Legal Notices
The legal notice includes information about the publisher, host, copyright, privacy policy, and terms of use.
Legals
In accordance with article 6 III-1 of French Law No. 2004-575 of 21 June 2004 regarding confidence in the digital economy, we inform users that:
- This website is the property of REED MANAGEMENT SAS, a French société par actions simplifiée with capital of EUR 4,000,000 registered with the “Paris Registre du Commerce et des Sociétés” under number 949 366 363, and whose headquarters are located 15 rue soufflot, 75005 Paris, France.
- REED MANAGEMENT SAS is registered as a management company with the AMF under number GP 2023 0019.
- This website is governed by French law.
- E-mail : contact@reed-management.com
- This website is hosted by: OVH, 2 rue Kellermann - 59100 Roubaix - France, +33 (0)8 203 203 63
- Head of publication: Julien TOUATI, CEO (président) of REED MANAGEMENT.
Reed SHIFT SLP
Reed SHIFT SLP is an investment fund for which the subscription of the shares is reserved to professional clients within the meaning of the European Directive 2014/65/UE.
While part of Societe Generale Group, Reed Management is the sole owner of this website and acts on its own behalf in respect of any information published on this website.
Regulatory information
Conflict of interest policy
Reed Management has adopted a conflict of interest management policy in accordance with the applicable legal framework. In this respect, Reed Management maintains and operates organisational measures with a view to take reasonable steps designed to identify, prevent, manage and / or monitor conflict of interest aiming to ensure the primacy of the interests of the investment funds it manages (the “Funds“) and their underlying investors.
Identifying conflict of interest
A confict of interest situation may arise when the interests of several persons are, directly or indirectly, in competition. Reed Management takes all reasonable steps to identify conflict of interest that may arise, as the case may be, in the course of managing the Funds between:
- Reed Management, including its directors, officers, employees or any person directly or indirectly linked to Reed Management by control, and a Fund managed by Reed Management or its underlying investors;
- a Fund or its underlying investors, and another Fund or its underlying investors; or
- a Fund or its underlying investors, and another client of Reed Management.
Reed Management’ compliance and internal controller (Responsable de la Conformité et du Contrôle Interne) is in charge of assessing situation where a conflict of interest may arise. In particular, Reed Management has processes in place aiming at detecting and monitoring situations where Reed Management or its related persons is likely to receive some advantage at the expense of a Fund, its investors or clients, or is in a situation where interests of different Funds, investors or clients might be in competition.
In this context, Reed Management has established organizational and administrative arrangements aimed to limit the risk of conflict of interest in the normal course of business, including the following measures :
- Investment allocation: rules of allocation are implemented to allocate, as the case may be, the investment opportunities among the Funds;
- Risk mapping: a risk mapping identifying potential conflict of interests has been drawn up and is periodically updated;
- Employees training and awareness: the relevant employees are periodically trained on Reed Management ‘ policies, the regulatory and legal requirements for preventing and identifying conflict of interest;
- Gift & benefits: the receipt of gifts or similar benefits from business relationship is limited and monitored; and
- Personal dealing: Reed Management’ employees are subject to disclosure obligations and restrictions in relation to their personal transaction in the financial markets.
Managing conflict of interest
For each case identified, the conflict of interest procedure provides a course of action and measures to be taken in order to manage a conflict of interest when it arises.
Where Reed Management organisational or administrative arrangements are considered by Reed Management not sufficient to ensure with reasonable confidence that the risks of damage to the interests of a Fund or its underlying investors resulting from a conflict of interest are prevented, Reed Management will inform the concerned investors of the general nature and/or source of the conflict of interest.
These situations, if they occur, are recorded in a conflict of interest register maintained by Reed Management.
Client complaint management policy
Reed Management drawn up and operates a specific procedure in order to manage client complaints, in accordance with the applicable legal framework.
Definition of ‘Client complaint’
A Client complaint is defined as a claim from a client in one or several funds managed by Reed Management caused by its dissatisfaction with the investment service provider. A request for information, advice, clarification or service is therefore not considered to be a complaint and will not receive a response should you use this channel.
How to send your complaint?
You are able to send a complaint relative to investment services provided by Reed Management or relative to a subscription into a fund managed by Reed Management. You can contact your usual investor relations representative or use the dedicated email address:
Email: complain@reedinvest.com
Postal Address: Reed Management, 15 rue soufflot, 75005 Paris, France.
