Legal & Compliance
Sustainable Finance Disclosure Regulation (SFDR)
Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (SFDR) is a European directive which aims at providing clarity in sustainable investments and sustainability risks disclosures to investors. It lays down sustainability disclosure obligations for fund managers toward end-investors in relation to the integration of sustainability risks in all part of the investment process. Further information is available on the European commission website.
At Astanor, all our funds are article 9 funds: they each have sustainability (and impact) as investment objective. You can find Astanor funds disclosures here below. For funds managed by an appointed third party manager, please refer to the website of our external AIFM.
All investment entities affiliated to the Astanor universe, including the Fund Manager, abide by the Astanor Responsible Investment Policy which can be consulted in the link below. The purpose of this Responsible Investment Policy is to illustrate the guiding principles and frameworks which help Astanor achieve its sustainable investment objectives and impact KPIs. It encompasses consideration of sustainability factors across organizations, from the implication of implementing purposeful ESG and scaling impact standards with investees. This document forms Astanor core ESG and impact management system and helps assess, adapt, and manage the ESG and impact performance as an investor and as a firm.
This statement aims at communicating appropriate internal structure and defining the internal responsibilities and instructions for the reception and the handling of Complaints in relation to Astanor funds, in order to ensure that they are handled in a manner which is fair, objective and truth oriented.
“Complainant” means any natural or legal person, such as a ‘customer’ of the Fund, an investor, former investor, or actively solicited potential investor, having filed a Complaint. Complainants will be able to file a Complaint in English, French or in Dutch.
“Complaint” means any written complaint filed with, or addressed, to the Fund to recognize a right or to redress a harm. Complaints usually represent dissatisfaction whether expressed orally or in a written from or on behalf of an eligible complainant, about Astanor’s provision of or failure to provide a financial service or other expected service. For the avoidance of the doubt, simple information or explanation requests are not to be regarded as Complaints.
“Complaints Filing Form” is a form which the Complainant can file a Complaint, accessible in reaching out to email@example.com.
“CSSF” means “Commission de Surveillance du Secteur Financier”, the Luxembourg Financial Services Authority. “Fund” means any investment fund promoted and / or managed by Astanor from time to time.
“FSMA” means “Autorité des services et marchés financiers”, the Belgium Financial Services.
Complaints Handling Procedure
Any complaint concerning the Astanor Entity must be sent using the Complaints Filing Form
To the attention of the Compliance Officer
480 Avenue Louise 1050 Brussels – Belgium
or in reaching out to firstname.lastname@example.org.
Astanor will treat your complaint as follows
- An acknowledgement letter or email will be sent to you within ten (10) business days as of the receipt of the Complaint if the Complaint cannot be settled before this timeline.
- An update letter or email will be sent to you one month and every four weeks thereafter to inform you of the progress of your Complaint.
- A final letter will be sent to you to inform you on the outcome of our investigation and the actions taken to resolve the Complaint.
Where a Complainant did not receive a response within one (1) month of a Complaint being submitted to Astanor, the Complainant can refer its Complaint to the local relevant financial authorities where the Fund operates.
For investors of Luxembourg-based Astanor Entities:
This statement is compliant with the requirements of CSSF Regulation 16-07 relating to the out-of-court resolution of Complaints.
Astanor hereby informs its Luxembourg-based Astanor Entities investors of the existence of the out-of-court dispute settlement procedure with the Commission de Surveillance du Secteur Financier (the “CSSF”), the Luxembourg financial services regulator. For the avoidance of doubt, this only concerns Astanor Entities which are Luxembourg-based investment fund vehicles. The escalation process therein suggests that, where a Complainant did not receive a satisfactory response within one (1) month of a Complaint being submitted to Astanor Ventures, the Complainant can refer their Complaint to the CSSF by the following means:
Either by mail addressed to:
Commission de Surveillance du Secteur Financier
283, route d’Arlon
Grand Duchy of Luxembourg
or by e-mail at the following address: email@example.com
For investors of Belgian-based Astanor Entities:
Astanor hereby informs its Belgium-based Astanor Entities investors of the existence of the out-of-court dispute settlement procedure with the “FSMA”, the Belgium financial services regulator. For the avoidance of doubt, this only concerns Astanor Entities which are Belgium-based investment fund vehicles. The escalation process therein suggests that, where a Complainant did not receive a satisfactory response within one (1) month of a complaint being submitted to Astanor, the Complainant can refer its Complaint to the FSMA by the following means:
- The possibility to seek remediation via the Ombudsfin, www.ombudsfin.be/
- The possibility to reach out directly to the FSMA, by mail addressed to:
AUTORITÉ DES SERVICES ET MARCHÉS FINANCIERS
Rue du Congrès 12-14
1000 Brussels – Belgium
This privacy statement (the “Privacy Statement”) is maintained by Good Harvest Ventures Management S.à r.l. for and on behalf of itself and for all the Astanor Entities (as defined in the List of Astanor Entities, as amended from time to time and available upon request) (collectively, “Astanor” “Astanor Ventures”, “we”, “us” or “our”). This Privacy Statement explains how Astanor collects, stores, shares, protects, and uses personal information of our website visitors, business contacts, investment advisors, investors and management teams involved in business relationship or a potential business relationship with Astanor (“you”, “your”).
