General terms

General terms and conditions of use of the site

The website is the property of 2PM Europe S.A. whose registered office address is :

West Side Village - 1st floor
89D, rue Pafebruch
L-8308 Capellen - Luxembourg

RCS Luxembourg number B208545.
The intra-community VAT number of 2PM Europe S.A. is LU 28785125.

2PM Europe S.A. is subject to the supervision of the CSSF CSSF (Commission de Surveillance du Secteur Financier)
The website contains only general information, which has not been customized for your personal needs.
Under no circumstances whatsoever can we be held responsible for any decision taken on the basis of information contained on the site, nor for the use that may be made of it by third parties. We are at your disposal to advise you personally, do not hesitate to contact us via our website or by telephone.

We strive to ensure the accuracy and updating of the information disseminated on the site, at the time it is put online, as well as access to the site.
However, we in no way guarantee the accuracy, precision or completeness of the information made available on the site and we reserve the right to modify or correct, at any time and without notice, the content of the information and documents published on the site.
In this respect, we cannot be held liable for the content of the site and the use you may make of it, namely for any damage, direct or indirect, caused by access or use of the site by anyone or by the impossibility of accessing it.

Toutes les informations contenues sur le site internet, y compris le design, le style et les logos, sont la propriété exclusive de 2PM Europe S.A. Toute reproduction d’éléments du site sans autorisation préalable de 2PM Europe S.A. est strictement interdite.

Our site contains hypertext links allowing access to sites of which we are not the publishers.
Consequently, we decline all responsibility for the content and any damage incurred when visiting sites to which the site leads by hypertext links.
The user visits other sites under his own responsibility and at his own risk. By accessing another site through a hypertext link, you accept that such access is at your own risk.
Consequently, any direct or indirect prejudice resulting from your access to another site linked by a hypertext link cannot engage our responsibility.

The information published on the site is intended for use in Luxembourg.

We reserve the right to modify or supplement the present general conditions at any time and without notice.

Conflict of interest policy

1. Purpose and Scope

Pursuant to the European Directive 2004/39/EC of April 21, 2004 on markets in financial instruments ("MiFID": transposed into Luxembourg law by the Law of July 13, 2007 on markets in financial instruments as amended, and the Grand-Ducal Regulation of July 13, 2007 on organizational requirements and rules of conduct in the financial sector), we maintain an effective organizational and administrative structure with a view to taking all reasonable steps to identify, assess and manage potential conflicts of interest.
This document summarizes the policy that has been put in place and provides essential information about the measures taken to protect their interests.

2. Conflict of Interest Policy

Our conflict of interest policy is defined as follows:
- we identify circumstances that give rise or are likely to give rise to a conflict of interest with a tangible risk of harming the interests of the client ;
- we define the procedures to be followed and the measures to be taken in order to manage these conflicts of interest;
- we maintain systems designed to prevent actual harm to the client's interests in the event of a conflict of interest.

3. Identifying a conflict of interest

Under MiFID regulations, and regardless of the department of the company concerned, a conflict of interest exists when, in the context of providing a service to a client, the performance of the service benefits the company (or another client on whose behalf it acts or a person directly or indirectly linked to the company by a controlling relationship), while being likely to harm the interests of the client for whom the service is provided.

The risk of a conflict of interest exists when 2PM Europe S.A. (or a client or a person directly or indirectly linked to the company by a control relationship) :
- is likely to realize a financial gain or avoid a financial loss at the expense of the client ;
- has an interest in the outcome of the service provided to the client or the transaction carried out on behalf of the client that is different from the client's interest ;
- has an incentive, for financial or other reasons, to favour the interests of another client or group of clients over the client concerned;
- is engaged in the same professional activity as the client;
- receives or will receive from a person other than the client a benefit in connection with the service provided to the client, in the form of money, goods or services, other than the commission or fee normally charged for that service.

When a business relationship that is entered into with 2PM Europe S.A. is likely to create conflicts of interest or have an adverse influence on the risk profile of the company, it must be submitted to the Board of Directors for approval. Any business relationship must be entered into in the interest of the company, i.e. it must take place under competitive financial conditions, it must respect its liquidity and solvency, and it must be within acceptable risk conditions in order to ensure sound and prudent management of the company.

An exercise was carried out to identify the circumstances that give rise or are likely to give rise to a conflict of interest within 2PM Europe S.A. Similarly, the measures deemed appropriate to monitor and manage these conflicts of interest and to control their impact were taken. Potential conflicts of interest identified include
- Conflicts of interest between our clients with opposing interests;
- Conflicts of interest due to differing interests between the institution and the client with respect to a particular outcome;
- Conflicts of interest due to a divergence between the personal interests of the institution or its staff and the interests of the client.