Processing your request
Once your complaint has been submitted, you will be issued:
- a confirmation of receipt within 10 working days, unless the answer is provided to you in the meantime;
- an answer within 2 months of submission of your complaint (unless duly justified circumstances require a longer period).
Processing of your request will be free of charge. We will respond to any request for information on the processing of your claim.
Contact the “Autorité des Marchés Financiers (AMF)” ombudsman
In the event of the answer provided by Reed Management not meeting your expectations, you are also able to contact the AMF Ombudsman using the following link: www.amf-france.org, or write to the following address: Médiateur de l’AMF, Autorité des Marchés Financiers, 17 place de la Bourse, 75 082 Cedex 02, France.
Additional information on the Mediation Charter are available on the AMF website.
Terms and conditions of Use
This website is intended to users who are at least eighteen (18) years old.
By using this website, you confirm that you are at least eighteen (18) years old, and you agree to these Terms and Conditions of Use (the “Terms”), which constitute a legal agreement between you and Reed Management governing your access to and use of the Website.
It is your responsibility to review the Terms and to make sure you understand and comply with them. Your compliance with the Terms is an ongoing condition to your use of the Website, and you may not use it if you are not prepared to comply with all of the Terms.
If you are a “Registered User” benefiting from a personal access to the dedicated investor portal accessible from the Website and hosted by Intralinks, Inc.’s (the “Investor Section”), you shall in addition comply with the provisions specifically dedicated to Registered Users set out herein and through the Investor Section.
Purpose of the Website
The purpose of this website is to present general information about the activities of Reed Management.
The information on the Website shall not be regarded as information of a contractual nature and nothing on the Website should be construed as an offer, recommendation, invitation or solicitation or any substitute for any form of advice or recommendation in relation to any services or products of Reed Management or any fund it manages, and generally should not form the basis for entering into any transactions, services or other legal arrangements.
Nature of the information provided on the Website
While Reed Management seeks to present information on the Website in a manner that it believes to be reliable, the information provided on the Website is provided “as is” and for information purposes only and shall not be relied upon. As a result, the users shall take all steps to verify the fairness, completeness, accuracy, quality and suitability of any and all information accessible on the Website.
Reed Management may update, complete, correct or revise contents of the Website at any time without notice, but is under no obligation to do so.
Liability
Reed Management makes no representation and accepts no liability or responsibility to you or any other party in relation to the Website, including in respect of the fairness, completeness, accuracy, quality or continued availability of any contents on the Website. Any and all warranties of any kind, express or implied, including without limitation warranties of merchantability, fitness for a particular purpose, title or non-infringement, are excluded to the fullest extent permitted under applicable law in respect of Reed Management, its directors, officers, employees, external advisers, affiliates and affiliated funds.
You agree to indemnify, defend and hold harmless Reed Management from and against all claims, liabilities, demands, damages, losses or expenses, including notably legal fees and costs, resulting from or arising out of your improper access to or use of the Website and/or any breach of these Terms attributable to you.
Local regulations
The laws and regulations of the country from which you access the 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. Access to products / services of Reed Management may be restricted and therefore not provided should these products be unlawful in your resident country. You shall be obliged to inform yourself in this respect of and to observe any such restrictions. As a consequence, none of the services and products of Reed Management target persons from countries which prohibit those services and products: Each person or entity interested by subscribing products/services should assess with their own advisor whether their legal and fiscal status allows it.
Warning for “US" person
Reed Management is not registered as broker-dealer in accordance with US Securities Exchange Act of 1934 as amended (the “1934 Act”), nor in accordance with any other US applicable law. Furthermore, financial instruments which may be subscribed via this website are not registered, unless otherwise specified, in the US with the Securities Exchange Commission (“SEC”).
Accessibility and use of the Website
The Website is provided “as is” and accessible according to its availability. Reed Management endeavours to ensure that the proper functioning of the Website. However, Reed Management does not provide, and expressly excludes, any guarantee regarding the right to access this Website or the fact that it is free of errors, viruses and/or malicious codes of any kind.
