LEGAL NOTICE

Company name: Trail Management
Head office: Trail – 12 avenue Matignon, 75 008 Paris

Legal status: S.A.S. au capital de 1,000,000 euros
SIREN N°: 821 737 632
GP N°: GP-17000019

Responsible: Mr Xavier Marin

Website creation: Digital Village

Address: Trail – 12 avenue Matignon, 75 008 Paris – Tel : +33 1 55 35 55 00

This web site, notably accessible from the URL www.trailcapital.eu, is owned by Trail Management which has a share capital of EUR 1,000,000, its registered office at 12 Avenue Matignon, 75008 Paris, France and is registered with the Paris Registre du Commerce et des Sociétés under the number 821 737 632 (“Trail”). The person in charge of the editing service of this web site is Mr. Xavier Marin.

By accessing and/or using this web site, the pages contained on it and/or the information, tools and material contained or described herein (the “Site”), you, whether you are acting on your own behalf or on behalf of someone else (referred to, alone or together with the person you represent, as the “User”), acknowledge your agreement with and understanding of the following terms and conditions of access and use of the Site and, to the extent permitted by applicable laws and/or regulations, you notably waive any right that you may have (or obtain as a result of accessing and/or using the Site) and which would be inconsistent with the said terms and conditions including, but not limited to, any rights that might restrict the provisions regarding the absence of warranty and/or liability pursuant to section 5 of this legal notice.
Although Trail strives to protect the Site from viruses, it makes no warranties as to whether the Site is free from viruses. Users must take appropriate measures to protect themselves from viruses before downloading the Information.

Information on the Site
Information of any kind contained in or referred to on this Site (the “Information”) is intended to describe or explain the activities of the group “Trail”.

The Information contained on this Site and this Site itself are not an offer to sell, or a solicitation of an offer to buy or acquire in any other manner securities or other financial interestS In any jurisdiction or to provide any kind of financial service or advice.

Trail uses its best efforts in order to keep the Information contained on the Site accurate, complete and up-to-date but before the Users use the Information, the attention of the User is drawn to the following paragraphs and sections 5 and 6 of this legal notice.

Trail reserves the right, at its sole discretion, to change, modify, add or remove any portion of this Site, in whole or in part, at any time, without notice or liability.

Although Trail strives to protect the Site from viruses, it makes no warranties as to whether the Site is free from viruses. Users must take appropriate measures to protect themselves from viruses before downloading the Information.

Legal use of the Site
This Site is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) its publication or availability is prohibited. Persons in respect of whom such prohibitions apply must not access this Site.
Ownership of Site, trademarks and copyrights
“Trail and other trademarks on this Site are trademarks and service marks or registered trademarks or service marks of Trail and/or its affiliates (to be understood, for the purpose of this legal notice, with the widest meaning possible including notably Trail’s controlling persons, foreign offices, subsidiaries or branches) (referred to, together with Trail, as “Trail Group” ) or Trail Group has been authorized to use them. All material available on the Site, except where otherwise noted, is under copyright to Trail Group or Trail Group has been authorized to use them. Trail Group reserves all rights with respect to copyright, trademark ownership of all material on the Site and/or the right to use the foregoing, and will enforce such rights to the full extent permitted by applicable laws and/or regulations.

Nothing on the Site shall be construed as granting any license or right to use any image, trademark, service mark or logo. Downloading, copying or printing individual pages and/or parts of the Site is allowed for personal use only, and will not transfer title to any software or material on the Site to the User. Express prior written request for authorization must be sought from Trail Group in the event that the reproduction of any of the material or any part thereof, is contemplated and regardless of the form (written, electronic, etc.) of the said contemplated reproduction. Furthermore, any subsequent reproduction, re-publication or distribution of this material requires the express prior written consent of Trail Group.

Links towards other websites
Activating certain links on this Site may cause the User to leave this Site. Such links, addresses or hyperlinks are provided solely for User’s convenience and information. Trail has not reviewed any of the websites linked with or connected to this Site, or which provide links to this Site, and does not accept any liability for their contents, including notably any offer of products or services or any other offer. Using links from this Site to any website not owned by Trail is at the User’s own risk.

