Conflict of Interest

GLASSBOX ASSET MANAGEMENT has established a policy to manage conflicts of interest and has implemented specific organizational measures, including resources, procedures, and controls, to prevent, identify, and address conflicts of interest that could harm its clients' interests.

In the event of a conflict of interest, it will be managed in the best interest of the client, ensuring fairness, transparency, and appropriate disclosure.

As an independent asset management company, GLASSBOX ASSET MANAGEMENT is authorized, in the event of a conflict of interest, to:

• Proceed with the activity or transaction if its organizational framework allows for proper conflict management.
• Inform the client when the conflict of interest persists, providing relevant details on their nature and origin.
• If necessary, refrain from executing the activity or transaction that gives rise to the conflict of interest.

GLASSBOX ASSET MANAGEMENT is committed to managing conflicts of interest from detection to resolution. 

To this end, it has established a framework designed to:

• Prevent conflicts of interest by raising staff awareness of internal and market conduct rules, and by implementing strict policies and procedures.
• Identify conflicts of interest that could negatively impact clients by mapping them from a risk-management perspective.
• Manage potential conflicts of interest effectively.

COMPLAINTS HANDLING POLICY

The following provisions of the General regulation of the AMF are applicable:

Article 318-10

The asset management company shall establish and maintain operational an effective and transparent procedure for reasonable and prompt handling of complaints received from all holders of units or shares in AIFs, when no investment service is provided to them upon subscription.

Holders of units or shares may file complaints free of charge with the asset management company.

The asset management company shall respond to the complaint within a maximum of two months as of the date on which the complaint was sent, except in duly justified special circumstances.

They shall implement a system enabling fair and consistent handling of complaints from the holders of units or shares. This system shall be allocated the necessary resources and expertise.

It shall record each complaint and the measures taken to handle it. It shall also implement a complaint monitoring system enabling it, among other things, to identify problems and implement appropriate corrective measures.

Information on the complaint handling procedure shall be made available free of charge to the holders of units or shares.

The complaint handling procedure shall be proportionate to the size and structure of the asset management company.

Article 318-10-1

The asset management company shall establish appropriate procedures and arrangements to ensure that it deals properly with complaints from AIF unit or shareholders and that there are no restrictions on these persons exercising their rights if they reside in another European Union Member State. These measures shall allow AIF unit or shareholders to send a complaint in the official language or one of the official languages of the Member State in which the AIF is marketed and to receive a response in the same language.

The asset management company shall also establish appropriate procedures and arrangements to supply information, at the request of the public.

These provisions shall apply if no investment service is provided upon subscription.

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Procedure

Any complaint should be sent in writing to the address hereunder:

• By post 

Glassbox Asset Management

40 rue du Colisée, 75008 Paris - FRANCE

• By email

compliance@glassbox.am

The asset management company undertakes to acknowledge receipt of any complaint within a maximum period of ten (10) business days since the sending date and to provide a response within a maximum period of two (2) months since the same date.

Any complaint should also be notified to the AMF’s ombudsman who is competent in any dispute relating to a financial instrument, an investment service or, more generally, a matter falling within the scope of competence of the Autorité des marchés financiers. Such complaint should be sent in writing to the address hereunder:

• By post 

AMF Ombudsman

Autorité des marchés financiers

17 Place de la Bourse

75082 Paris cedex 2

• By electronic means 

www.amf-france.org/fr/le-mediateur-de-lamf/votre-dossier-de-mediation/vous-voulez-deposer-une-demande-de-mediation