COPYRIGHT
The Keensight Capital website is protected under intellectual property rights, as are any data on the website, such as brands, logos, graphs, photographs, etc. The information contained on this website is strictly for the personal use of the website’s visitors and may not be reproduced or communicated to third parties, in whole or in part, for commercial or non-commercial purposes.
Due to the simplified nature of the website’s content, the information communicated by Keensight Capital’s website is incomplete and has no contractual value. Despite our best endeavors, technical faults may occur. These could result, for example, from restricted access or faulty reproduction of information, caused by either the website itself or the actions of third parties: Keensight Capital takes no responsibility for any loss which could result. It undertakes only, upon identification of the fault, to implement procedures to remedy such fault. The user is liable for any reproduction or, in general, any unauthorized use of the website and the information contained therein. Such use may result in legal proceedings, particularly for piracy.
© 2024 – Keensight Capital. All rights reserved. The information contained on this website may not be reproduced without the permission of Keensight Capital. This Website is hosted by Kinsta. Kinsta Inc. 8605 Santa Monica Blvd #92581 West Hollywood, CA 90069 United States. Data is hosted on the server in London, UK.
REGULATIONS AND RESPONSIBILITIES
Keensight Capital is responsible for updating the website. Keensight Capital has ensured to the best of its ability that the information published on the website is correct, but it shall not be held liable for any loss or damage incurred, whatever its nature, which may result from the opinions or information published on the website, whether explicit or implicit.
LOCAL RULES AND REGULATIONS
The laws and regulations of the country from which you access this website may contain restrictions on the distribution of the information the website contains. If this is the case, this information may not be distributed or used by any natural person or legal entity. Such natural persons and legal entities shall be obliged to inform themselves of and to observe any such restrictions.
Any dispute relating to the use of the keensight.com website is subject to French law. The competent courts in Paris have exclusive jurisdiction.
MANAGEMENT OF PERSONAL DATA
In the context of the General Data Protection Regulation (EU Regulation 2016/679, hereinafter referred to as the “GDPR”), we, Keensight Capital, a simplified joint-stock company registered in the Paris Company Register under number 509 104 527, having its registered office at 128, rue du Faubourg Saint-Honoré – 75008 Paris (France), is the controller responsible for the processing of Personal Data (the “Personal Data” or “Data”) described in this Privacy Notice (the “Privacy Notice”).
The aim of this Privacy Notice is to inform you about the processing of your Personal Data. When using the keensight.com website, the following information may be collected: the URL of the links through which the user accessed the www. keensight.com website, the user’s access provider, the user’s Internet protocol (IP) address.
In any case, Keensight Capital only collects personal information that is necessary for the proper functioning of the site and its features and to ensure the user’s ease of navigation.
By logging on to the website, the user agrees to the terms of this Privacy Notice, and in particular agrees to: the collection, storage and use of his/her personal data as described in this Privacy Notice.
In accordance with the French Data Protection Act of January 6, 1978, as modified by the law of the 6 August 2004, you have a right to inquire about, access and rectify all of your data and to object to their processing on legitimate grounds. You can exercise these rights by sending a letter, together with a copy of an identity document to Keensight Capital by e-mail at gdpr@keensight.com or by mail to Keensight Capital : 128, Rue du Faubourg Saint Honoré 75008 Paris.
Investors can find the latest Privacy Notice regarding the processing of their Personal Data in the context of their subscription here.
COOKIES MANAGEMENT
Browsing the keensight.com site may result in the installation of cookie(s) on the user’s computer. A cookie is a small text file containing letters and numbers placed by a website onto your computer, which does not allow the user to be identified, but which records information relating to the navigation of a computer on a site.
keensight.com only uses necessary cookies, which enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.
Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer’s website.
If you are based in the European Union and would like to learn more about cookies or you do not wish to receive them, then please visit the Your Online Choices site. For those based in the US please visit the Aboutads choices page.
CLAIM HANDLING POLICY
In case of disagreement, you can address your complaints to your usual contacts within Keensight Capital or directly:
- By post to Keensight Capital, 128 Rue du Faubourg Saint Honoré, 75008 Paris.
- By email to reclamations@keensight.com.
- By phone at +33 (0)1 83 79 87 30.
To facilitate the resolution of your complaint, we encourage you to submit it in writing.
Keensight Capital undertakes to provide you with:
- An acknowledgment of receipt within a maximum of ten working days from the date of sending your written complaint.
