Legal notices and regulatory information
The website www.stabiho.com is for information purposes only. All information available on this website is provided for indicative purposes only. It is not a transactional website.
Under no circumstances does the information published on this site represent an offer of products or services that may be considered as a public investment offering or a canvassing or solicitation activity for the sale of UCITS. It does not constitute legal or tax advice and has no legal or contractual value. Any information herein may be changed without notice.
The products on this website may only be subscribed for in a jurisdiction where their marketing and promotion are authorised. All interested persons are advised to first ensure that they are legally authorised to subscribe for the products and/or services presented on this website.
Past performance is no guarantee of future performance and is not constant over time.
Legal information about the company
STABIHO INVESTMENT PARTNERS SAS is a French simplified limited company (société par actions simplifiée) with share capital of €500,000, with its registered office at 73 rue Vaugirard, 75006 Paris, France. The company is registered in the Paris Trade and Companies Register under no. 922 351 234 and approved by the French financial markets authority (Autorité des Marchés Financiers - AMF) on February 20th, 2023 as a portfolio management company under no. GP-2023004.
Email address: contact@stabiho.com
Intellectual property rights (copyrights)
This site is the property of Stabiho Investment Partners. Any total or partial reproduction of this site’s content, including logos, photographs, design elements, analyses, information, data, prices, evaluations, etc. is prohibited, subject to the prior written consent of Stabiho Investment Partners.
Regulatory information
Complaints management
Only requests for customer complaints against Stabiho Investment Partners are concerned. A complaint can be defined as being a statement recording the dissatisfaction of a client or a unitholder/shareholder. Requests for information, opinions, clarifications, services, services are not complaints.
Complaints can be sent to Stabiho Investment Partners:
- By letter to: Stabiho Investment Partners - 73 Rue Vaugirard - 75006 PARIS ;
- By email: bhottin@stabiho.com.
Stabiho Investment Partners ensures to send the client an acknowledgment of receipt within a period of 10 working days, unless the answer is provided within that timeframe. From the date of sending, the request will be processed within a period which may not exceed 2 months.
In case of dissatisfaction with the follow-up given to your complaint, you can appeal to the Ombudsman of the Autorité des Marchés Financiers at the following address :
AMF Ombudsman
Autorité des Marchés Financiers
17 place de la Bourse
75082 PARIS CEDEX 02
A mediation request form is also available on the AMF website:
The procedures are confidential, free and non-binding. Either party may terminate it at any time and retains the right to go to court.
However, before contacting the AMF Ombudsman, it is necessary that the client has first raised his/her complaint to the person in charge of complaints within Stabiho Investment Partners.
Conflict of Interests
Stabiho Investment Partners has formalized a conflict of interest management policy and implemented specific provisions in terms of organization (means and procedures) and control in order to prevent, identify and manage conflict of interest situations that may damage to the interests of its clients
However, if any conflicts of interest arise, they will be managed in the interest of the client, i.e. fairly and by providing him with complete and appropriate information.
It is recalled that Stabiho Investment Partners is an independent management company in the exercise of its activities.
Carry out the activity or operation insofar as the organization makes it possible to appropriately manage the situation of potential conflict of interest
- Carry out the activity or operation insofar as the organization makes it possible to appropriately manage the situation of potential conflict of interest;
- Inform the client in the event that certain conflicts of interest may subsist and provide him with the necessary information on their nature and origin;
- Where applicable, not to carry out the activity or operation leading to a conflict of interest.
