Cinven Website Disclosure

Cinven Fund Management S.à r.l. (hereafter referred to as “the AIFM” or “Cinven Luxembourg”) is a regulated alternative investment fund manager based in Luxembourg. The AIFM is incorporated under the laws of the Grand Duchy of Luxembourg, with its registered address at 4 Rue Albert Borschette (Kirchberg) L-1246 Luxembourg, and is registered with the Luxembourg Trade and Companies Register under the number RCS number B287169. It operates under the supervision of the Commission de Surveillance du Secteur Financier (CSSF).

Cinven Luxembourg is authorised to act as an alternative investment fund manager (AIFM) under Chapter 2 of the amended Law of 12 July 2013 on alternative investment fund managers (hereafter referred to as the “2013 Law”) and to manage undertakings for collective investment under Chapter 16 of the amended Law of 17 December 2010 (Article 125-2) (hereafter referred to as the “2010 Law”). In addition to its core AIFM activities, Cinven is authorised to provide (i) portfolio management services on a discretionary, client-by-client basis and (ii) reception and transmission of orders in relation to financial instruments under Article 5(4) of the 2013 Law, commonly referred to as the “MiFID top-up”. This authorisation is strictly limited to facilitating the distribution of funds managed by non-EEA management companies within the Cinven Group.

To support its European distribution strategy, the AIFM has established a branch in Spain, registered as Cinven Fund Management S.à r.l., Sucursal en España, with its office located at C. del Pinar, 7, 6ª Planta, Salamanca 28006 Madrid. The Spanish branch (registry number 1111191888) is subject to oversight by the Comisión Nacional del Mercado de Valores (CNMV). The branch facilitates the AIFM’s marketing activities by enabling the use of marketing passports and the free provision of services across relevant EU Member States.

Complaints Handling Process

In accordance with the provisions set forth by the CSSF Regulation No. 16-07 relating to out-of-court complaint resolution, Cinven Luxembourg has established and implemented effective and appropriate procedures for the reasonable and prompt handling of complaints received from its clients. You can find a summary of its complaints handling procedure below.

How to file a complaint with Cinven Fund Management?

If you wish to express your dissatisfaction with our services, or if you wish to receive more information on our complaints handling process, please do not hesitate to contact our Complaints Handling Officer at your convenience, in writing via post or email, using the following contact details, with the reference “Complaint”:

Cinven Fund Management S.à r.l.
Attn: Complaints Handling Officer
4 Rue Albert Borschette (Kirchberg) L-1246 Luxembourg
Email: CFMcompliance@cinven.com

To ensure a prompt handling of your complaint, please include the following information:

  • Your identity and contact details;
  • Reason(s) of the complaint and any resulting damage or loss caused;
  • Where relevant, copies of any documentation supporting your complaint.

Complaints may be made in French or in English.

Once we have received your complaint, you will receive a written acknowledgement of receipt within ten (10) Luxembourg business days.

Your complaint will be investigated, and we aim to find a resolution as quickly as possible. However, some complaints may be more complex and require further investigation. If a decision is not reached by the time of the acknowledgement letter, a response will be sent to you within one (1) month which will either contain:

  • A full and clear final response including the outcome of the investigation; or
  • An explanation as to why we are not able to provide a final response and details of when the response will be provided.

What if you are not satisfied?

If you are not satisfied with the answer provided, you may refer the complaint to Cinven Fund Management’s governing body by sending a letter via post to the following address:

Cinven Fund Management S.à r.l.
Attn: Board of Managers
4 Rue Albert Borschette (Kirchberg) L-1246 Luxembourg

Alternative Dispute Resolution

If you remain dissatisfied with the response provided by Cinven Fund Management’s governing body within a reasonable timeframe, you may notify the Luxembourg regulatory authorities, Commission de Surveillance du Secteur Financier (“CSSF”), using the procedure for out-of-court complaint resolution. This must be done within one year of filing the original complaint.

