SWEN CP has formalised a specific policy regarding the prevention and management of potential conflicts of interest, in compliance with applicable laws. This policy has been set up by the Compliance and Internal Control Officer. The latter is responsible for overseeing its implementation and the respect of the rules and procedures enacted in it.
Regarding conflicts of interest prevention, employees are committed to comply with SWEN CP’s code of ethics and are subject to compliance rules regarding transparency (personal transactions, external mandates, gifts received, etc.). SWEN CP’s code of ethics refers directly to the ethical guidelines of professional associations (France Invest, AFG, Invest Europe). Moreover, before any new investment, each member of the investment team is required to fill in a questionnaire assessing potential conflicts of interest.
Each co-investment must be in compliance with SWEN CP's co-investment Charter. The later rules the distribution of invesment among the different investment vehicles (with overlaping investment strategies) managed by SWEN CP. The co-investment Charter is frequently reviewed.
Finally, the company has established a risk mapping in order to identify potential conflicts of interest situations. It is reviewed annually.