Stabiho Investment Partners must manage any conflict of interest, from its detection to its appropriate treatment. As such, Stabiho Investment Partners has set up an organization to:
- Prevent the appearance of conflicts of interest, by raising awareness among all its staff of the rules and codes of good internal and market conduct, and by implementing strict rules and procedures:
- implementation of an internal control system;
- separation of functions that could generate potential conflicts;
- constantly ensure that the range of products and services that Stabiho Investment Partners offers its clients corresponds to the profile and their expectations, and is never in contradiction with their interests;
- recording of telephone conversations from principals of Stabiho Investment Partners;
- prohibition of personal transactions that do not respect the rules set by the company;
- training or raising awareness of all staff on good practices in the profession;
- Identify situations of conflicts of interest that could harm the interests of clients, by establishing a risk map of these conflicts of interest. This mapping specifies activities or operations for which a conflict of interest is likely to occur. The manager – RCCI of Stabiho Investment Partners is responsible in particular for ensuring that this mapping is updated;
- Manage potential conflict of interest situations:
- by fully and objectively informing customers, refraining from using tendentious arguments while pointing out the constraints and risks associated with certain products or certain operations;
- by requiring employees to declare to the manager – RCCI the gifts and benefits received according to the rules set by Stabiho Investment Partners as well as, as soon as they arise, any conflict of interest situations in which they may find themselves, if applicable.
Our conflict of interest prevention and management policy is available at the headquarters of STABIHO INVESTMENT PARTNERS in its full version and can be communicated to any client or prospect who requests it by email to: contact@stabiho.com.
Remuneration Policy
Stabiho Investment Partners remunerates fairly and in a consistent manner the work provided by all its employees while keeping the sustainability of the management company as a priority. Thus, the elements of remuneration will be made with due respect for the financial health of the company and will not put it at risk.
As such, the fixed compensation is in line with the position, level of responsibility and experience.
Variable remuneration will initially depend on the resources available, i.e. these will depend on the company's results and its capital requirements. Then it will be determined by a number of criteria defining collective and individual performance both from a quantitative point of view, such as fund performance, assets raised from clients or compliance with legal and regulatory constraints, client satisfaction; than qualitative, for example good understanding and the ability to work as a team.
Under no circumstances should the variable part of the remuneration lead employees to take inappropriate risks likely to harm the interests of Stabiho Investment Partners and/or its clients.
Stabiho Investment Partners' Remuneration Policy is available in hard copy upon request.
Best Selection
The purpose of the counterparty selection policy is to select the brokers and counterparties that Stabiho Investment Partners uses in order to obtain the best possible result for its clients.
The criteria selected take into account the specificities of the markets considered, particularly in terms of trading conditions, and will be based, among other things, on the following non-exhaustive list:
- Quality of execution
- Counterparty's financial position
- Quality of administrative processing
- Compliance with LCB-FT rules
- Quality of the overall relationship with the intermediary, including the quality of market information
- Cost and security of settlement/delivery and quality of post-trade processing
- Execution cost and price.
Monitoring of the quality of counterparties is done on an ongoing basis and a periodic review of the above criteria takes place once a year.
The complete best selection, execution and research policy is available upon request.
Proxy Voting Policy
As a long-term shareholder, Stabiho Investment Partners is aware of the need to exercise its voting obligations. Challenging certain negative behaviors of companies, and approving other positive ones, through voting at meetings, helps to improve the value of portfolio investments over time.
At the same time, the experience of Stabiho Investment Partners indicates that, too often, shareholder votes are done automatically and are for the sole purpose of fulfilling a regulatory obligation or a commitment to clients. Thus, the votes do not reflect the convictions of managers with in-depth knowledge of the issues, but rather a schematic behavior based on a too vague analysis by a third party. Stabiho Investment Partners believes that in many cases, the ill-informed and nonchalant shareholder would do better to abstain from voting the resolutions of which he does not have sufficient understanding. This is particularly true in the emerging world with significant geographical heterogeneity where local specificities can lead to poor interpretations of resolutions by foreign investors.
Stabiho Investment Partners undertakes to participate in the votes if and only if it thinks it has sufficient knowledge to speak out with conviction and will do its utmost to participate in as many votes as possible from the companies held in its portfolio.
