Legal Notice

Company Information

• This website is published by Exclusive Partners, a simplified joint-stock company with a share capital of €833,300, headquartered at 18 avenue Matignon, 75008 Paris.
  Paris Trade and Companies Register (RCS) – SIRET: 518 935 713 000 17 – APE: 7022Z
  Intracommunity VAT number: FR 25 51 89 35 713
  Legal representative of the site and publication manager: Clément Pochard

• Contact: +33 (0)1 72 28 54 71 (standard rate call) 
• Email: info@exp.fr

Legal and Hosting Information

Exclusive Partners is an Investment Services Provider (PSI) under French law, authorized by the Autorité de Contrôle Prudentiel et de Résolution (ACPR) to provide investment advice and order reception and transmission services under number 19173. Exclusive Partners is under the joint supervision of the Autorité de Contrôle Prudentiel et de Résolution (ACPR) and the Autorité des Marchés Financiers (AMF).

Exclusive Partners is registered in the Single Register of Insurance, Banking and Finance Intermediaries* under registration number 13002792, as a non-exclusive banking and payment services intermediary (MOBSP) and insurance or reinsurance broker (COA).

Exclusive Partners uses the services of tied agents duly registered in the Single Register of Insurance, Banking and Finance Intermediaries (ORIAS*), some of whom are banking and payment services intermediary agents (MIOBSP) and insurance intermediary agents (MIA), depending on the service offered. 

EXCLUSIVE PARTNERS also has the ability to provide investment services on a freedom of services (FOS) basis in a number of European countries, the list of which is available on the REGAFI website (updated regularly).

Pursuant to the MiFID II Directive, Exclusive Partners has chosen to provide "non-independent" investment advice and, as such, may receive commission retrocessions or any other monetary or non-monetary benefits from financial instrument providers under the conditions set forth in Article L.533-12-4 of the Monetary and Financial Code.

*Single Register of Insurance, Banking and Finance Intermediaries (Orias)
Postal address: 1 rue Jules Lefebvre, 75331 Paris cedex 09
Website: www.orias.fr

Site Design

Summary of the Conflicts of Interest Management Policy – Exclusive Partners

In accordance with the MiFID Directive (2014/65/EU), Exclusive Partners has established and maintains a policy for the identification, prevention, and management of conflicts of interest. The objective of this policy is to ensure that Exclusive Partners complies with applicable professional best practices and conducts its business honestly, fairly, and professionally in the best interests of its clients. 

Definition - A conflict of interest arises when a company or an individual, in the course of their professional activities, faces multiple or divergent interests (financial, personal, commercial) that could lead them to act in favor of one of these interests to the detriment of others (particularly clients). 

Persons concerned - Executives, employees, agents, and shareholders of Exclusive Partners.

Identification of conflicts - Exclusive Partners has identified several categories of potential conflicts, including: family or financial ties with clients/suppliers, the promotion of unsuitable but high-commission products, the acceptance of significant gifts that could influence decisions, the listing of products from related companies, incentives for listing products through the payment of retrocessions, and proprietary trading by employees… 

Each category of conflict is subject to a risk assessment and the identification of corresponding mitigation measures. 

Prevention measures 

To prevent and manage the risk of conflicts of interest and strengthen the trust of its clients and suppliers, EXCLUSIVE PARTNERS has implemented a robust framework that includes:

• A framework for managing conflicts of interest (including a procedure, a mapping, and a register of potential conflicts to identify the types of conflicts that may arise in the conduct of business);  
• Specific procedures (internal control charter, code of ethics, remuneration policy, information barriers / "Chinese walls" principle) need to know, watch and restricted lists, segregation of duties, procedures regarding inducements and incentives, gifts and benefits, etc.) governing the activities of EXCLUSIVE PARTNERS and aimed at preventing or managing conflict of interest situations. These procedures are reviewed at least annually.
• Regular training and awareness programs for employees and agents.
• A self-reporting system for employees and agents. 
• Ongoing monitoring conducted by the Compliance department

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Conflict Management

When organizational or administrative measures taken to avoid a conflict are insufficient to ensure with reasonable certainty that the risk of harming a client's interests will be prevented, Exclusive Partners will inform the client of the general nature and/or source of the conflict of interest, as well as the measures taken to mitigate these risks. 