4. Policies and Procedures

We have well-established internal policies and procedures designed to manage potential conflicts of interest. These policies and procedures, which have been designed to ensure the required level of independence, are subject to an ongoing process of evaluation and review, and include, but are not limited to, the following :

Chinese Walls:
We apply procedures that control the exchange of information between employees and/or between different departments of the company, in cases where the interests of one client could be in conflict with the interests of another client or our own, or those of a person related to us directly or indirectly by a controlling relationship (a "Related Person").
We have well-established information segregation policies and procedures designed to manage confidential information and prevent the improper transmission of confidential or price-sensitive information (often referred to as "Insider Information").

Separate control and segregation of duties :
Where appropriate, a separation of control and/or functions of our employees and/or departments carrying out activities for clients whose interests may be in conflict with the interests of another client, our own or those of a related person, has been implemented. These measures are designed to avoid the simultaneous involvement of a person concerned in separate departments or activities, when such involvement is likely to interfere with the proper management of conflicts.

Disclosure :
When there is no other alternative for managing a conflict of interest or if, in our view, the measures in place do not sufficiently protect the client's interests, then the existence of the conflict of interest will be disclosed to the client. This is so that the client is able to make an informed decision as to whether or not to continue the business relationship.

Refusal to intervene :
When we consider that we are unable, in any way whatsoever, to manage a conflict of interest, we may refuse to act for the client.
The client who wishes to do so may contact his RM to receive more detailed information on our conflict of interest policy.

Privacy policy for personal data

The purpose of this document is to inform the clients about the policy of confidentiality of personal data in force within the framework of their relations with the Management Company.

Who ?

The Management Company is responsible for the processing of its clients' personal data. You can contact the Management Company via the following contact details:
Telephone: +352 / 28 48 36 1
The contact person who is responsible for handling questions and/or complaints from clients is Jean-Yves Dourte, Member of the Authorized Management Board.

Which personal data ?

The personal data collected by the Management Company may vary according to the services and products offered and the circumstances of each situation. The data concerned may therefore include surname and first name, address, telephone number, place and date of birth, tax identification number, national register number, marital status, family situation, professional data, financial data, origin of personal assets, details of portfolios and financial transactions, risk profile, etc.

Why ?

The personal data collected by the Management Company meet several objectives:
- Regulatory/legal: the Management Company is required to have a certain amount of personal information relating to its clients within the framework of its regulatory obligations (for example, the "KYC- Know Your Customer" obligations).
- Execution of the management mandate: the Management Company must have personal information for the proper execution of its obligations within the framework of the management mandate granted to it.
Finally, with their authorization, the Management Company may also use the personal data of its clients for purposes of invitation to private events that it may organize.
Under no circumstances will the personal data be exchanged, sold or rented to third parties with commercial and/or marketing intentions.

How long will it take?

I
n order to satisfy its regulatory obligations, the Management Company will keep this personal data for a period of 10 years following the collection of this information and/or the end of the contractual relations.
What are the customers' rights?

Quels sont les droits des clients ?

The clients of the Management Company have the following rights:
- consultation of the personal data used by the Management Company and, if need be, correction of these data ;
- deletion or limitation of the access to certain personal data when they prove to be no longer necessary within the framework of the objectives mentioned above (section "why?");
Customers may exercise their rights by contacting the person responsible for the processing of personal information mentioned above.
In addition, clients have the right to submit a complaint to the Luxembourg authority, namely the National Commission for Data Protection (CNPD) when they are no longer satisfied with the processing carried out by the Management Company.
This Commission is accessible at https://cnpd.public.lu or at the following address:
National Commission for Data Protection
1, avenue du Rock'n'Roll
L4361 Esch-sur-Alzette
Tel: +352/26 10 60 1
These same rights apply to persons who are interested in the services of the Management Company but who have not yet granted a management mandate to the Management Company.

Procedure for handling complaints and claims from customers (extracts)

The internal procedure for handling customer complaints describes the tasks and responsibilities for handling customer complaints in accordance with CSSF Regulation 16-07 on out-of-court settlement of complaints.

Below are some excerpts from this internal procedure.

A complaint is understood to mean any complaint addressed by a client to the Management Company in order to have a right recognized or to repair a prejudice.

These complaints can be addressed to the Management Company either by e-mail to the address info@2pmeurope.com or by mail to the address of the registered office of the Company.

The contact person who is responsible for handling questions and/or complaints from clients is Jean-Yves Dourte, Member of the Authorized Management.

An acknowledgement of receipt must be sent to the customer within a period not exceeding 10 working days from receipt of the complaint.

An answer will then be sent by the Management Company at the latest in the month following its reception.

Remuneration policy

In order to satisfy our legal obligations, the Management Company holds at the disposal of its clients and/or any person interested in its services a document containing the main elements of the Remuneration Policy applied within the company.

To obtain this document, you can make a justified request by mail addressed to the registered office of the Management Company to the attention of the Authorized Management.