CORPORATE GOVERNANCE
2
Report of the Chairman of the Supervisory Board
B. Combat against money laundering
and terrorist financing
As every year, Apax Partners employees took part in a training
course on combatingmoney laundering and terrorist financing.
Controlssuitedtothenatureofthetransactionswereperformed.
SUMMARY OF THE COMPANY’S INTERNAL
CONTROL PROCEDURES
This section reiterates much of the content of previous reports
on internal control. Its purpose is to refresh the reader’s memory
of the practices implemented by the Company.
A. Organisation of the Company’s internal control
procedures
A) INTERNAL CONTROL PARTICIPANTS AND THEIR ACTIVITIES
The purpose of the Company is to invest, in principle, in securities
of unlisted companies, either directly, or
via
investment vehicles
such as French or European private equity funds.
Altamir continues to create value and divest alongside the funds
from Apax France VI to Apax France VII, managed by Apax
Partners SA.
Since 2011, Altamir has also invested
via
the Apax France
VIII-B and Apax France IX-B funds, managed by Apax Partners
MidMarket SAS, and since 2012,
via
the Apax VIII LP and Apax
IX LP funds advised by London-based Apax Partners LLP.
Occasionally, theCompanymay co-investwith all these funds. For
these investments, it is assistedby investment and support teams.
The first objective of internal control is to ensure the quality of
the investment and divestment process. Internal control involves
ensuring that the investment teams focus solely on projects in
line with the Company strategy in terms of sector, maturity, size
and expected financial performance.
The investment monitoring bodies for the funds managed in
France are:
Approvals Committee: composed of two or three experienced
partners, theApprovals Committeemonitors the due diligence
and negotiation procedures undertaken by the investment
team;
Investment and Divestment Committee: composed of four
senior partners, the committee takes the final decisions on
investments and divestments: full or partial sale, merger, IPO,
reinvestment;
Portfolio Monitoring Committee: composed of four partners
and external consultants, the committee meets according to
a pre-determined schedule. Its role is to work with the team in
charge of an investment so as to ensure that the strategic and
operational objectives aremet and that the performance of the
investment is controlled.
All investments are subject toa financial, legal and tax audit byone
or more renowned independent auditors. Other reviews (market,
insurance and environment) are carried out when necessary.
The Management Company has ensured that Apax Partners LLP
operates similarly to the French asset management companies.
The second objective is to control cash flows and assets.
This is achieved by implementing the following processes:
the accounting and fund administration processes are
segregated;
securities are registered in “pure” nominative form and
periodically reconciled with the custodian and registrars of
each company;
payment instructions are centralised with the Chairman of the
management companies in the case of the funds, and with the
Chairman of the Management Company of Altamir;
fund administration, together with the bank custodian, ensures
that the legal documentation is completebefore submitting the
documents to the Chairman for signing;
fund administration and the accountingdepartment ensure the
pari passu
distributionof investments anddivestments between
the funds and Altamir and between the Apax France VIII-A,
Apax France VIII-B, Apax France IX-A and Apax France IX-B
funds, Altamir’s new investment vehicles, based on the rules
defined at the start of every half-year.
As previously reported, Altamir’s Supervisory Board has created
an Audit Committee, which can be assisted by the Company’s
Statutory Auditors.
The third objective is the accuracy of financial reporting. The
objective is achieved by cross-checking accounting data with
data from the securities management system. Increasingly
sophisticated automation limits the risk of human error.
The fourth objective is compliance with laws and regulations in
force. The Company does everything in its power to adhere not
only to general regulations, but also to the regulations specific
to SCRs (investment eligibility quotas) and to listed companies.
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REGISTRATION DOCUMENT
1
ALTAMIR 2016