Conflict of Interest Policy

BlueIMvest carries out the activities of:

• Investment adisory,
• AIF management within the meaning of Directive 2011/61 / EU (below the thresholds and not wishing to opt to the application of the AIFM Directive)
• Real estate investment advisory,

The people affected by the risk of conflicts of interest are as follows:

• the managers of BlueIMvest,
• the asset managers,
• BlueIMvest employees,
• the shareholders of BlueIMvest or companies linked to one or more of the shareholders of BlueIMvest,
• external service providers to whom the essential functions are delegated (auditor, legal function, compliance and internal control functions, evaluators, etc.),
• investors.

With a view to identifying potential conflicts of interest, the management company must take into account the possibility that it itself, or one of the vehicles it manages, or one of its employees or one of the “data subjects” or a related company, is in one of the situations listed below (and without this list being exhaustive):

• Realisation of a financial gain or elimination of a financial loss at the expense of one of the managed vehicles;
• Interest in the result of a service provided or a transaction carried out on behalf of one of the managed vehicles different from the interest of the managed vehicle or the partner company;
• Perception by a person other than the managed fund of a benefit in relation to the service provided to the managed fund, in any form whatsoever, other than the commission or fees normally charged for this service;
• Incentive, for financial or other reasons, to favor the interests of one of the managed OPCIs (or group funds) over the interests of one or more other managed vehicles;

BlueIMvest has drawn up a map of the different situations that may be or be perceived as conflicts of interest.

These risks of conflicts of interest concern:

• Gifts and advantages;
• The remuneration of the persons concerned;
• Privileged links;
• The simultaneous exercise by the persons concerned of functions with divergent interests;
• Belonging to a group, dependence and financial relationship;
• The rules for the distribution of assets;
• The rules of co-investments;
• Transactions between vehicles;
• The valuation of assets;
• Transactions for own account or for employees.

For each source of conflict of interest there is a corresponding prevention system as well as 1st and 2nd level control procedures implemented.

The risk classification is updated periodically. The identification of potential conflicts of interest allows BlueIMvest to implement preventive measures, in order to prevent their occurrence.

In order to prevent situations of possible conflicts of interest, BlueIMvest has implemented a policy and a system enabling it to carry out its activities independently and with respect for the primacy of the interests of its clients. This policy is based on:

• A code of ethics,
• A body of procedure and associated controls,
• Known and disseminated procedures in order to provide transparency in situations likely to be perceived as conflicts of interest,
• A risk mapping of conflicts of interest,
• Employee awareness of the primacy of customer interests,
• The honest, loyal and professional behavior of employees in order to best serve and protect the interests of clients,
• Competition between service providers,
• A framework for potential conflict of interest situations related to group membership.

BlueIMvest must manage conflicts of interest in order to avoid any violation

(1) of its obligations towards Customers and

(2) applicable laws and regulations.

In response to a conflict of interest, BlueIMvest may:

• refuse to act: in certain situations, often situations involving a risk of a particularly critical conflict of interest, BlueIMvest will not carry out (or withdraw from) the operation, or one of the operations, generating the conflict of interest.
• accept the conflict of interest but prevent any significant abuse of this situation and protect the Client, or
• disclose the conflict of interest or obtain the appropriate waiver or consent from the Client.