We are committed to ensuring that your privacy is protected, and any data you provide will be used in accordance with Regulation 2016/679 (EU) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) as well as any adapting or implementing text (together Data Protection Law). This Privacy Statement may be updated from time to time in accordance with applicable Data Protection Law.
Collection of Personal Data
(a) How do we collect personal information?
If you contact us notably through the submission of forms on astanor.com (our Website), social media channels, by post, phone, email, or in person, we may retain the communication for records, including any information included within it. We also may make use of systems that collate publicly available information. In addition, there is information that is collected automatically when you visit our Website, such as IP addresses.
(b) What personal information do we collect from you?
You may communicate to us from time to time, in which context we may collect the following
- Name, job title and company name;
- Contact information including e-mail address and phone number;
- Employment and education details mentioned in any documents or resumes you send us;
- Information required for Astanor Ventures to meet legal and regulatory requirements, particularly in respect of anti-money laundering legislation;
- Meetings attended in and visits to our offices; and
- Electronic identification data such as information concerning the name of the domain and host from which you access the internet, the browser software and operating system of your computer, the internet protocol (“IP”) address of your computer and the internet address of the site from which you linked directly to the Website will be collected and stored;
- Traffic data (date/time you accessed the Website); and
- Any other information you send to us.
(c) How long will we retain information?
- As regards information you provided on our on-line forms: for the time necessary to respond to your question or handle your request. The retention of such information will normally not exceed two years from registration, unless you have requested us to delete such information or application, subject however to our legal obligations; and
- As regards technical data collected during your use of our Website: for a maximum period of time of six months from the date of collection.
Note that data may be kept longer for permitted purposes, upon prior notification to the data owner.
(d) How is the information used?
We use data (including personal data) for the following purposes and on the following lawful basis:
- To carry out any obligations under a contractual agreement or for pre-contractual measures between us (contractual basis);
- For our legitimate interests (to manage our relationship with you, for internal record keeping, to identify, evaluate, and execute in- and divestment opportunities);
- To monitor and support portfolio companies;
- To contact you for administrative and promotional purposes relating to our services, for internal record-keeping, to administer, protect and improve our Website, to handle potential claims and disputes): you can opt-out at any time by emailing firstname.lastname@example.org; and
- To comply with legal obligations, particularly in respect of tax, accounting, and anti-money laundering legislation (legal basis).
(e) Where is the information stored?
We are committed to ensuring that your information is secure. In order to prevent any unauthorized access, use or disclosure, all information is securely stored with GDPR- compliant services.
(f) Who is the information shared with?
Consistent with any of the purposes mentioned above, we may share your data with:
- our business partners and third-party agents and contractors, such as e.g., intermediaries which introduced you to us, or professional advisors. Personal data will only be transferred to a person who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation; and
- to the extent required by law, e.g., we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;
(g) Where do we transfer your personal data?
Data-sharing may include transfers to companies or organizations in countries outside of the
European Union / European Economic Area (EU/EEA) without an adequate standard of data
protection. In these cases, we transfer personal data in accordance with the provisions of
Data Protection Law on the international transfers of personal data, including by using
appropriate safeguards to secure the transfer of your Personal Data and ensure its protection
(such as Standard Contractual Clauses).
(h) What are your rights?
We respect your privacy rights. You can contact us at any time to:
- Request access to the personal data we have on you; we process a large quantity of
information, and can thus request, in accordance with GDPR, that before the
information is provided, you specify the transaction, information or processing
activities to which your request relates;
- Rectify your personal data that are incorrect and/or incomplete;
- Restrict or delete your personal data, in specific cases provided for by art. 17 and 18
- Object to the processing of your personal data for reasons related to your particular
situation. We will consider your objection and comply with it unless we have a
compelling legitimate reason or for reasons of defending legal rights. In the case it is a
matter of commercial prospecting, you may object without reason; and
- Request portability of your personal data, in certain cases (subject in particular to
technical feasibility) and, where technically possible and with regard only to the data
you have provided to us, to request receipt of your personal data in a structured and
commonly machine-readable format.
To exercise any of these rights, you may contact us by emailing email@example.com by postal mail:
Good Harvest Ventures Management S.àr.l.
46a, avenue J.F. Kennedy
If you are not satisfied with our handling of your data or any answer, you have the right to lodge a complaint with the National Data Protection Commission – Luxembourg – cnpd.public.lu.
Links to other websites
Our Website may contain links to other websites. We do not have any control over these
websites. Therefore, we cannot be held responsible for the protection and privacy of any
information which you provide whilst visiting such sites and such sites are not governed by
this Privacy Statement. You should exercise caution and look at the privacy notice applicable
to the website in question.
Data Protection Officer
Antoine Cuny is appointed as Data Protection Officer for Astanor.