Regulatory Information

Regulatory Status

Spinecap is authorized and regulated by the French Autorité des Marchés Financiers (“AMF”) as a full-scope Alternative Investment Fund Manager (“AIFM”), is exempted from registration with the US Securities and Exchange Commission (“SEC”), and is registered with the US Commodities Futures Trading Commission (“CFTC”). Spinecap is a member of the Alternative Investment Management Association (“AIMA”) and Association Française de la Gestion Financière (“AFG”).

Complaints

If there are any aspects of the services provided to you by Spinecap that you are unsatisfied with, please write to:

Chief Compliance Officer
Spinecap SAS
23 rue d’Aboukir
75002 Paris
France

Or send an email to Chief Compliance Officer attention to compliance@spinecap.com.

We take every complaint very seriously and they will be handled in accordance with the relevant rules of the Autorité des Marchés Financiers ("AMF"). A full copy of Spinecap Clients Complaints Handling Policy can be obtained upon request by contacting us at info@spinecap.com.

In the event we are unable to resolve your complaint to your satisfaction, you may also be entitled to refer your complaint to the AMF Ombudsman’s office who provides arbitrating services on complaints between regulated firms and their clients. Full AMF Ombudsman's office details can be found on the AMF website.

Conflicts of Interest

In accordance with the applicable rules and regulation, Spinecap maintains a Conflict of Interests Policy, ensuring that all reasonable measures are taken to prevent, detect and resolve any conflict of interest that might arise during the course of its activities. A full copy of Spinecap Conflict of Interests Policy can be obtained by contacting us at info@spinecap.com.

Best Execution and Selection

Spinecap owes a fiduciary duty to investors of the funds it manages, and takes all reasonable steps to serve their best interests at all times.

Best execution and selection assessment combine several parameters which may vary according to each situation.  A full copy of Spinecap Best Execution and Selection Policy can be obtained upon request by contacting us at info@spinecap.com.

Remuneration

In accordance with the applicable rules and regulation, Spinecap maintains a Remuneration Policy, which aims at aligning the interests of its staff to that of the its clients with a view to deliver long-term performance within a strictly defined risk framework avoiding any remuneration schemes that could encourage excessive risks taking. A full copy of Spinecap Remuneration Policy can be obtained by contacting us at info@spinecap.com.

SFDR and LEC Disclosures

Download here our SFDR disclosures and LEC report.