TIME for Growth SAS
23, rue la Boétie
Phone: +33 1 40 73 87 30
TIME for Growth is a simplified joint stock company.
Portfolio management company approved by the AMF on the 28/09/2018, under the number GP 18000017
Share capital of € 158,086
R.C.S. PARIS 509 544 300
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The person in charge of the content of the publication of the website is Henri De Bodinat.
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The management company TIME for Growth SAS maintains a procedure for the reasonable handling of claims made by customers.
A claim is a statement of the client’s dissatisfaction with the professional. A request for information, advice, clarification, service or service is not a claim.
Clients can make claims free of charge to the portfolio management company. Any complaint can be addressed to TIME for Growth SAS:
By letter at the following address: 23 rue la Boétie - 75008 Paris;
By phone at the following number: +33 (0) 1 40 73 87 30;
By email at the following address: email@example.com.
If a customer or prospect in any way exhibits an inconvenience that he has suffered, TIME FOR GROWTH faces the situation with the best possible diligence.
Management and RCCI are aware of the need to consider the inconvenience exhibited by the client as a claim or not.
Claims made by customers are subject to:
• a reasonable and fast treatment;
• An acknowledgment of receipt to the client concerned, by mail or mail, within a maximum of 10 working days from the receipt of the claim;
• A response within a maximum of 2 months.
As a Portfolio Management Company, TIME for Growth must have a remuneration policy whose main provisions are described in the following regulatory references:
• Article 13 and Annex II to Directive 2011/61 / EU of 8 June 2011 on Alternative Investment Fund Managers (AIFM Directive)
• Delegated Regulation (EU) No 231-2013 of the Commission of 19 December 2012
• ESMA of 11/02/2013
• Articles 319-10 to 319-20 of the AMF General Regulations
Time for Growth has defined its device in accordance with the requirements of the AIFM standard. The devices were declared to the AMF in June 2018.
The purpose of this policy is to describe the organization and principles of TIME for Growth for the compensation of its employees. In this context, TIME for Growth is in charge of human resources management (recruitment, career development of employees, incentives, etc.), with the main objective of sustaining a quality management team while not encouraging risk taking.
1. General Principles
This Remuneration Policy promotes sound and effective risk management and does not encourage risk taking that would be incompatible with the risk profiles, the regulations and the constituent documents of the UCIs managed by the Management Company. It is also determined in such a way as to avoid situations of conflict of interest and to prevent risk-taking that is inconsiderate or incompatible with the interest of investors from the range of funds managed by SGP.
Time for Growth’s Compensation Policy aims to encourage the alignment of the personal goals of all employees with those of the Time for Growth managed funds as well as the long-term objectives of Time for Growth.
The managers of Time for Growth have always attached great importance to aligning the long-term interests of all employees with those of Time for Growth and its customers. With this in mind, they have involved key employees in the smooth running and development of Time for Growth.
Time for Growth’s Compensation Policy also aims to promote:
· Time for Growth’s competitiveness in a competitive environment
· Attractiveness and maintan of motivated and qualified employees
Time for Growth’s Compensation Policy is based on the following principles:
1. The SGP shall ensure that the fixed part of the remuneration represents a sufficiently high proportion that makes it possible to remunerate the employees with regard to the obligations of their position, the level of competence required, the responsibility exercised and the experience acquired.
2. The SGP has set up a profit-sharing agreement and a Company Savings Plan (PEE) which associates all employees in the long term to the smooth running of the SGP. In addition, these vehicles encourage investment in the "home" funds of the SGP.
3. Variable compensation is determined in such a way that its level is related to the wealth created by the management company over the long term. It will not exceed 200 000 €. In the event that the variable remuneration of one of the employees exceeds the threshold of € 200,000, the regulations in force will apply, namely:
An annual adoption and review of the remuneration policy by the management body, in the exercise of its supervisory function, or by the supervisory body, when the management and supervisory functions are separated, from the portfolio management company,
The supervision by a compensation committee, if there is one, of the salaries of senior managers in charge of risk management and compliance,
The multi-annual evaluation of the employees concerned,
The principle that guaranteed variable remuneration is only possible in exceptional cases,
An appropriate balance between fixed and variable components,
The spread over time (3 to 5 years) of at least 40% of the variable remuneration,
Constraints conditioning the payment of the variable remuneration to the financial health of the asset management company.
4. The allocation and distribution of variable compensation is by its very nature discretionary and in no way indexed to fund performance.
5. The distribution of variable remuneration is determined on the basis of essentially qualitative objectives. The performance of a fund, a strategy or a particular transaction can not be attributed to an employee and can not be directly linked to his or her compensation.
6. The total amount of the variable compensation is compatible with the financial position of the management company, so that it is considerably reduced, or even nil, when the management company records poor or negative financial performance.
