ArtsGain Investments and its partners have implemented and maintained a procedure to quickly and efficiently handle complaints made by its investors.
A complaint is defined as “a statement of dissatisfaction by a client toward the professional. A request for information, opinion, clarification, service or provision is not a complaint” according to EU Directive 2011/61/EU and related transposing local law in each EU country.
Any complaint may be sent to the Compliance Officer (RCCI) of the company at its registered office at 12 Paseo de Gracia, 1st floor, 08007 Barcelona, Spain. The management company will acknowledge receipt of the complaint within ten working days of the date on which it was received and a response will be issued to the client within two months of receipt of the complaint.
For any country, in the event of an ongoing dispute, the client may contact a mediator, such as the Judicial Arbitration and Mediation Service. The mediation request form and the mediation charter with its local address are available online at www.jamsadr.com.
Conflict of interest policy
ArtsGain Investments maintains and operates an effective policy to identify, prevent, manage and monitor conflicts of interest situations that may adversely affect its customers. ArtsGain Investments also holds a register that lists situations in which a conflict of interest has arisen, whenever applicable. A copy of the policy is available at Internal Rules of Conduct.
Best Execution Policy and Best Selection Policy
An investment service provider must take all reasonable measures to obtain for its client the best execution of its order. In this context, ArtsGain Investments only implemented a Best Selection Policy and selected intermediaries whose execution policy allows the best possible result when executing orders.
The criteria applied to select intermediaries that guarantee the best execution of market orders are both quantitative and qualitative. They depend on the markets for which the intermediaries provide services, in terms of geographical area (global, European, or local intermediaries) and financial instruments traded (equity). The analysis criteria cover the availability and proactiveness of the intermediary representatives, their financial situation, their speed, and the quality and cost of the processing and execution of orders.
The intermediaries’ ratings are updated every year. Based on this, the list of selected intermediaries is also reviewed annually.
A copy of the policy is available free of charge upon request.
ArtsGain Investments is an independent asset management company, whose capital is majority held by its managers. It, therefore, does not depend on any other company that could be the source of conflicts of interest. In addition, all ArtsGain Investments employees have signed the Code of Ethics drawn up in accordance with the Code of Ethics of the law.
Monitoring of strategy, financial and non-financial performance, risks, social and environmental impact, and corporate governance.
ArtsGain Investments’s ESG Charter constitutes the reference framework for the development of the company’s activities and its internal line of conduct. Thus, ArtsGain Investments excludes any investment in art themes that are not in line with its convictions (weapons, tobacco, and in general any activity undermining the integrity of individuals) or contravening international standards and conventions (violation of human rights, labor children).
ArtsGain Investments invests in artworks of artists under specific art themes and manages its related artworks which by nature contribute to a better and more sustainable future for all by using low-emission transportation, moving artworks only when it is essential, using reusable transport materials, and using pre-established transport of our logistic partners.
ArtsGain Investments dedicate 0.3% of the funds to Social Art, that is, to singular artists to give visibility to art created by people with functional disabilities, mental illness, or people at risk of social exclusion through agreements with artistic communities and specialized NGOs.
ArtsGain Investments select works of art linked to their Investment Themes, taking into account positive discrimination for the inclusion of underrepresented recognized artists and for greater recognition of women and diversified artists.
Dialogue with partners
During the holding period, ArtsGain Investments are in constant dialogue with the logistics partners, artistic communities, and specialized NGOs to receive their financial reporting regularly, at least annually, discuss and raise awareness of good ESG practices,
and request annual surveys to measure progress. Dialogue with those organizations is particularly important to get extra-financial value creation for the invested themes and related artworks related to ESG benefits.
The management team thus meets regularly with the representatives of the ESG partners to ensure ESG criteria and best practices.
Exercise of voting rights and other rights attached to shares
ArtsGain Investments’ voting rights policy aims to favor the exclusive interests of the investors of its funds. To this end, and concerning the vote of funds falling within the scope of the policy, the votes cast will favor:
- laying the foundations for an effective corporate governance regime;
- the rights of investors;
- fair treatment of investors;
- transparency and dissemination of information;
- the responsibility of the board of directors of the funds;
- the sustainability and development of the funds.
Decisions are discussed within the management team and made based on in-depth knowledge of the art themes and their activities.
Communication with investors
ArtsGain Investments is in contact with the investors of the funds regularly to update them on topics like regulation, investment themes, investment criteria, investment acquisitions and exits, yearly NAV and audit, yearly expenses and incomes, and the status of suppliers, brokers, and ESG partners.