Stabiho Investment Partners will vote by proxy. In certain circumstances, proxy voting may prove impossible, in particular when this service does not exist for certain emerging countries or when the voting notice was sent with too short a notice to allow Stabiho Investment Partners to vote. When voting by proxy in certain markets, Stabiho Investment Partners may be limited by issues specific to the country or the company concerned. For example, some portfolio companies may impose a maximum number of proxies that an outside shareholder can control. Others require that all resolutions proposed at the board meeting be voted on by a show of hands, rather than a secret ballot. Market access products, which can be used by Stabiho Investment Partners managers to gain exposure to certain difficult-to-access markets, do not give these holders the right to vote. These restrictions may have the effect of substantially limiting Stabiho Investment Partners' ability to participate in votes.
In its voting policy, Stabiho Investment Partners will rely on the following principles:
1/ act in the exclusive interest of long-term shareholders
2/ ensure that the company concerned respects all the stakeholders in its ecosystem
3/ ensure that the company concerned acts in accordance with the laws and governance regulations in force
4/ promote strong entrepreneurial and societal ethics
mong the resolutions submitted to the vote, Stabiho Investment Partners will focus in particular on:
- decisions leading to a modification of the articles of association,
- approval of accounts, payment of dividends and decisions to buy back own shares,
- the appointment and dismissal of corporate bodies,
- corporate governance issues with particular emphasis on the existence of checks and balances,
- mergers and other corporate restructurings,
- changes in capital structures, including capital increases and decreases and the issuance of preferred shares, material stock options,
- management compensation or questions relating to incentive plans,
- social and corporate responsibility considerations.
To support its decision, Stabiho Investment Partners may refer, if necessary, to the main recommendations of the AFG or to the services of providers. However, it is specified that the Management Company remains free to vote.
Stabiho Investment Partners is guided at all times by the sole interest of the shareholders to the exclusion of any other consideration.
In all cases, Stabiho Investment Partners keeps track of all its decisions.
Extra-financial elements
Stabiho Emerging Markets does not formally take ESG criteria into account in its investment policy. However, we take into account extra-financial criteria. Indeed, Stabiho Investment Partners' investment decisions are mainly based on considerations related to the company's activity and its financial aspects but extra-financial issues are also part of our' investment process without, however, being formally documented. Stabiho Investment Partners takes into account non-financial, environmental, social or governance aspects if these are likely to have a significant impact on the financial situation, present or future, of a company or come into conflict with the laws or applicable regulations. This approach allows Stabiho Investment Partners to take into account the appropriate risks, to make a balanced judgment on the investment opportunity and to act in the best interest of its clients.
Stabiho Investment Partners is a long-term investor determined to minimize the risk of loss of capital for its clients. It therefore attaches great importance to the stability and solidity of the earnings of portfolio companies over time. Companies that do not respect their respective ecosystems, by 1/violating labor laws or disregarding their employees, 2/being nonchalant in the face of environmental issues, 3/transgressing the rights of minority investors or any other laws or regulations concerning them, will suffer ultimately a fall in their rates of return or will be exposed to financial penalties, which would lead to a reduction in their profits, a development contrary to that sought by Stabiho Investment Partners. Companies that do not respect extra financial elements cannot excel in the long term and are therefore unlikely to become potential investments.
Stabiho Investment Partners draws the attention of shareholders, current or future, to the fact that the emerging nature of its investments implies a diversified and heterogeneous geographical exposure. Developing countries may in fact have weak or little independent legal frameworks, which weakens their sensitivity to social, environmental or governance issues. The extra-financial elements will therefore have to be judged in this sensitive context, taking into account the specificities of each country and its own legal and regulatory framework. The managers of Stabiho Investment Partners cannot replace local authorities or fight against them. Only the latter can force companies to adopt a more responsible behavior.
Finally, we recall that, having regard to the regulatory provisions set out in article 4 of the SFDR regulation, Stabiho Investment Partners has chosen, at this stage, not to take into account the principal adverse impacts of investment decisions in terms of sustainability risk (PAI).