7. SGP shall ensure that variable remunerations are paid after the closure of the accounts of the managed funds and that the SGP has determined its overall result for the financial year concerned.
8. The SGP sets up a Remuneration Committee.
2. Compensation Committee & Governance
Time for Growth is a Simplified Joint Stock Company with a Chairman, Mr. Henri de BODINAT
The top management decide the staff remuneration, who are:
• Mr. Henri de BODINAT (President)
• Jean-Luc CYROT (Managing Director-RCCI)
Time for Growth reviews the general principles of the remuneration policy at least once a year.
3. Identified Personnel
Given the size of the company’s workforce, and for the sake of simplification, Time for Growth has decided to extend the principles of this remuneration policy to all employees of the Management Company.
4. Policy on the distribution of variable remuneration
The company’s compensation policy will be based primarily on fixed salaries for all employees. A variable remuneration could be paid according to the results of the company but without exceeding 30% of the fixed remuneration.
The portion of variable compensation awarded to each employee for the tasks performed during the past year is determined on the basis of mainly qualitative objectives. It is in no way based on an indexation to the performance of one or the other of the funds, of a strategy or of particular operations. The elements of appreciation of the performance of the collaborator are understood in others through:
• The achievement of defined objectives
• The creativity and motivation of the collaborator
• Team spirit and cooperation with the different teams composing the SGP
• Adherence to the risk policy
• Compliance with internal or external rules
• The quality of managers’ analyzes
• The measurement of customer satisfaction
The variable component of the employee’s compensation is in no way a guaranteed payment, either in principle or in amount, and can not be considered as fixed or quasi-fixed remuneration, even if a collaborator receives the same amount. for several years.
5. Discretionary Variable Compensation
The variable compensation of the employee determined in year N (for year N-1) is paid 100% in cash if the latter is less than € 200,000.
In the event that the variable remuneration exceeds the threshold (€ 200,000), the following conditions must be respected:
• an immediate payment (in practice in year N) of 60% of the amount awarded,
• A deferred payment over a period of 3 to 5 years of the remaining 40%.
Each year, the Compensation Committee, at its annual review, determines the allocation between the different UCIs of the overall deferred compensation package for the year N that it has set.
6. Compensation control system
The RCCI of Time for Growth and its delegate D2R / CAPSI Conseil integrate the field of variable compensation into the potential risks of conflicts of interest.
This procedure is put in place to minimize the risks involved. A control of its application is integrated into the Compliance and Internal Control Plan established by D2R / CAPSI Conseil and validated by Mr Jean-Luc CYROT as RCCI.
The control carried out by the RCCI consists of checking:
• The application of the compensation policy above
• The compliance of the remuneration policy with the AIFM Directive
This procedure may be modified at any time at the initiative of the Time for Growth Compensation Committee, the RCCI or its delegate or at the request of the regulator (AMF).
Conflicts of interest
Time For Growth has formalized a conflict of interest procedure in accordance with the transposition into French law of Directive 2004/39 / EC on Markets in Financial Instruments.
The procedure for the identification and management of conflicts of interest aims to identify situations leading to, or likely to lead to, a conflict of interest, in order to provide a solution guaranteeing the preservation of the interest of the clients.
As a portfolio management company, Time For Growth is required to take all reasonable steps to prevent conflicts of interest from adversely affecting the interests of its clients.
Conflicts of interest may especially appear between:
• Time For Growth, the Relevant Persons or any other person directly or indirectly related to Time For Growth through a control relationship, on the one hand, and its clients (subscribers of FPCI’s shares), on the other hand;
• or between two customers.
Where the measures adopted are not sufficient to guarantee with reasonable certainty that the risk of harming the interests of the customers will be avoided, Time For Growth shall clearly inform the customers, before acting on their behalf, of the general nature or source of these conflicts of interest.
In addition, Time For Growth is required to establish and maintain an effective conflict of interest management policy that must be set in writing and be appropriate for its size, organization, nature of its importance and the complexity of its activity.
Finally, Time For Growth shall maintain and regularly update a record of the types of investment services or related services, or other activities performed by or on behalf of Time for Growth, for which a conflict of interest involving a material risk of loss of the interests of one or more of its customers have occurred or, in the case of a service or activity in progress, is likely to occur.
Data Protection Policy as of May 25, 2018
TIME for Growth gives importance to the protection of your personal data. Starting on May 25, 2018, the processing of your personal data is subject to the EU regulation 2016/679 of 27 April 2016 called "GDPR" relating to the protection of individuals with regard to the processing of personal data and the free circulation of these data. The purpose of this policy is to provide you with detailed information on how TIME for Growth collects, protects and retains your personal data, as well as the reasons for their use and sharing.