- A response to your complaint within a maximum period of two months from the date of sending your written complaint, except in the event of duly justified exceptional circumstances.
If you are not satisfied with the response provided to your complaint, you may contact, free of charge, the mediator of the French Financial Markets Authority. It is preferable to use the electronic form on the AMF website, or you can send postal mail to the address: 17 Place de la Bourse, 75082 Paris Cedex 2.
CONFLICT OF INTEREST MANAGEMENT POLICY
Keensight Capital has a conflict-of-interest management policy in accordance with current regulations. Keensight Capital maintains and applies effective organizational and administrative arrangements, with a view to taking any reasonable measure to identify, prevent, manage and monitor conflicts of interest to prevent them from adversely affecting the interests of Funds and investors.
Keensight Capital has identified different situations of potential conflicts of interest:
- General potential conflicts of interest;
- conflicts of interest involving the Company and one of its shareholders;
- conflicts of interest involving the Company and a Related Business (such as defined in the regulation of the funds managed by the Company, hereinafter the “Funds”);
- conflicts of interest involving the Company or a Fund and an Investor (such as defined in the Funds’ By-Laws);
- conflicts of interest involving the Company or a Fund and a Partner (such as defined in the Funds’ By-Laws) or an employee;
- conflicts of interest involving two Investors.
- Potential conflicts of interest specific to the organization and activities conducted;
- Potential conflicts of interest specific to the activities carried out by Keensight Performance.
To prevent conflicts of interest, the Company has implemented different measures:
- Procedures, policies, and guidelines encompassing a wide range of areas, including, but not limited to, conflicts of interest, external engagements, prevention of market abuse, personal securities transactions, anti-bribery, acceptance of gifts.
- Mapping the different potential conflict of interest cases as well as a “Register of Conflicts of Interest” that lists potential or proven conflicts of interest cases since the creation of Keensight Capital;
- A Code of Conduct, which is approved by each employee upon hiring.
- Appropriate escalation processes when identifying a conflict of interest as well as a whistleblowing tool.
Whenever an employee, an investor, or any other person raises concerns about the existence or possibility of a real, potential, or apparent conflict of interest, they must immediately inform the RCCI (Compliance and internal control officer).
This communication should be made through any durable medium (email, internal memo, etc.). It should specify:
- The relevant activity;
- The date when the conflict was observed;
- Whether the conflict is actual or potential;
- A detailed description of the conflict;
- The stakeholders impacted by the conflict;
- The potential type of impact.
Individuals are also encouraged to report, either in writing or orally, to the RCCI any situations they deem necessary and which could generate a conflict of interest or its appearance, even if they are unable to specify all six characteristics mentioned above.
When a potential conflict is reported, the RCCI examines the nature, origins, and consequence of the identified conflict of interest and implements appropriate measures to mitigate its immediate impact.
Where the organizational or administrative arrangements made by Keensight Capital to manage conflicts of interest are insufficient to provide reasonable assurance that the risk of undermining the interests of investors will be avoided, the company shall clearly inform the persons concerned of the nature or source of such conflicts of interest.
The Fund’s Investor Advisory Committee is informed as soon as the Management Company identifies a situation of conflict of interest qualified as i) potential but not treated and ii) proven, in accordance with the rules of good conduct specified in the Fund Regulations.
In the event of a proven conflict of interest, the Management Company shall inform the Fund’s Investor Advisory Committee (in accordance with the provisions of the Fund Regulations) and the Statutory Auditor of the Company and the Fund(s) of the situation observed and the measures taken.
SFDR (PAI)
Article 4(1)(b) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”) requires fund managers to publish a statement regarding the consideration of principal adverse impacts of investment decisions on sustainability factors. Keensight Capital has established processes and measures to assess and monitor ESG and sustainability matters (i.e., environmental, social, and governance factors) in the investment cycle, in line with its ESG Policy and Responsible Investment Policy.
However, at this stage, Keensight Capital does not consider any adverse impacts as prescribed in the EU SFDR regulation as the Company acknowledges the current limitations on readily available data to fully comply with the reporting requirements.
The Firm’s position will be kept under ongoing review and monitored closely as the market developments evolve. In this sense, Keensight Capital will reassess the situation and make the necessary changes in due course, toward the consideration of principal adverse impacts in the manner contemplated by Article 4(1)(a) of the SFDR.
