Legal Notice

LEGAL INFORMATION

Since 2007, IMPACT Partners has been working with committed entrepreneurs to build a fairer and more sustainable society.

We have grown with one conviction: financial performance and social impact are not incompatible. But we needed to demonstrate it.

By supporting our entrepreneurs in achieving ambitious economic and social objectives and enabling entrepreneurial projects to access the financial resources they need to succeed, we have built our track record.

Because at IMPACT Partners, facts matter far more than intentions.

This same standard applies to our own activities. This page sets out the regulatory framework, rules and commitments governing our work.

 

IMPACT PARTNERS

Since its creation, IMPACT Partners has been driven by one conviction: only value creation within profitable organisations can provide a sustainable response to economic and social inclusion challenges.

As of today, IMPACT Partners manages 10 funds across 3 activities:

Local seed

Creating economic activity in fragile areas in France, including disadvantaged neighbourhoods, rural areas and struggling town centres.

Social growth

Supporting companies capable of generating significant social impact and scaling up at European level.

Profit sharing

For these 2 profit-sharing funds, investors have agreed that the majority of the profits generated will be directed to the Institut du Cerveau et de la Moelle Épinière (ICM), a French foundation recognised as being of public interest, established on 24 September 2010.

 

OUR REGULATORY FRAMEWORK

IMPACT Partners is a portfolio management company authorised by the French Financial Markets Authority (Autorité des marchés financiers – AMF) under number GP-08000053 since 18 December 2008.

Its authorised programme of activities covers the management of alternative investment funds (“AIFs”) within the meaning of Directive 2011/61/EU on Alternative Investment Fund Managers (“AIFMD”), IMPACT Partners having opted to comply with this Directive.

The funds managed by IMPACT Partners are subject to the regulations applicable to their investment strategies and investor categories.

Certain funds are reserved for professional investors.

 

FACTS BEFORE INTENTIONS

At IMPACT Partners, we believe that impact cannot remain an intention.

It must be embedded in the investment process, monitored over time and measured.

IMPACT Partners’ investment philosophy is based on the conviction that taking environmental, social and governance (ESG) considerations into account is essential to creating sustainable value and driving the performance of the companies in which the portfolios we manage invest.

We want to contribute to the development of a new form of capitalism that is also socially and environmentally responsible, rather than focused solely on economic growth.

From the assessment stage onwards, each potential investment is screened against two analytical frameworks:

  • Activity exclusions.

  • ESG criteria.

 

SFDR

Funds meeting the requirements of “Article 9”

With the exception of the 2 profit-sharing funds, all other funds within the LOCAL and SOCIAL activities qualify as sustainable investments within the meaning of Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector, known as the Sustainable Finance Disclosure Regulation (SFDR).

What is SFDR?

The Sustainable Finance Disclosure Regulation (SFDR) aims to provide greater transparency regarding environmental and social responsibility in financial markets, in particular through the disclosure of sustainability-related information about financial products.

It notably aims to:

  • ensure alignment between marketing materials and actual practices;

  • enable better comparability between products;

  • channel private investment towards more responsible investments.

The regulation notably distinguishes between:

Article 6: The product has no sustainability objective.

Article 8: The product promotes environmental and social characteristics, even though these do not constitute its central focus or the central focus of the investment process.

Article 9: The product has a sustainable investment objective.

The funds within the LOCAL and SOCIAL activities, representing more than 90% of the funds managed by IMPACT Partners, pursue a sustainable investment objective within the meaning of Article 2(17) of the Regulation.

The investments made contribute to a social objective: combating inequalities, promoting social cohesion, social integration and labour relations, investing in human capital or in economically or socially disadvantaged communities.

We also ensure that these investments do not significantly harm these objectives and that the investee companies follow good governance practices.

 

OUR EXCLUSIONS

What we do not finance.

For the funds we manage, the following activities are excluded:

  • Illegal economic activities, such as human cloning for reproductive purposes;

  • The production or trade of weapons or ammunition;

  • The production or trade of tobacco and distilled alcoholic beverages;

  • Casinos and online gambling;

  • Pornography;

  • Real estate;

  • Biotechnology;

  • Banking or financial activities;

  • Illegal access to electronic database networks or the illegal downloading of electronic data.

Since 2020, IMPACT Partners has undertaken to ensure that its funds do not invest in any company generating more than 10% of its revenue from coal-related activities, including coal extraction and/or coal-fired energy or electricity generation.

By way of exception, IMPACT Rebond and its successor funds:

Given the specific nature of the IMPACT Rebond fund, this exclusion does not apply, for this fund, to the sale of consumer gaming products and/or PMU betting products, or to the trade of tobacco and distilled alcoholic beverages.

