Regulatory information
Bathys Asset Management
AMF-authorised management company, no. GP-20260013
Last update: 24 August 2026
Bathys Asset Management is a portfolio management company authorised by the Autorité des marchés financiers on 13 August 2026 under no. GP-20260013. It manages investment funds whose access conditions and characteristics are set out in their respective legal documentation.
The policies summarised below are formalised in the company's procedural corpus. Their full version is provided free of charge upon request addressed to the Compliance and Internal Control Officer (CICO): contact@bathys-am.com.
1. Handling of complaints
Any complaint may be sent to complaints@bathys-am.com, or by post to the registered office for the attention of the Chief Compliance Officer, who ensures its centralisation and follow-up.
In accordance with Article 318-10 of the AMF General Regulation and applicable AMF doctrine, an acknowledgement of receipt shall be sent within ten working days, unless a response is provided within that period, and a response shall be provided within a maximum period of two months from receipt of the complaint, except in duly justified special circumstances.
In the event of a persistent disagreement, the AMF Ombudsman may be referred to free of charge: Autorité des marchés financiers, Médiateur, 17 place de la Bourse, 75082 Paris Cedex 02, www.amf-france.org/en/the-ombudsman.
2. Prevention and management of conflicts of interest
Bathys Asset Management has put in place a conflicts of interest prevention and management policy proportionate to its size, organisation and the nature of its activities, in accordance with Articles 318-12 et seq. of the AMF General Regulation.
This mechanism is based on a mapping of situations likely to generate a conflict, rules for the separation and independence of management decisions, a register kept by the compliance officer for investment services (RCCI) and periodic checks. Where a conflict cannot be avoided, it is managed in the exclusive interest of the unitholders, where appropriate by informing the investors concerned or, failing that, by abandoning the transaction.
3. Remuneration policy
The remuneration policy is established in accordance with Article L. 533-22-2 of the French Monetary and Financial Code, the AIFM Directive and ESMA guidelines. Taking into account its size, organisation and the volume of its assets under management, the company applies the proportionality principle.
Remuneration comprises a fixed component and, where appropriate, a discretionary variable component. It is designed so as not to encourage risk-taking that is inconsistent with the risk profile of the funds managed and to align the interests of employees with those of unitholders. The policy is subject to an annual review.
4. Integration of sustainability risks
Pursuant to Article 3 of Regulation (EU) 2019/2088 («SFDR»), sustainability risks, defined as any environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment, are factored into the investment decision-making process in the same manner as other risk factors analysed during preparatory work and the monitoring of holdings.
In accordance with Article 4 of the SFDR Regulation, Bathys Asset Management does not consider the principal adverse impacts of investment decisions on sustainability factors, given its size and the stage of development of its business. This position will be reviewed in light of the development of its assets under management and the regulatory framework.
Fund-specific sustainability-related information is set out in its legal documentation.
5. Exercise of voting rights and shareholder engagement
Bathys Asset Management exercises the voting rights attached to the securities held by the funds managed in the exclusive interest of the unitholders, paying particular attention to resolutions having an impact on governance, capital structure and the strategy of the companies concerned.
Given the nature of the assets held, engagement is carried out primarily through direct and ongoing dialogue with the management of the portfolio companies.
6. Selection of intermediaries and service providers
Given the nature of the assets managed, Bathys Asset Management does not routinely execute market orders. The framework therefore focuses primarily on the selection of intermediaries and service providers involved in the investment and disinvestment process.
Selection is made in the exclusive interest of unitholders, on the basis of objective criteria: competence and recognition in the relevant field, capacity to execute the assignment, quality of reporting, organisation and compliance with regulatory obligations, and fee conditions. Related service providers are subject to a documented competitive tender process. The list of intermediaries and service providers is reassessed at least once a year.
7. Fund documentation
The pre-contractual and periodic documents of the managed funds are made available to investors and provided free of charge upon request, under the conditions set out in their legal documentation.
The information on this page is provided for information purposes only. It does not constitute an offer or investment advice. The legal documentation of each fund shall prevail.