Identified conflicts are recorded in a dedicated register and monitored regularly by Exclusive Partners. 

Terms of Access and Use

The site is free and open access. However, the publisher reserves the right to restrict access to all or part of the site unilaterally and without notice.
Access to the products and services presented on the site may be subject to restrictions for certain individuals or in certain countries. None of the products and/or services will be provided by Exclusive Partners to any person if prohibited by the laws of their country of origin or any other relevant jurisdiction.
It is the responsibility of any interested party to verify with their usual advisors beforehand that their legal and tax status allows them to subscribe to the products and/or services presented on the site.

Site Content

As part of its activities and in accordance with applicable regulations, Exclusive Partners may record and store telephone, electronic, or any other communications exchanged with its clients, prospects, or partners. The purposes of these recordings include providing proof of exchanges and transactions, ensuring the quality of services provided, meeting applicable legal and regulatory obligations, preventing and managing disputes, and combating fraud and abuse.

Data from these communications is intended solely for authorized personnel within Exclusive Partners, as well as its service providers or competent authorities when access is required by law or necessary to fulfill the aforementioned purposes. Data is retained for the duration strictly necessary to comply with applicable legal and regulatory obligations and, in any event, for a period not exceeding that authorized by current regulations.

Under the conditions provided for by Regulation (EU) 2016/679 and applicable legislation, the individuals concerned have the right to access, rectify, restrict the processing of, and, where applicable, object to the processing of their personal data. These rights may be exercised by contacting the Data Protection Officer or the relevant department using the contact details provided in the privacy policy.

When required by regulation, the individuals concerned are informed in advance that their communications are being recorded. No recordings are made for the purposes of profiling or automated decision-making that produces legal effects concerning them, unless otherwise specified and brought to their attention.

Hypertext Links

What is a complaint?

A complaint is a statement expressing a client's dissatisfaction with a professional. Requests for information, advice, clarification, service, or assistance do not constitute complaints.

Complaints may be submitted in writing (by mail or email) or verbally (by phone).

How do I submit a complaint?

You can:

• Fill out the online contact form 
• Call 01.72.28.54.71 (standard rate call) 
• Send your request in writing to the following postal address: 18 avenue Matignon, 75008 Paris.

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How will your complaint be handled at EXCLUSIVE PARTNERS?

Handling complaints is an important element in the trust-based relationship we have with our clients. 

We commit to sending you an acknowledgment of receipt of your complaint within 10 business days of its submission, unless a response can be provided to you within that timeframe.

A final response will be provided within a maximum of two months from the date the complaint is received, except in duly justified special circumstances.

In the event of a negative response, you will be informed of the available avenues for appeal.

If you are not satisfied with the response to your complaint

• If your complaint concerns any financial instrument, investment service, or more generally, any matter falling within the jurisdiction of the Financial Markets Authority (AMF), you may contact the Financial Markets Authority Ombudsman free of charge:

• By completing the online form on the AMF Ombudsman's website: www.amf-france.org/

• By mail by sending a standard letter to:

AMF Ombudsman

Financial Markets Authority - 17 place de la Bourse - 75082 Paris cedex 02

The AMF Mediation Charter is available on the AMF website.

This recourse does not prevent you from taking legal action if you are not satisfied with the outcome of the mediation. Referring the matter to the Ombudsman suspends the statute of limitations for civil action; it resumes once the mediation process has concluded.

• If your complaint concerns banking or insurance matters, you may send a copy of your complaint to the Prudential Supervision and Resolution Authority (ACPR), report a difficulty you have encountered, or ask a question: 

• By mail at the following address: 

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Prudential Supervision and Resolution Authority - Business Practices Supervision Directorate - 4 Place de Budapest - CS 92459, 75436 Paris 

• By email
•  https://acpr.banque-france.fr/proteger-la-clientele

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Liability

The use of this site and its information is the sole and exclusive responsibility of the user.
Consequently, the publisher, its partners, employees, or any other party involved in the creation and operation of this site cannot be held liable for any direct or indirect damage of any kind resulting from access to, use of, or interpretation of the information on this site, even in part.