 

ESG

IMPACT Partners considers that the best way to successfully support companies in making progress on ESG issues is to involve Investment Directors, who are the primary points of contact with the companies they oversee.

Education and awareness play a key role. This approach is based on a constructive relationship of trust with company executives.

ESG considerations play an important role from the outset of the investment decision-making process. Before committing to a long-term relationship with a company, the investment team must be satisfied with its assessment of ESG sustainability risks.

For funds within the SOCIAL activity, the ESG due diligence process notably aims to provide an ESG SWOT analysis of the investment opportunity, together with a range of actions designed to:

  • Limit negative impacts;

  • Limit ESG risks;

  • Increase positive impacts;

  • Fully leverage the company’s comparative advantages in terms of sustainability.

 

ENVIRONMENT

Companies with positive environmental impacts are prioritised.

Where an investment opportunity presents environmental risks arising from its activities, these risks are assessed as part of the due diligence process.

During the initial assessment and identification phase, each potential investment is systematically subject to a risk analysis covering the main ESG issues, with particular attention paid to social considerations.

However, climate-related risks and/or opportunities are not assessed, and portfolio eligibility is not evaluated against the European Taxonomy.

 

SOCIAL

An assessment framework covering each investee company’s social recruitment policy is established for every investment.

It sets targets in terms of inclusive employment:

  • Recruitment of people from priority neighbourhoods targeted by French urban policy;

  • Recruitment of people with disabilities;

  • Recruitment of apprentices;

  • Recruitment of people in employment integration programmes.

 

GOVERNANCE

A governance body is systematically formalised or established for each investment.

It includes the company’s executives and one or two members of the investment team.

Independent members are invited to participate wherever possible.

For companies of sufficient size, particularly those within the SOCIAL division, an ESG roadmap is monitored annually as part of the monitoring of sustainable development objectives.

Physical and transition risks related to climate change are identified based on the findings of the climate-risk materiality assessment that may have been identified during the ESG investment assessment, as well as any materiality assessments of climate-related risks for portfolio companies.

 

COMMITMENTS THROUGH TO EXIT

When an investment is made, IMPACT Partners seeks the agreement of the company’s executives to support the future development of their business, within the scope of the tools and powers available to it.

This notably includes:

Compliance with sound governance practices;

Respect for human capital;

Implementation of an environmentally responsible policy;

Transparency regarding sustainability risks.

An ethics clause and an ESG clause are systematically included in the shareholders’ agreement.

Compliance with these clauses is continuously monitored by the investment teams until the investment is exited.

 

ETHICS CLAUSE

The ethics clause provides for a commitment to operate the investee company in accordance with the activity exclusion rules set out in the fund regulations and with the general principles and rules arising from the European Convention for the Protection of Human Rights and Fundamental Freedoms of 4 November 1950, as well as the standards and recommendations of the International Labour Organization.

It notably covers child protection and seeks to prevent or limit, to the extent permitted by available technologies, harm to the environment.

Where a website or messaging service is operated on the Internet, no message may contain content that is contrary to generally accepted standards of morality or to the general principles and rules arising from the European Convention for the Protection of Human Rights and Fundamental Freedoms.

 

ESG CLAUSE

The ESG clause provides that the founders, shareholders and the company acknowledge IMPACT Partners’ stated intention to eventually adopt and ratify the United Nations Principles for Responsible Investment (UNPRI).

The Founders, the Other Shareholders and the Company undertake to take into account, in the management and administration of the Company and in connection with any development transaction contemplated by the Company, environmental, social, societal and good corporate governance criteria.

These criteria notably cover:

  • Use of natural resources;

  • Environmental impacts;

  • Employment;

  • Social dialogue;

  • Human resources;

  • Care and consideration for people;

  • Relationships with suppliers and customers;

  • Relationships with local communities and stakeholders more generally;

  • Governance;

  • Management.

The ESG clause also provides that the founders, shareholders and the company undertake to pursue a continuous improvement approach, so that the company conducts its activities in a manner that reconciles economic interests with corporate social responsibility.

IMPACT Partners is entitled to require the company to provide an annual report detailing the concrete actions implemented in the environmental, social and societal fields.

Based on these assessments, IMPACT Partners determines measurable areas for improvement, which are then monitored annually throughout the period during which the shares are held.

 

LOCAL seed

The Local seed activity comprises 3 funds.

Investments are made to support local businesses in fragile areas of France, including disadvantaged neighbourhoods, rural areas and town centres in certain medium-sized cities.

This activity, launched in 2017, has resulted in 529 investments (as of 30 June 2026).