Further details as to the out-of-court resolution procedure is available on the CSSF website at the following address: https://www.cssf.lu/en/customer-complaints/

The complaint can be filed either:

  • By filling in the online complaint form available here: https://www.cssf.lu/en/Document/interactive-form-for-complaints/;
  • Or by sending the completed complaint form (PDF):
    • Either by mail (simple mailing, no registered letter required) to the following address: Commission de Surveillance du Secteur Financier Département Juridique CC 283, route d’Arlon L-2991 Luxembourg
    • Or by fax using the following number: (+352) 26 25 1-2601;
    • Or by email to the following address: reclamation@cssf.lu

A copy of CSSF Regulation No. 16-07 is available on the CSSF website at the following address: https://www.cssf.lu/en/Document/cssf-regulation-n-16-07/

Conflict of Interest

Cinven Luxembourg is committed to acting in the best interests of the Funds it manages and their investors. In line with the Alternative Investment Fund Managers Directive (“AIFMD”) and applicable Luxembourg regulations, the AIFM has implemented a structured approach to identifying, managing, and, where necessary, disclosing conflicts of interest to ensure the highest standards of integrity and transparency.

Conflicts of interest may arise in the normal course of managing private equity investments, particularly in relation to investment decisions, allocation of opportunities, relationships with service providers, or interactions with investors and counterparties. The AIFM has put in place a robust governance framework designed to ensure that such situations are appropriately handled. Policies and procedures are in place to prevent undue influence on investment decisions, ensure fair treatment of investors, and maintain clear oversight of key functions. The AIFM also ensures that any engagements with affiliated or related parties are conducted on an arm’s-length basis and in line with market standards.

To reinforce its commitment to transparency, the AIFM has established measures requiring employees to disclose any potential personal interests that could interfere with their professional responsibilities. Strict internal controls govern the acceptance of benefits or inducements, and the segregation of duties across key functions helps to maintain objectivity in decision-making. If a situation arises where a conflict cannot be fully mitigated through existing controls, the AIFM will provide appropriate disclosures to investors, ensuring that they have all relevant information to make informed decisions.

The AIFM regularly reviews and enhances its policies to align with regulatory developments and industry best practices. Senior management oversee the implementation of these measures to ensure their effectiveness and ongoing relevance. By maintaining a strong and transparent conflict management framework, the AIFM continues to uphold investor confidence and the integrity of its operations.

For further details on the AIFM’s approach to conflicts of interest, or to request additional information, investors may contact the AIFM at CFMcompliance@cinven.com.

Remuneration Policy

The AIFM has established and implemented a remuneration policy that aligns with the principles of sound governance, prudent risk management, and the long-term interests of the Funds under its management and their investors. This policy is designed to ensure that remuneration practices are consistent with and promote effective risk management, do not encourage excessive or inappropriate risk-taking, and prevent any conflicts of interest that could impair Cinven’s duty to act in the best interests of its clients.

The remuneration framework adopted by the AIFM adheres to applicable regulatory requirements and reflects a balanced approach between fixed and variable remuneration components. Variable remuneration is structured to be proportionate, performance-based, and subject to appropriate risk-adjusted metrics, ensuring that it does not incentivise behaviour that is inconsistent with the risk profile of the AIFM, the investment strategies of the Funds, or their constitutional and regulatory requirements.

The policy further provides for robust governance measures, including oversight by the AIFM’s Board of Managers and relevant governance bodies, to ensure that remuneration structures are fair, transparent, and aligned with the AIFM’s long-term strategic objectives. In line with best practices, the AIFM regularly reviews and updates its remuneration policy to maintain alignment with evolving regulatory expectations and market standards.

A summary of the AIFM’s Remuneration Policy, including details of how remuneration and benefits are determined, is available upon request. Investors may obtain further information by contacting the AIFM at CFMcompliance@cinven.com.