1. What personal data does TIME For Growth use?
We do not collect personal information about web users by simply browsing this site. We track the overall usage of the website, such as the total number of times each page was viewed and in which order the pages are viewed on our site. We identify the basic navigation features, such as IP addresses and browser, used to detect unusual and unauthorized traffic on our website.
No information collected from our readers may ever be sold, rented or passed on to a third party unless required by law.
Outside of its website, TIME for Growth may collect various types of personal data about you, including:
• Your identification information (surname, first name, nationality, date of birth, gender);
• Your contact details (postal address and email address, telephone number);
• Your family situation (for example, marital status, number of children);
• Information about your education, profession and work experience;
• Your banking identities, financial data (property situation ...) and capital shares in the investments;
• Data collected in the course of exchanges, especially those made at the headquarters of TIME for Growth, or even at meetings or exhibitions, interviews, telephone conversations, e-mails.
2. With whom does TIME For Growth share your personal data?
Your personal data is used exclusively by TIME for Growth and will not be sold or exchanged with third parties. However, in certain cases, they may be the subject of a communication, namely: to the judicial or financial authorities, state agencies or public bodies, upon their request and within the limits of what is authorized by the regulations
If you simply want to ask your questions, you can send an email to the following address: firstname.lastname@example.org or send a letter to the following address: TIME for Growth - 23, rue La Boétie, 75008 Paris - la France
In accordance with the applicable legislation, in addition to the rights mentioned above, you have the right to contact a data protection authority (such as the CNIL in France, www.cnil.fr).
TIME for Growth may update its data protection policy at any time and post it online with the date of revision.
TIME For Growth SAS has signed the PRI (Principles for Responsible Investment), confirming its commitment to integrate the responsible criteria in its management and investment policy.
The concrete illustration of the commitment of TIME For Growth SAS is highlighted in the PRI Guides, which give practical advices to private equity players willing to implement an ESG approach.
TIME For Growth SAS commits itself with France Invest (French association of investors for growth) and signs the Charter involving values, responsibilities and commitments.
You will find all the information listed in Article D533-16-1 of the Financial Monetary Code under the heading "Responsible Investor" of the website.
Terms and conditions of TIME For Growth SAS to take environmental, social and governance criteria into account in its investment policy
ESG policy of TIME For Growth SAS
TIME For Growth SAS is committed to excellence and innovation and has decided in 2017 to adopt a global environmental, social and governance (ESG) strategy. The company includes ESG at all stages of the investment process:
Before an acquisition, TIME For Growth SAS:
• Conduct ESG due diligences
• Incorporates ESG principles into shareholders offers and pacts
During the holding period, TIME For Growth SAS:
• Defines a roadmap with the management of the company
• Encourages the appointment of a project manager within the company
• Help to implement the action plans
The geographical field and the public concerned
The management company TIME for Growth SAS addresses the European market. The FCPI is only for professional clients.
Voting rights policy
The AMF General Regulation sets out the obligations of asset management companies (SGP) regarding investors concerning the exercise of voting rights relating to the securities appearing on the assets of the AIFs. they manage.
These obligations are part of the rules of good conduct and other professional obligations of asset management companies relating to investor relations.
This voting policy is an extension of TIME FOR GROWTH’s investment policy, which aims to seek regular performance over the long term in accordance with the AIF management guidelines.
It aims to favor the projects of companies that lead to the creation of value and the development of their economic activities in profitable, sustainable and equitable conditions.
In this context, TIME FOR GROWTH ensures the interest of the unitholders or shares of the UCITS that it manages, while respecting the integrity of the financial markets.
The decision on the vote of the companies held by the AIF administered by TIME FOR GROWTH is entrusted to the manager of the portfolio concerned. In the event that the manager is in difficulty or in a situation of conflict of interest, he informs the RCCI of TIME FOR GROWTH. If applicable, the voting decision may be deferred to the other members of the Management Committee.
Threshold of intervention:
TIME FOR GROWTH sets itself the following intervention thresholds to participate systematically in the votes:
• Beyond a holding threshold of 5% of voting rights per company for all AIFs managed by TIME FOR GROWTH;
This intervention threshold aims to favor flexibility and speed in making investment decisions. Beyond these thresholds, TIME FOR GROWTH considers that the positions taken on companies are in the long term and require closer monitoring.
In addition, TIME FOR GROWTH reserves the right not to exercise the voting rights held by its AIF in the following cases, even if the above thresholds are reached:
• When voting requires securities to be locked for a long period of time, limiting liquidity and preventing market opportunities;
• When voting results in prohibitive administrative costs;
• In the particular case where the shares were temporarily sold at the time of the exercise of the voting rights, TIME FOR GROWTH does not intend to recall the securities and does not exercise its voting rights.
Finally, TIME FOR GROWTH reserves the right to vote on any occasion, even when the holdings in the managed portfolios are below the thresholds mentioned below.