Our conviction is simple: local businesses are companies deeply rooted in their communities.

They serve local residents, create local wealth and remain rooted in their communities, including after they have achieved success.

In these areas, this dynamic remains fragile.

The entrepreneurs targeted have limited equity but are willing to establish their businesses in these areas; they are often first-time entrepreneurs.

 

THREE OBJECTIVES

To monitor the overall performance of this activity, social performance indicators have been defined:

Employment
Total jobs created in these areas. 4,110 jobs have been created since the activity was launched, 94% of which are permanent positions. One in three employees lives in a fragile area, and the employment rate of women from these neighbourhoods exceeds the national averages observed in the same areas.

Business activity
Revenue generated and reported. €748 million in cumulative revenue since the activity was launched.

Training
The number of hours of professional training undertaken by entrepreneurs and their employees. 5,693 days of professional training have been completed since the launch of the LOCAL funds.

In 2025:

The funds are reserved for professional investors.

In accordance with applicable regulations, investors receive annual reports from IMPACT Partners on these funds.

To pursue these objectives, a new fund, IMPACT LOCAL III, is currently being raised.

 

SOCIAL growth

The IMPACT CROISSANCE activity comprises 3 funds, 2 feeder funds and 2 parallel funds.

As of 30 June 2025, the portfolio of this activity comprised 51 investments.

As this activity has developed since 2015, the funds under management have grown in size and become increasingly international, both in terms of investors and portfolio companies.

 

SOCIAL PERFORMANCE

As a pioneer in the field, IMPACT Partners established social performance objectives for each of its investments at an early stage.

Each investee company is assigned a social performance objective.

This objective is monitored throughout the life of the investment and serves as a key social performance indicator, as well as a final target to be achieved over the holding period.

This indicator, consolidated at fund level, is measured and reported annually to investors.

It constitutes the Social Performance of the fund concerned.

The overall social performance index is calculated as a weighted average of the social performance indices of each company in which the fund has invested.

Depending on the level of social performance achieved, the carried interest payable in respect of the relevant shares, normally determined by the fund’s financial performance, is paid in full or reduced in part.

The portion of carried interest not paid to Category B shares is transferred by the fund to charities and non-profit organisations whose purpose is to promote, support, subsidise, finance or carry out social initiatives for people experiencing social, cultural or physical disadvantages.

 

OUR SOCIAL OBJECTIVES

IMPACT Partenaires III

In addition to an indicator relating to the company’s activity, five indicators had been selected:

  • Exemplary leadership;

  • Creation, maintenance or availability of jobs for people from fragile areas;

  • Creation, maintenance or availability of jobs for apprentices;

  • Creation, maintenance or availability of jobs for people with disabilities;

  • Creation, maintenance or availability of jobs for people in employment integration programmes.

As of 31 December 2025, the Social Performance of this fund stood at 135.39% of the fund’s final target.

Past performance is not indicative of future performance.

This fund is reserved for professional investors.

In accordance with the applicable fund regulations, investors receive annual impact reports for this fund.

 

IMPACT CROISSANCE IV

For subsequent generations of its funds, IMPACT Partners has adopted the United Nations Sustainable Development Goals (SDGs).

For IMPACT Croissance IV, the selected SDGs are:

SDG 1 – No Poverty

SDG 3 – Good Health and Well-being

SDG 4 – Quality Education

SDG 8 – Decent Work and Economic Growth

SDG 10 – Reduced Inequalities

SDG 11 – Sustainable Cities and Communities

SDG 12 – Responsible Consumption and Production

Each investment has 2 social performance objectives linked to the company’s activity. As of 31 December 2025, the weighted social performance of this fund’s portfolio stood at 70.2% of the fund’s final target.

Past performance is not indicative of future performance.

 

IMPACT GROWTH V

For IMPACT Growth V and its feeder fund, the selected SDGs are:

SDG 1 – No Poverty

SDG 3 – Good Health and Well-being

SDG 4 – Quality Education

SDG 8 – Decent Work and Economic Growth

SDG 10 – Reduced Inequalities

SDG 12 – Responsible Consumption and Production

Each investment has 1 social performance objective linked to the company’s activity.

As of 31 December 2025, the weighted social performance of this fund’s portfolio stood at 24.9% of the fund’s final target. As the fund is still within its investment period, the portfolio is currently being built.

Past performance is not indicative of future performance.

 

OUR INVESTORS

Certain funds managed by IMPACT Partners are reserved for professional investors.

In accordance with applicable regulations, investors receive the annual reports relating to the funds in which they are invested.

Documents and information intended for investors may be made available through dedicated areas or access portals.

 

YOUR PERSONAL DATA

Trust also means protecting the data entrusted to us.

