Complaints Handling Policy
Solvo Capital has established a procedure enabling a prompt and efficient handling of clients’ complaints.
How to file a complaint
Clients may submit a complaint to Solvo Capital by registered letter with return receipt requested or by email with delivery receipt, to the following address :
Solvo Capital
2, avenue du Général Dubail
75016 Paris – France
Complaints may be drafted in French or English.
Processing time of clients’ complaints
Solvo Capital will acknowledge receipt of the complaint within 10 business days of the date of the mail posting (as evidenced by postmark) or email transmission, of the complaint to Solvo Capital (the “Submission Date”), unless a response is provided to the client within the same timeframe.
Otherwise, a response will be addressed to the client within 2 months of the Submission Date, except under particular and duly justified circumstances (in which case, the client will be kept duly informed of the status and progress of its complaint).
Mediation before the Autorité des Marchés Financiers (AMF)
If the client finds the response unsatisfactory, he may refer the matter to the mediator (Ombudsman) of the Autorité des Marchés Financiers by mail or electronic form, at the following address :
Autorité des Marchés Financiers
Médiateur de l’AMF
17, place de la Bourse
75082 Paris Cedex 02
https://www.amf-france.org/fr/le-mediateur
Conflicts of Interest Policy
Solvo Capital has established and maintains a Conflicts of Interest Policy aimed at preventing, identifying and managing conflicts of interest that may arise in the course of its activities. The policy calls for the adoption of effective operational measures designed to prevent such incidents from adversely affecting investors’ interests.
A ‘conflict of interest’ refers to a situation in which the discretion, decision-making or performance of duties and responsibilities by or on behalf of Solvo Capital requires a choice to be made between, on the one hand, the interests of Solvo Capital (or its related parties) and, on the other hand, the investors’ interests, or else between the interests of two (or more) investors.
The framework established by Solvo Capital for the prevention of such conflicts of interest is grounded in the principle that all staff members must prioritize investors’ interests and must refrain from acting in any manner that is likely to cause harm to the investors. With this in mind, Solvo Capital has adopted a policy and procedure identifying both general and specific potential situations (taking into account the firm’s activities and organizational structure) likely to give rise to a conflict of interest, and prescribing corrective actions to prevent, limit or manage such conflicts of interest. Solvo Capital shall implement all reasonable measures to prevent conflicts of interest from arising, including where appropriate by amending or defining its internal procedure and/or strengthening existing controls. A complete review and update of the policy and procedure’s effectiveness, adequacy and completeness is conducted at least once a year. Where the measures in place do not provide reasonable assurance that investors’ interests will be adequately protected in a particular case, the affected investors are duly informed of the specific nature and sources of such conflict. Reports of actual conflicts of interest are also recorded in a register of conflicts of interest.
Solvo Capital disseminates its Conflicts of Interest Policy to all its staff members and promotes its consistent application across the firm.
Remuneration Policy
Solvo Capital has established a Remuneration Policy setting forth the rules and procedure applicable to the compensation and benefits (including non-monetary) received and/or paid by the firm. The policy is designed to prevent any conflicts of interest arising from the remuneration of services, in order to protect investors’ interests and uphold the quality and integrity of its services.
Under this framework, Solvo Capital may receive compensation for investment advisory services provided on a non-independent basis. More specifically, the firm’s compensation, in the form of fees, can be due directly by the investors who benefit from the relevant services. Solvo Capital may also receive or pay compensation, commissions or non-monetary benefits from or to third-parties. As a matter of principle, Solvo Capital shall ensure that any remuneration (including incentives) is appropriate or necessary to the provision of services and, in particular, that it is the object of a full, clear and accurate prior disclosure to the investors, that it enhances the quality of the services and that it does not impede the duty to always act in the investors’ best interest.
The Remuneration Policy also establishes a framework for the oversight and governance of staff member compensation. The purpose of the policy is to promote sound and effective risk management, by discouraging conduct inconsistent with the investors’ best interests or with the firm’s business strategy, objectives and values. Staff member compensation consists of a fixed component (salary and benefits) and a variable component (bonus). Solvo Capital is committed to maintaining an appropriate balance between the fixed and variable portions of staff member compensation, and to assessing and rewarding staff performance in a manner that serves investors’ best interests.