Data protection and privacy

EXCLUSIVE PARTNERS has established a personal data protection policy and is committed to processing this data in a way that ensures its security, confidentiality, and integrity, and to complying with the provisions of current regulations, the General Data Protection Regulation (GDPR), and the French Data Protection Act (view our data protection policy)

CNIL Declaration

EXCLUSIVE PARTNERS, an investment services provider registered with the Paris Trade and Companies Register under number 518 935 713 000 17, with its registered office at 18 avenue Matignon, 75008 Paris, acts as the data controller for personal data collected via this website, particularly through contact, information request, or application forms. 

The collected data is processed for the purposes of responding to user requests, managing relationships with prospects, clients, partners, and candidates, ensuring compliance with our legal and regulatory obligations, and defending our rights in the event of a dispute. This processing is based, depending on the case, on the performance of pre-contractual or contractual measures, compliance with legal and regulatory obligations applicable to investment service providers, the legitimate interest of EXCLUSIVE PARTNERS, or the consent of the individuals concerned where required.

The data is intended for the authorized departments of EXCLUSIVE PARTNERS as well as its technical service providers, subcontractors, and advisors acting within the scope of their duties and limited to the intended purposes.

Unless otherwise indicated, data is not transferred outside the European Union. In the event that such a transfer becomes necessary, it will be carried out in accordance with the requirements of Regulation (EU) 2016/679 and accompanied by appropriate safeguards.

Data is kept for the time necessary to achieve the intended purposes and to comply with applicable legal and regulatory obligations. In this regard, data relating to a contractual relationship is kept for a maximum of five (5) years from the end of the relationship, while data relating to prospects is kept for a maximum of three (3) years from the last contact from the individual concerned, unless a longer retention period is required by law or by a judicial or supervisory authority.

In accordance with applicable regulations, every individual has the right to access, rectify, erase, restrict, or object to the processing of their data, the right to data portability, and the right to define directives regarding the fate of their data after their death. 

These rights may be exercised by contacting the Data Protection Officer:

• At the address RGPD@exp.fr 
• Or by mail to: Exclusive Partners – Data Protection – 18 avenue Matignon, 75008 Paris. 

Individuals also have the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL) (www.cnil.fr).

When the collection of certain data is necessary to process a request or to fulfill a pre-contractual or contractual relationship, the relevant fields are marked as mandatory. Failure to provide this information may prevent EXCLUSIVE PARTNERS from processing the request or providing the requested service. 

The collected data is not subject to any fully automated decision-making that produces legal effects for the individuals concerned, nor any profiling, unless specifically stated otherwise. Finally, should EXCLUSIVE PARTNERS intend to further process the data for a purpose other than that for which it was collected, the individuals concerned will be informed in advance in accordance with applicable regulations.

Cookie and Tracker Policy

The site uses cookies, whether or not they are necessary for the technical operation of the site, on users' devices. The information banner displayed allows visitors to accept or refuse the various categories of cookies, giving users the ability to freely, specifically, and clearly accept or refuse the placement of any tracker, without any negative consequence other than the inability to use the site's features. 

EXCLUSIVE PARTNERS, in its capacity as data controller, informs visitors in advance about the purposes of the trackers used, the categories of data collected, and any potential recipients of the data. Cookie management is handled using the Axeptio tool (French publisher Agilitation).

EXCLUSIVE PARTNERS is committed to implementing a system that complies with the provisions of Article 82 of Law No. 78-17 of January 6, 1978, as amended, Regulation (EU) 2016/679 (GDPR), as well as the guidelines and recommendations of the CNIL regarding cookies and other trackers. 

Collection of personal data

No personal data is collected or shared without your knowledge on this site.

The user authorizes the publisher to place one or more cookies related to the user's navigation on the computer they are using. These are the following cookies:

• Functional cookies: these cookies are essential for the site to function.
• Audience measurement cookies: these cookies measure site traffic and allow us to improve its functionality.
• Partner Area connection cookie: this cookie allows the User to log in to their personalized space.