The User is not permitted to create a link targeting the Site and/or any website or material to which the Site refers without the prior written consent of Trail.

No warranty; no liability
The information on this Site is provided on an “as is”, “as available” basis, Trail makes no warranty that access to the Site will be uniterrupted or error-free, that defects will be corrected, or that viruses or other harmful comonents will not be transmitted in connection with the user’s use of the Site, Trail hereby expressly diclamis, on its behalf, on the behalf of its affiliates and of its and its affiliates’ employees, directors, shareholders and agents (together, the “”disclaiming persons””), to the fullet extent permitted by applicable laws and/or regulations, all warranties, express, statutory or implied, regarding the site and any consequences resulting from the use of the Site and its contents. The disclaiming persons do not warrant or guarantee the accuracy, timeliness, suitability, completeness or availability of this Site or the information or results obtained from the use of it,
Under no circumstances and under no theory of any applicable laws and/or regulations shall any of the disclaiming persons be liable to anyone for any damages arising in tort, contract, strict liability or otherwise from accessing or using or from the inability to access or to use this Site (including with regard to the content of the information) or from any action taken or not taken as a result of the foregoing, regardless of whether they are direct, indirect, special incidental, or consequential damages  of any character, including damages for trading losses or lost profits, or for any claim or demand by any third party, even if the relevant disclamining person(s) knew or had reason to know of the possibility of such damages, claim or demand.

Conflicts of interest
In using the Information and, more generally, the Site, the User acknowledges that he is aware and understands that:

Trail, its affiliates, its and its affiliates’ employees, directors, shareholders or agents may, to the extent permitted by applicable laws and/or regulations, participate or invest in financing transactions with any of the issuer(s) of securities referred to in this Site, and/or have a position or holding, or other material interest or effect transactions in such securities, issuers or options thereon or investments related thereto.
Trail, its affiliates, its and its affiliates’ employees, directors, shareholders or agents may, to the extent permitted by applicable laws and/or regulations, act upon or use the information or opinions it presents on this Site, or the research or analysis on which such information or opinions are based, before the material is published.

E-mail addresses and any other personal data voluntarily included by the User for identification purposes in the User’s e-mail sent to Trail, and the User’s IP address (Internet Protocol address) relating to the User’s connection to the Site are the only personal data which may be collected and processed by Trail through its Site (referred to together as the “Personal Data”).

E-mail addresses and any other personal data included by the User for identification purposes in the User’s e-mail are collected through a “mailto” link on the Site which allows the Users to send an e-mail to Trail or to one of its members. This data is collected, processed and recorded exclusively for the purpose of responding to the e-mails. A valid e-mail address must be sent to Trail in order to receive an answer (should Trail decide, in its sole discretion, to answer the said email) and any other personal data provided is optional. The Personal Data sent by e-mail are recorded and kept for a period of time consistent with the purpose of their collection and processing.

The User’s IP addresses are collected, processed and recorded by Trail exclusively for the purposes of discovering any malfunction of the Site and/or the servers where the Site is hosted, securing the Site and/or the servers where the Site is hosted and using the data for statistical purposes.

This Site uses cookies to store browsing information during the use of the Site. Cookies cannot be used to identify the Users. They, however, record information relating to the page browsing performed by the User’s computer on the Site (details of pages visited, time and date of visit, etc.) which can be retrieved at later visits.

Users may block the use of cookies by configuring their browsers in accordance with the documentation provided with the relevant software.

The Personal Data is not leased nor transferred to any third party, whether free of charge or not. The affiliates of Trail are not regarded as a third party.

Any User, upon proof of the User’s identity, has the right to request, as appropriate, the rectification, completion, updating and/or deletion of Personal Data which are incomplete, inaccurate, expired, or of data, the processing or the recording of which is forbidden.

The rights of the User referred to above can be exercised by sending an e-mail to info@trailcapital.eu or by sending a letter to the following address:

Trail Management
12 avenue Matignon
75008 Paris
France

Personal Data relating to the members of Trail which are accessible through the Site cannot be collected and/or be processed without the prior and express consent of the individual concerned. In particular, Users are not allowed to collect and process this data, whether automatically or manually, to send unsolicited commercial messages or any other kind of messages.