The Remuneration Policy applies to all staff members of Solvo Capital, and is reviewed for appropriateness and approved on an annual basis.
Shareholder Engagement
Under the current legal framework, shareholder engagement refers to the manner in which portfolio management companies integrate their role as shareholders into their investment strategy. This includes the monitoring of investments, conducting dialogue with underlying investee companies, exercising voting rights, cooperating with other shareholders, engaging with relevant stakeholders, and the prevention and management of conflicts of interest.
The investment strategy of the funds advised by Solvo Capital primarily targets minority stakes in direct secondary equity (GP-led transactions, continuation vehicles and co-investments) of unlisted companies. As a result of its position as a minority investor in a generally highly intermediated investment structure (fund-of-funds investor), Solvo Capital expects to have a limited engagement with and direct intervention on investee companies and related governance issues. For this reason (as well as its position as a financial investment adviser), Solvo Capital does not maintain a dedicated shareholder engagement policy, and will instead rely on its other mandated internal policies (namely its Conflicts of Interest Policy) to govern the relations with its underlying investments. As a general principle, Solvo Capital intends to fulfill its shareholder role fully and diligently, and to exercise any rights, duties and obligations attached to its underlying investments with the sole view of ensuring the investors’ best interests at all times.
Sustainability Disclosures
Solvo Capital recognizes responsible investment to be an essential driver of its activity and an integral component of its investment process. With this in mind, Solvo Capital has sought to embed Environmental, Social and Governance (ESG) considerations at each stage of the life of an investment and has designed its investment and monitoring procedures accordingly.
During the due diligence phase, Solvo Capital will assess ESG-related factors with a view to identifying ESG risks and opportunities that may be material to the performance of an investment. The investment team will determine the degree of relevance of such ESG factors on a case-by-case basis, taking into account their contribution to long-term resilience and value creation in the particular context of each considered investment. This integration of ESG risks is only one of several elements composing the firm’s investment decision-making process alongside financial, operational and strategic considerations, among others. Investment decisions are thus made following a holistic evaluation of all factors (including, as applicable, ESG) deemed material and relevant to the investment opportunity under review.
Throughout the holding period and up to the divestment phase, Solvo Capital will continue to closely monitor the ESG status and developments of each portfolio investment. To this end, the investment team will establish and periodically update an ESG scorecard and dashboard, building on its initial ESG assessment, the reporting received from underlying asset managers, and ongoing dialogue and constructive engagement with their teams. Solvo Capital will also engage with underlying asset managers by sharing its perspectives on ESG matters, discussing and reviewing their ESG approach, and supporting initiatives that contribute to sustainable performance across its portfolio, as part of its investment approach.
Given its strategy focus on secondary minority investments (which typically involve multiple intermediary structures), Solvo Capital has an inherently limited ability not only to shape the ESG policies and practices of its portfolio companies, but also to influence the collection, availability and quality of their ESG data. For this reason (as well as its position as a financial investment adviser), Solvo Capital has concluded that it is not appropriate for it to consider the principal adverse impacts of its investment decisions on sustainability factors, as referred in article 4 of Regulation (EU) 2019/2088 of 27 November 2019 (Sustainable Finance Disclosures Regulation - SFDR).
Similarly, Solvo Capital has decided not to include sustainability risks as a distinct assessment criterion in its Remuneration Policy as referred in article 5 SFDR. Solvo Capital rather considers that the variable remuneration of its staff members should reflect equal and due compliance with all of the firm’s policies and procedures, including (where relevant) those relating to the integration of ESG considerations and risks in the investment process.
Solvo Capital may revise its sustainability approach in the event of a change to its regulatory status or investment activities, as well as to reflect developments in applicable legal requirements or prevailing market practices.
Product-specific information regarding the investment funds advised by Solvo Capital as referred in articles 6, 8 and 10 SFDR (including their pre-contractual disclosures and, where applicable, any investment exclusion policies that Solvo Capital as investment adviser is bound to comply with) can be found in their respective data rooms, accessible to investors and prospective investors through a secured platform.
Last updated on 31 August 2026.