Prevention and management of actual or potential conflicts of interest in relation to their commitment
ArtsGain Investments takes care to place the client’s interests above all other considerations. In this context, ArtsGain Investments has set up a system to detect and prevent any conflict of interest that may arise. A mapping of the potential conflicts of interest identified and the system put in place for their resolution has been put in place within the company. A register of conflicts of interest is kept by the regulator.
Employees are made aware of the risks of conflicts of interest and comply with the rules of integrity defined in the procedure for managing conflicts of interest and the Code of Ethics. These rules govern the exercise of corporate offices and functions external to ArtsGain Investments, personal transactions, gratuities, gifts, or other received and given.
The purpose of this Charter is to set out the ways in which environmental, social, and governance (ESG) criteria are incorporated into the investment and risk management policy of ArtsGain Investments and the funds under management.
ArtsGain Investments has taken also non-financial criteria into account in its investment processes, from the investment opportunity analysis stage to exit. The firm is convinced that extra-financial data enables value creation and promotes an alignment of interests between all stakeholders – management and employees, investors, and society in the broad sense.
ArtsGain Investments is a signatory to the ESG practices of the regulator and follows the recommendations of sustainable practices established by Ki Culture to promote sustainable management of cultural heritage.
Aware of the environmental footprint generated by its operations and through its investments, ArtsGain Investments undertakes:
- when an environmental risk is identified during the course of an investment due diligence, request an audit in order to assess the impact of the investment in question and to encourage the target to prevent any potential damage that has been identified as regards the environment;
- to promote best practices in terms of environmental protection – transportation use reduction, and the usage of reusable materials in relation to its invested artwork logistics.
Due to its convictions, ArtsGain Investments does not invest in themes and related artworks that can promote pornography, alcohol, tobacco, gambling, arms, and, in general, any business activities that infringe the integrity of persons or that contravene international standards and conventions (e.g., that violate human rights, child labor).
Before making each investment, the firm reviews its strategies for distributing the added value created and for aligning interests with respect to the investments in question – this entails drawing up investment criteria that feature all the potential artworks to be invested, drafting a policy for transportation of the artworks and the allocation of diversified artists arising from funds.
ArtsGain Investments promotes diversity but does not have a specific policy to promote gender equality either for its employees or for the artists that are interested to invest.
Good corporate governance lays the foundations for value creation and for risk reduction, and thus ensures the long-term sustainability of the funds.
- Before each investment is made, a detailed analysis of the governance of target artists and their artworks is carried out.
- The firm makes sure that it complies with the laws, conventions, and regulations that apply to it;
- ArtsGain Investments ensures that it complies with anti-money laundering, anti-corruption and anti-terrorist financing regulations as regards matters that are within its control for the potential investors, for the potential clients of the acquired artworks and for the potential suppliers of the target artworks to be acquired;
- It has a voting policy and a general policy for preventing and dealing with conflicts of interest.
- ArtsGain Investments always acts primarily in the interests of investors;
- The firm provides reports to investors on our operations and to further the goal of transparency, in particular with regard to the economic, environmental, social, and governance impacts of its investments.
ArtsGain Investments makes the following disclosures in accordance with the Sustainable Risk Finance Disclosure Regulation (2019/2088) (the “SFDR”).
ArtsGain Investments invests in artworks and artists which are part of their related art themes, which contribute positively to achieving a better and more sustainable future for all (low-emission transportation, resuable of materials, and social funds).
ESG criteria are a key component of ArtsGain Investments policy since 2021. ArtsGain Investments has already its own tailor-made procedures and metrics to assess the sustainability adverse impacts. Therefore, ArtsGain Investments does not intend to consider the prescribed adverse sustainability impacts of the SFDR but will follow closely the future developments related to the regulation.
Remuneration policy and sustainability
Quadrille Capital’s remuneration policy complies with the AIFM EU directive and its related transposing local law in each EU country requirements.
The remuneration policy is in line with the interests of the funds under management and their investors.
ArtsGain Investments’s staff receives a combination of fixed remuneration (salary and benefits) and variable remuneration (bonus). Variable remuneration is discretionary, not guaranteed, and takes into account ArtsGain Investments’s performance and individual objectives such as the respect of the ESG charter.
Non-discrimination for promotions and compensation is a cornerstone at ArtsGain Investments.
A copy of the policy is available free of charge upon request.