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CORPORATE GOVERNANCE
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Report of the Chairman of the Supervisory Board
Compliance with the Code of Ethics included in the Rules of
Procedure is monitored centrally by an ethics manager who
reports to the Compliance and Internal Control Officer of each
asset management company.
The rules on ethics are presented later on in this report, in the
section entitled “Ethics”.
In order to avoid the risks of insider trading, the Ethics Officer
and Compliance and Internal Control Officer maintain a list of
companies whose securities employees and their families are
prohibited from trading. In practice, any investment in a listed or
unlisted company must first be authorised by the Ethics Officer.
Control is carried out not only on transactions internal to the
Company, but also on the companies in the portfolio. Apax
Partners SA and Apax Partners MidMarket SAS are corporate
officers of practically all the companies in the portfolio. The
permanent representatives of themanagement company (or the
directors themselves) performthe role of corporate officers. They
are active onBoards andon remuneration andAudit Committees.
They receive amonthly activity report and each comments on it in
the partner’smeetings. They take the greatest care to ensure that
the capital of the funds managed by Apax Partners and Altamir
is invested in accordance with the objectives set at the time of
investment.
The Company exercises its voting rights at each Annual General
Meeting.
C. Procedures
In order to compile this report, the Chairman of the Supervisory
Board interviewed all the parties involved in internal control: the
CFO, the Compliance and Internal Control Officer, the Deputy
Internal Control Officer, the Statutory Auditors and themembers
of the Audit Committee.
The topics of internal control and ethics were discussed during
the Supervisory Board meetings.
D. Identification of serious deficiencies or
inadequacies of the internal control system
To thebest of our knowledge, no serious deficiencyor inadequacy
was revealed during the assessment or preparation of this report.
RELATIONSHIP BETWEEN RISK FACTORS
AND THE INTERNAL CONTROL PROCEDURES
Please refer to section 1.5. Risk Factors
The risk factors and measures taken to limit their impact are
addressed in the Management Company’s report.
This report does not aim to describe the procedures in detail. Our
description of the organisation and our internal control principles
is intended to give you an outline of how our internal control
system functions.
In2016,theCompanypursuedinternalcontrolinitiatives,continued
to combat money laundering and the financing of terrorism
and implemented new reporting software. It also conducted a
complete review of the FATCA status of the Company and all of
its investment holdings.
In 2017, we will continue to implement corrective actions if we or
our auditors identify weaknesses or omissions.
This report was approved by the Supervisory Board during its
meeting of 6 March 2017.
Chairman of the Supervisory Board
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REGISTRATION DOCUMENT
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ALTAMIR 2016