Users have the option to object to the installation of cookies, particularly through the features offered by browsers such as Internet Explorer, Netscape Navigator, Mozilla Firefox, or Opera.

Users are informed that when visiting the www.exp.fr website, one or more cookies may be automatically installed on their computer. A cookie is a small file that does not identify the user but records information about a computer's navigation on a site. The data obtained is intended to facilitate subsequent navigation on the site and is also used for various traffic measurements. Browser settings can be configured to notify you of the presence of cookies and, if desired, to refuse them as described at the following address: www.cnil.fr. Refusing to install a cookie may make it impossible to access certain services. Users may, however, configure their browser to refuse the installation of cookies.

User Rights

The site was designed in France by:

Agence Norry – 22 rue du Marché – 86300 Chauvigny - France

Agencenorry.com – 0756 97 20 23

The site is hosted in the United States by Webflow, Inc., - 398 11th Street, 2nd Floor, San Francisco, CA 94103, United States – contact@webflow.com – +1 415-964-0555.

These terms are subject to French law.
In the event of a dispute regarding the application or interpretation of these terms, or more broadly regarding the use of the site by any individual or legal entity, it is expressly agreed that the French courts shall have exclusive jurisdiction, even in the event of multiple defendants or third-party claims.

Telephone Line Recordings

The site is free and open access. However, the publisher reserves the right to restrict access to all or part of the site unilaterally and without notice.
Access to the products and services presented on the site may be subject to restrictions for certain individuals or in certain countries. None of the products and/or services will be provided by Exclusive Partners to any person if the laws of their country of origin or any other relevant country prohibit it.
It is the responsibility of any interested person to verify in advance with their usual advisors that their legal and tax status allows them to subscribe to the products and/or services presented on the site.

Ownership of the Site and its Content

The information, tools, and content on the site are provided for informational purposes only.
Exclusive Partners strives to regularly update the information contained on the website. However, the company cannot be held liable for errors due to changes in legal, administrative, or judicial provisions that may occur after publication on the site. The user is solely responsible for how they use the information gathered.

Regulatory Disclosures

Hypertext links to other websites or any other existing Internet resources from this site shall in no way engage the liability of Exclusive Partners.

Liability

Use of the site and its information is the sole and exclusive responsibility of the user.
The publisher, its partners, employees, or any other party involved in the creation and operation of this site shall not be held liable for any direct or indirect damage or loss of any kind resulting from access to, use of, or interpretation of the information on this site, even in part.

Ownership of the site and its content

Protection of Site Content
All intellectual property rights regarding the site and its content (hereinafter "Content"), including but not limited to text, databases, software, applications, slideshows, logos, images, drawings, and graphics, are the property of the publisher or third parties who have authorized the publisher to use them.
All such content is protected by French and international laws, including, where applicable, copyright, design rights, trademark law, and database rights.
The names and brands mentioned on the site are trademarks registered by the publisher or its assignees. Any reproduction, imitation, or broader exploitation of these trademarks is prohibited.

Site Usage
This site is intended exclusively for the user's personal and private use. The publisher grants the user authorization to view the site only. However, the user may download or print pages and/or parts of the site strictly for personal use, provided that they do not remove any copyright or intellectual property notices.
Any other use (including reproduction, representation, modification, adaptation, or distribution for commercial or non-commercial purposes) is strictly prohibited without the publisher's prior express written consent.
As the producer and owner of all or part of the databases present or used on the site, it is also strictly prohibited, for example, to extract or use any or all of the content from the databases found on the site.

This website is published by Exclusive Partners, a simplified joint-stock company (SAS) with a share capital of €833,300, headquartered at 18 avenue Matignon, 75008 Paris.
RCS PARIS – SIRET: 518 935 713 000 17 – APE: 7022Z
Intracommunity VAT number: FR 25 51 89 35 713
Legal representative and publication manager: Clément Pochard

The site was designed in France and is hosted in France by AIMS Informatique – 68, rue de la Croix de l’Orme - 78630 Morainvilliers (contact@aims-informatique.com). These terms are subject to French law.
In the event of a dispute regarding the application or interpretation of these terms, or more broadly regarding the use of the site by any individual or legal entity, it is expressly agreed that the French courts shall have exclusive jurisdiction, even in the event of multiple defendants or third-party claims.