When using Website, you undertake not to:
- make available viruses or other technologies likely to harm Reed Management or the interests or property of Reed Management’ users;
- use robots, scraper or even use any other automatic process to access the functionalities of Website without being authorised to do so;
- copy, modify or distribute Website content;
- copy, reproduce, reverse engineer, modify, create derivative works, distribute or disclose to the public any content (except for your own information) from Website without the express prior written consent of Reed Management or, if applicable, that of the relevant third parties;
- collect, accumulate, transmit to other media, make public, publish or disclose data relating to the other users of Website or concerning their activity on Website;
- accessing or attempting to access the Investor Section if you do not or no longer qualify as Registered User.
Intellectual property rights
This entire website is governed by French and international legislation on copyright, trademark and database law and intellectual property in general, both as they are applicable to its form (editorial choices, layout, topics, means for accessing data, display, etc.), and to its content (text, images, etc.).
Any reproduction, representation, diffusion or re-diffusion, in whole or in part, of the contents of this website on any medium or by any means whatsoever (including, but not limited to, caching, framing), as well as any sale, resale, retransmission or any other act tending to make such contents available to any third party in any manner whatsoever shall be prohibited, except preliminary written authorization of the publication manager. Failure to comply with these restrictions shall constitute a forgery engaging the civil and criminal liability of the forger.
Only the paper reproduction is authorized under conditions of a use in strictly personal purposes, a respect for the integrity of the reproduced documents, or in short quotation with clear and readable mention of the source, for example under the following form " Extracts from the site xxx. All rights reserved Reed Management.
The trademarks quoted on the site are protected: their reproduction or use is forbidden.
Links to third party websites
This Website may display links redirecting to pages and websites published by third parties. In this respect, please note that Reed Management neither has any control over the content published by such third parties nor monitors such content.
You are hereby invited to read the terms and conditions governing third party websites you access after clicking on hypertext links displayed on the Website.
Reed Management shall not be liable for the hypertext links towards other websites, and particularly for the contents of the linked websites.
Reed Management shall not be liable for the hypertext links towards this website.
Link by third parties to this Website
Links redirecting to the Website are only allowed subject to the express prior written consent of Reed Management.
Assignment
Reed Management reserves the right to assign all or part of its rights and obligations under these Terms to any third party of its choice.
Severability
In the event any part of these Terms is found to be unenforceable or invalid by a competent court, such decision shall not invalidate or void the remaining provisions thereof.
Electronic communications
In accordance with the provisions of Articles 1365 and subsequent of the French Civil Code, you acknowledge and agree that information exchanged between you and Reed Management in electronic format (notably by email) shall be deemed valid means of proof, equivalent to information in paper format.
Governing law and jurisdiction
Use of this Website is governed by French law. Any complaints or disputes relating to the Website or its use, shall be subject to the exclusive jurisdiction of the competent courts of Paris (France).
Data privacy policy
In accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and the French Data Protection Act No. 78-17 of 6 January 1978 as amended, and its related texts, (together “French Data Protection Legislation”), Reed Management respects the privacy of the users of this website (the “Website”) and their personal data.
The following paragraphs explain how Reed Management, as data controller, uses the data collected through this Website.
You will find further information on how Reed Management processes personal data in the context of its business and their rights under the GDPR in Data Privacy Notice which can be found at the following link: GDPR Compliance Policy for Reed Management SAS. You are encouraged to carefully read this notice before using this Website.
How do we process your personal information on this Website?
Reed Management primarily uses personal data to provide this Website to users and to ensure the proper functioning and security of the Website.
In particular, Reed Management processes the following types of personal data: name, e-mail address, telephone number, IP address any other information that is provided by you in relation to any subscription or when you visit this Website or contact Reed Management. This information may be obtained from completed forms, incoming e-mails and inquiries about our products or services but not exclusively.
This processing is carried out for administrative and marketing purposes. The legal basis for the processing is the legitimate interest of Reed Management to communicate with its clients, investors and third parties in the operation of its business and to ensure that the Website is tailored to the needs of users and provides secure environment in which to do so.
How and why we share personal information?
Personal information is accessible to all Reed Management’ staff and may also be communicated to Reed Management’ service providers who act as subcontractors, in particular those in charge of carrying out communication, marketing and distribution operations for the products and services offered by Reed Management, as well as those in charge of supplying networks, IT tools and IT services.
Security
Whilst Reed Management will take all reasonable steps to protect your personal information, Reed Management cannot guarantee the security of personal information disclosed online, and you accept the inherent security implications of disclosing personal information online.