The principles of Reflexion Capital’s remuneration policy are as follows:  

  • Aligning remuneration policy with Reflexion Capital’s strategy and objectives 

Reflexion Capital’s objective is to help companies realise their development plans and accelerate their growth, while ensuring their sustainability (controlling environmental, social and governance risks, and limiting the company’s main negative impacts on sustainability factors). 

  • Preventing excessive risk-taking in decision-making 

Reflexion Capital implements a reasoned approach to remuneration and ensures that employees are not encouraged to take excessive or inappropriate risks. 

  • Ensuring that remuneration and performance assessment correspond 

The remuneration of Reflexion Capital employees comprises a fixed and a variable component. The variable remuneration of the teams concerned takes into account compliance with all Reflexion Capital methodologies and procedures, in accordance with current regulations, including those relating to the sustainability risks of investments. 


January 2022 

  1. Regulatory framework 

Reflexion Capital has examined the practical conditions for implementing its obligations financial investor on how to take into account the main negative impacts on sustainability factors in its investments, in application of paragraph 5 of article 4 of the settlement (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the publication of sustainability information in the financial services sector, specified by first version of technical implementation standards (the Regulatory Technical Standards or “RTS”). The regulations require a “comply or explain” decision on the  provision and consolidation of indicators relating to the main negative impacts, at the level of each product as well as at the level of the management company. 

This review has led to the formalisation of this declaration.  

For the purposes of this statement, the main negative impacts are the most significant negative impacts of investment decisions on sustainability factors related to environmental, social, labour, human rights and anti-corruption issues. The RTS specify  that 14 mandatory indicators and 2 optional indicators from a predefined list must be included.   

  1. Declaration that the main negative impacts have not been taken into account 

Reflexion Capital invests  in unlisted companies with sales  of between  €2m and  €100m. For this reason, the data  required  for the mandatory indicators  are rarely available.  Because of the lack of data available at the level of the holdings, Réflexion Capital is currently not in a position to communicate consolidated datas on the 14 indicators of the main negative impacts, at the level of the funds managed and the management  company. For this reason, Réflexion Capital has chosen not to take into account the main negative impacts of investment decisions on sustainability factors at this stage. 

Nevertheless, Réflexion Capital includes  a qualitative analysis of these indicators  (and a quantitative one where available)  in its investment  and reporting  methodology.

It should be noted that Réflexion Capital closely monitors regulatory developments and market work in order to be able to take into account the main negative impacts in its investments and the monitoring of its holdings. – at a date to be determined – as soon as the necessary information is available.