Governing law / jurisdiction
This legal notice is construed and shall be interpreted in accordance with French laws and regulations. The courts of France shall have exclusive jurisdiction with regard to any matter relating to this legal notice. The User acknowledges and agrees that if any part of this legal notice is or becomes illegal, invalid or otherwise unenforceable, the other parts of this legal notice shall remain binding. In such case, the User undertakes to take all necessary steps (including waiving appropriate rights) to ensure that its rights and obligations pursuant to the terms and conditions of this legal notice will be as identical as possible to the rights and obligations the User would have had should the relevant part of this legal notice has not become illegal, invalid or otherwise unenforceable.

Regulatory documents

  • Complaints processing policy:
    • TRAIL MANAGEMENT commits itself to send the client an acknowledgement of receipt within 10 days, in the event that the complaint cannot be processed more quickly. The postal address where you can send your complaint is the following address: 12 avenue Matignon, 75008, Paris
    • From the date of this acknowledgement of receipt, the request will be processed within a period not exceeding 2 months. If you are dissatisfied with the outcome of your complaint, you may appeal to the Mediator of the Autorité des marchés financiers (AMF) by filling in the mediation request form, which you can find on the AMF website: https://www.amf-france.org/fr/lemediateur-de-lamf/votre-dossier-de-mediation/vous-voulez-deposer-une-demande-de-mediation
    • The mediation charter is also available on the same website. You can contact the mediator by mail at the following address: AMF – Ms Marielle COHEN-BRANCHE AMF Mediator 17, place de la bourse 75082 PARIS CEDEX 02
  • Policy on prevention and management of conflicts of interest:
    • The conflict of interest policy adopted by TRAIL MANAGEMENT is available on request by mail at 12 avenue Matignon, 75008, Paris; and by email: alefebure@trailcapital.eu

Voting policy
TRAIL considers the exercise of voting rights to be an integral part of the management of the funds’ investments and intends to fully fulfil its role as a shareholder.
It is TRAIL’s policy, in line with the provisions of the AMF’s General Regulations, to participate in all shareholder meetings of the funds’ holdings under management, either in person or by correspondence, and to exercise the voting rights attached thereto. TRAIL is generally represented at meetings by the person responsible for the investment or by any person holding a proxy.
For further information, please contact the Management Company.

 

ESG Policy

Article 3 SFDR

Integration of sustainability risks into the investment process

Sustainability risks are considered by Trail at all stages of each product’s investment process.

Preinvestment:

  • Trail has an exclusion policy whereby they will not invest in persons or entities directly and significantly involved in the production, marketing or use of, or trade in identified activity sectors that may represent sustainability risks.
  • ESG factors (environmental, social, business ethics, governance) and growth opportunities are considered when evaluating an investment opportunity.
  • Investment team performs ESG screening to ensure consistency with Trail’s values and commitments.
  • External experts conduct ESG due diligence if necessary.
  • ESG risks and opportunities are included in investment memo presented to investment committee when Trail is a majority shareholder.

During the holding period:

  • Sustainability risks are closely monitored during the holding period.
  • Trail seeks to mitigate risks and add value through implementation of sustainability measures and participation in shareholder governance meetings.
  • Annual external assessment of ESG practices is conducted.

The sustainability risks are identified particularly using guidance from an external advisory firm using frameworks and initiatives such as the Sustainability Accounting Standards Board (SASB) framework, which identifies financially material ESG risks by activity.

 

Article 4 SFDR

Consideration of sustainable Principle Adverse Impacts (PAIs)

Trail does not currently monitor principle adverse impacts at the portfolio level. Incorporating such criteria would entail the collection and computation of numerous key indicators and data, which would represent a significant administrative burden for portfolio companies that do not have the internal resources necessary to monitor these indicators given their stage of development.

Nevertheless, Trail continues to support its portfolio companies in addressing environmental, social and governance (ESG) aspects and annually collects indicators to measure and improve sustainability practices.

 

Article 5 SFDR

Integration of sustainability in the remuneration policy

To date, Trail does not include sustainability criteria in its remuneration policy.  However, the management team plans to integrate these criteria in the future.