The site was developed by Agence Norry

The information, tools, and content on this site are provided for informational purposes only.
Exclusive Partners strives to regularly update the information on the website. However, the company cannot be held liable for errors due to changes in legal, administrative, or judicial provisions that may occur after publication on the site. Users are solely responsible for how they use the information gathered.

Hypertext links to other websites or any other existing Internet resources from this site shall in no way engage the liability of Exclusive Partners.

In accordance with the French Data Protection Act of January 6, 1978, Exclusive Partners has declared the collection of information on this website to the CNIL.

Users have the right to access, rectify, and delete their personal data, as well as the right to object to its processing. To exercise these rights, please contact the company by mail, accompanied by a copy of an identity document, at the following address: Exclusive Partners – Data protection – 18 avenue Matignon, 75008 Paris. Or by email at RGPD@exp.fr.
Under no circumstances will information collected on the site be shared with third parties.

To ensure transparency in transactions concluded under the authorizations and licenses granted to Exclusive Partners, telephone conversations with our departments are recorded. In accordance with the General Data Protection Regulation (GDPR), you have the right to access, rectify, and object to the processing of your recorded data by contacting the company by mail, accompanied by a copy of an identity document, at the following address: Exclusive Partners – Data protection – 18 avenue Matignon, 75008 Paris. Or by email at RGPD@exp.fr.

Protection of Site Content
All intellectual property rights regarding the site and its content (hereinafter "Content"), including but not limited to text, databases, software, applications, slideshows, logos, images, drawings, and graphics, are the property of the publisher or third parties who have authorized the publisher to use them.
All such content is protected by French and international law, including, where applicable, copyright, design rights, trademark law, and database rights.
The names and brands mentioned on the site are trademarks registered by the publisher or its assignees. Any reproduction, imitation, or broader use of these trademarks is prohibited.

Use of the Site
This site is intended exclusively for the user's personal and private use. The publisher grants the user authorization to view the site only. The user may, however, download or print pages and/or parts of the site strictly for personal use, provided that they do not remove any copyright or intellectual property notices.
Any other use (including any reproduction, representation, modification, adaptation, or distribution for commercial purposes, whether for profit or not) is strictly prohibited without the prior express written consent of the publisher.
As the producer and owner of all or part of the databases present or used on the site, it is also strictly prohibited to extract or use any or all of the content of the databases appearing on the site.

Legal Status – Regulatory Information
Exclusive Partners is an Investment Services Provider (ISP) under French law, authorized by the Prudential Supervision and Resolution Authority (ACPR) on January 15, 2010, to provide investment advisory services under number 19173. In accordance with the MiFID II Directive, Exclusive Partners has chosen to provide "non-independent" investment advice and, as such, may receive commission retrocessions or other monetary and non-monetary benefits from financial instrument providers under the conditions set forth in Article L.533-12-4 of the Monetary and Financial Code.
Since April 18, 2012, this authorization has been extended to include order reception and transmission services. Exclusive Partners is under the joint supervision of the Prudential Supervision and Resolution Authority (ACPR) and the Financial Markets Authority (AMF), whose addresses are as follows:

Prudential Supervision and Resolution Authority (ACPR)
Postal address: 4 Place de Budapest CS 92459, 75436 Paris
Website: acpr.banque-france.fr

Financial Markets Authority (AMF)
Postal address: 17 place de la Bourse, 75082 Paris Cedex 02
Website: www.amf-france.org

Exclusive Partners is a member of the French Financial Markets Association (AMAFI).

