you can contact us directly online.
Hosting: The site is hosted on the servers of Amazon Web Services (AWS) Europe.
Complaints handling
This information is provided in accordance with Article 318-10 of the AMF General Regulation (Autorité des Marchés Financiers) and AMF instruction No. 2012-07. It is intended to inform Iroko's clients, whatever their category, about the complaints handling procedure.
Iroko strives to provide quality service to its clients every day. If you are dissatisfied with the quality of our services or products, you may send your complaint to the Customer Service department in charge of handling complaints within Iroko.
How to contact the department in charge of handling complaints within Iroko.
By email: reclamations@iroko.eu
Iroko will acknowledge receipt of your complaint within a maximum of 10 business days from the date the written complaint is sent (the postmark being proof for complaints sent by post), unless a response is provided directly within this period. From the date of receipt of your written complaint, Iroko undertakes to respond within a period not exceeding two months, except in duly justified special circumstances of which you will be kept informed.
Recourse: If you are dissatisfied with the handling of your complaint or in the absence of a response within a period of 2 months, you may refer the matter to the Ombudsman of the Autorité des Marchés Financiers (AMF), by completing the electronic mediation request form or by post. The mediation charter is also available on the AMF website.
For investment advice and portfolio management activities
Contact the Ombudsman by post:
AMF – Madame Marielle COHEN-BRANCHE
Médiateur de l'AMF
17 place de la bourse
75082 PARIS CEDEX 02
For disputes relating to insurance products
Le Médiateur de l'Assurance
TSA 50110
75441 PARIS CEDEX 09
www.mediation-assurance.org
For other activities
Centre de Médiation et d'Arbitrage de Paris
Service Médiation de la consommation
39 avenue Franklin D. Roosevelt – 75008 PARIS
www.mediateur-conso.cmap.fr – consommation@cmap.fr
A mediation request form is available online on the AMF website.
The procedures are confidential, free of charge, adversarial and non-binding. Either party may end them whenever they wish and retains the right to bring the matter before the courts. However, before referring the matter to the AMF Ombudsman, the client must first take steps with the department in charge of complaints within Iroko.
Conflicts of interest management policy
A conflict of interest refers to any situation in which ethical divergences, or divergences sanctioned by regulations, may arise between company stakeholders (shareholders, directors, employees, etc.) in their relations with clients, in a way that directly or indirectly harms the interests of the latter.
In accordance with the regulations, Iroko has implemented a policy for managing and controlling conflicts of interest. Iroko has built its framework around three pillars — prevention, detection, and then their handling — in order to avoid harming the interests of clients/partners.
The management company keeps its conflicts of interest management policy available to any client or third party who requests it.
Best selection and best execution policy
The AIFs managed by Iroko do not hold transferable securities in their portfolios. However, should Iroko come to manage transferable securities within its AIFs, we will implement a best execution and selection policy subject to an annual review.
Financial futures instruments
For the sole purpose of hedging against interest rate risk, certain managed AIFs may hold financial futures instruments. Iroko ensures that it obtains the best possible conditions for its shareholders and unitholders.
Client classification
Iroko has chosen to classify all of its partners as “non-professional clients”, allowing them to benefit from the highest level of protection and the most complete information possible. Clients who wish to do so may request, in writing and with supporting evidence, a change to their classification. The change of classification is subject to the agreement of the management company.
Remuneration policy
The remuneration applicable to all employees comprises:
A fixed component
It is sufficiently significant to remunerate the professional in view of the obligations of their position, the level of skills required, the responsibility exercised and the experience acquired.
The individual increase is determined according to various parameters such as performance, skills, current salary level, the employee's potential, the external market and the company's economic results.
A variable component in the form of a bonus
It aims to recognise individual performance and the level of commitment of employees. It should be noted that, for all employees, this variable remuneration is not linked to the performance of the funds, thereby not encouraging risk-taking incompatible with the risk profiles of the AIFs managed by Iroko. Bonuses may concern all employees and are a means of rewarding the achievement of objectives or assigned missions. The bonus differs according to teams and the contribution to creating value for the company; it takes into account qualitative and quantitative criteria as well as compliance with the regulations in force and the internal policies and procedures applicable in terms of compliance and risk management.
Sustainability risk
Iroko's remuneration policy now integrates sustainability risks. More concretely, roles and responsibilities regarding sustainability have been defined for various internal functions particularly involved in this topic within Iroko, and specific objectives have been assigned and adapted for teams and employees where relevant. Every year, the achievement of these objectives is assessed, as is the case for other objectives, during annual performance reviews.
Risk takers
Identified as risk takers within the meaning of the AIFM Directive are the President, the Chief Executive Officer, the fund managers, the Head of Compliance and Internal Control (RCCI) and the Head of Administration and Finance.
The Management Company undertakes to establish, implement and maintain remuneration policies, procedures and practices that promote sound and effective risk management, which constitutes one of the pillars of the Management Companies' strategy. The management company keeps its Remuneration policy available to any client or third party who requests it.
Statement on the non-consideration of adverse sustainability impacts
Introduction
Article 4 of Regulation (EU) 2019/2088 (“SFDR”) on sustainability-related disclosures in the financial services sector provides that transparency must be ensured regarding the principal adverse impacts of investment decisions on sustainability factors. This statement meets this objective by describing the due diligence policies regarding these impacts, taking into account the size of the organisation, the nature and scope of its activities, and the types of financial products offered.
Definition of the principal adverse sustainability impacts
The term PAI refers to “principal adverse impacts”. These are the adverse sustainability impacts, i.e. the most significant negative impacts of investment decisions on sustainability factors relating to environmental, social and employee matters, respect for human rights and anti-corruption.
Non-consideration of the principal adverse sustainability impacts
As Iroko is a management company with fewer than 500 employees, the consideration of PAIs is done on a voluntary basis. The management company is therefore not required to take into account adverse sustainability impacts.
When the company chooses not to follow the provisions of the regulation, it is required to explain why implementation is not relevant at its scale under the “comply or explain” principle. Although Iroko takes sustainability factors into account in its investment decisions, its thinking on the prioritisation of the adverse impacts of these investments is not yet fully developed, and the data currently available does not make it possible to ensure that the adverse impacts on sustainability factors are fully taken into account. At this stage, Iroko is therefore unable to measure the effects of these impacts.
It should be noted that Iroko closely monitors regulatory developments and industry work in order to be able to take the principal adverse impacts into account in its business in the near future. The decision regarding the consideration of the principal adverse impacts will be reviewed annually.