Exclusive Partners is registered in the Single Register of Insurance, Banking and Finance Intermediaries under registration number 13002792, as a non-exclusive agent for banking operations and payment services (MOBSP) and as an insurance or reinsurance broker (COA).
Exclusive Partners uses the services of Tied Agents duly registered in the Single Register of Insurance, Banking and Finance Intermediaries (formerly recorded in the Banque de France's file of Tied Agents).
Exclusive Partners also uses the services of banking and payment service intermediary agents (MIOBSP) and insurance intermediary agents (MIA), depending on the service offered. These agents are duly registered in the Single Register of Insurance, Banking and Finance Intermediaries.
Single Register of Insurance, Banking and Finance Intermediaries (Orias)
Postal address: 1 rue Jules Lefebvre, 75331 Paris cedex 09
Website: www.orias.fr

Conflict of Interest Management
In the interest of transparency, Exclusive Partners wishes to inform potential subscribers that the financial products it has selected and for which it provides investment advisory services may be subject to conflicts of interest.
The conflict of interest management policy is available upon request by emailing info@exp.fr.

Best Selection Policy
This policy addresses the best selection principles implemented by Exclusive Partners regarding subscriptions received for marketed products and cash management investments.
In accordance with current regulations, Exclusive Partners has defined its best selection policy to ensure that its clients benefit from the best selection of intermediaries executing these operations.

1- General Provisions

In accordance with the provisions of Articles 314-69 et seq. of the AMF General Regulation, investment service providers must take all reasonable measures to obtain the best possible result for their clients when executing orders, taking into account specific criteria. This is the principle of "best execution," which requires the implementation of an execution policy.
Investment service providers that, like Exclusive Partners, transmit orders received from their clients to other entities for execution as part of the order reception and transmission service must comply with the obligation to act in the best interests of their clients. The principle of "best execution" therefore takes the form of "best selection" here, which consists of selecting, for each class of financial instruments traded, the entities to which orders are transmitted for execution.

2- Consequences for its "best execution / best selection" obligations

Exclusive Partners is subject to a "best selection" obligation, which stems from the "best execution" requirement. Specifically, Exclusive Partners guarantees the best execution of orders received from its clients in the context of order reception and transmission (RTO) by incorporating qualitative and quantitative best execution criteria into its selection process, such as:
– the price of the traded financial instrument,
– the cost of execution,
– the speed of execution,
– the liquidity of the execution venue,
– the size and nature of the order,
– the probability of execution and settlement/delivery of the order.

Internal procedures are in place to ensure the prompt and fair execution of orders in the best interests of clients. These procedures stipulate that orders are recorded and processed by Exclusive Partners with speed and precision.
Exclusive Partners is committed to selecting market intermediaries that ensure the security of its clients' transactions. Settlement/delivery and total cost are generally the most significant factors.
Regarding subscription or redemption orders for UCITS, the concept of "best possible result" is limited to ensuring that subscriptions and redemptions of units and shares are carried out according to the terms specified in each UCITS prospectus.
Regarding structured products, the concept of "best possible result" is limited to ensuring that the investment is made according to the terms specified in the product's term sheet.
Furthermore, Exclusive Partners regularly monitors the effectiveness of its order execution framework to identify and address any potential shortcomings. The company will inform its clients of any significant changes to its "best execution/best selection" policy, notably by publishing them on the company's website.
The evaluation of market intermediaries results in a report and may lead to the removal of an intermediary from the list and/or the addition of new ones.

Complaints
For any complaints, reports of abuse, or intellectual property rights violations, you may call 01.72.28.54.71 (standard rate call) or send a letter to 18 avenue Matignon, 75008 Paris.

Exclusive Partners is committed to:

If you are not satisfied with the response to your complaint and your complaint concerns any financial instrument, investment service, or more generally, any matter falling under the jurisdiction of the Autorité des marchés financiers (AMF), you may contact the AMF Ombudsman free of charge by mail at 17, place de la Bourse 75082 Paris cedex 02, or via the electronic form available on the AMF website: www.amf-france.org.

If you are dissatisfied with the outcome of your complaint regarding banking or insurance services and wish to send a copy of your complaint to the Autorité de contrôle prudentiel et de résolution (ACPR), report a difficulty, or ask a question, you may contact the ACPR free of charge by mail at Autorité de contrôle prudentiel et de résolution – Direction du contrôle des pratiques commerciales – 4 Place de Budapest CS 92459, 75436 Paris, or online at (https://acpr.banque-france.fr/proteger-la-clientele/grandpublic-vous-etes-un-particulier/formuler-une-reclamation-vis-vis-dun-professionnel).