In the course of its activities, IMPACT Partners may process personal data in accordance with applicable regulations, in particular Regulation (EU) 2016/679 – the General Data Protection Regulation (GDPR) – and French Law No. 78-17 of 6 January 1978 on data processing, files and freedoms, as amended.

Data subjects have, in particular, the right of access, rectification, erasure, restriction of processing, data portability and objection, under the conditions provided for by applicable regulations.

Investor data

As part of the subscription process, IMPACT Partners may process the investor’s personal data.

This data is provided directly by the investor when subscribing and throughout the life of the fund.

It may include, in particular:

  • First and last name;

  • Home address;

  • Tax residence;

  • Telephone number;

  • Email address;

  • Copy of passport or national identity card;

  • Bank details, including bank account statements;

  • Tax identification number.

This data is processed in particular to:

  • Enable the subscription, issuance and registration of units;

  • Process capital calls and distributions;

  • Issue the notifications, requests, enquiries and other communications provided for in the fund regulations;

  • Provide the tax authorities with the information required for IFU, CRS and FATCA reporting.

The data may be disclosed to IMPACT Partners’ employees and directors only to the extent necessary for the performance of their duties, to judicial, regulatory or tax authorities, in particular in connection with anti-money laundering requirements, as well as to commercial partners and service providers involved in managing relationships with investors.

The data collected is retained for the entire life of the fund. Thereafter, certain data may be retained for the period necessary to comply with applicable legal and regulatory obligations.

To exercise your rights or for any questions relating to the processing of your personal data:

Mathieu Cornietti

Data Protection Officer

personnaldata@impact.fr

 

MAKING A COMPLAINT?

In accordance with AMF Instruction No. 2012-07, complaints handled by IMPACT Partners are governed by the principles of transparency, free of charge and objectivity.

Complaints may be submitted:

By email

reclamation@impact.fr

By post

IMPACT PARTNERS

Investor Relations Department

22 rue de la Pépinière 75008 Paris

IMPACT Partners acknowledges receipt of the complaint within a maximum of 10 business days of receiving it, unless the response is itself provided to the client within this period.

Except in duly justified exceptional circumstances, IMPACT Partners will respond to the client within two months of receiving the complaint.

If the disagreement persists, the client may refer the matter to a mediator, including the AMF Ombudsman:

Ms Marielle Cohen-Branche

Autorité des marchés financiers

17 place de la Bourse 75082 Paris Cedex 02

The mediation request form and mediation charter are available from the Autorité des marchés financiers.

 

CONFLICTS OF INTEREST

In accordance with the General Regulation of the Autorité des marchés financiers, IMPACT Partners has established a policy for the prevention and management of conflicts of interest.

The purpose of this policy is to prevent, identify and manage situations that give rise, or may give rise, to conflicts of interest that could harm investors’ interests.

The conflict-of-interest prevention and management policy is available upon request from the company’s registered office:

22 rue de la Pépinière 75008 Paris

 

OUR ESG COMMITMENTS

IMPACT Partners recognises the need to take environmental, social and corporate governance (ESG) considerations into account in its investment policy.

Non-financial criteria have therefore been incorporated into the investment process of the management company.

Compliance with these principles reflects our commitment to aligning our practices with the best practices in our industry.

IMPACT Partners has also undertaken to adopt an approach that respects ESG criteria within the management company and the companies held in its portfolios.

This approach is formalised in a commitment charter, available upon request from the management company.

IMPACT Partners is a member of France Invest and, in this capacity, complies with the Investors for Growth Commitment Charter.

The reports prepared pursuant to Article 29 of the French Energy and Climate Law are available; the latest report for the 2025 financial year is attached:

Report pursuant to Article 29 of the French Energy and Climate Law – 2025

 

INTELLECTUAL PROPERTY

All elements of the IMPACT Partners website are protected by intellectual property rights.

The reproduction and use of any document published on this website are authorised exclusively for strictly personal and private purposes, provided that the source is acknowledged.

Any reproduction, use or distribution of copies for any other purpose is expressly prohibited and punishable by law.

Any hyperlink to or framing of this website is strictly prohibited.

No element appearing on any page of the IMPACT Partners website may be partially or wholly reproduced, distributed, transferred or incorporated into another website, nor used to create derivative products, without the express authorisation of IMPACT Partners’ management.

 

RELIABILITY OF INFORMATION

The purpose of this website is to provide information relating to the company and its activities.

It is not intended to solicit or provide information to investors.

We do not represent that this information is accurate or complete, and such information must under no circumstances be relied upon as such.

Any opinion or information expressed on this website reflects the opinion of the IMPACT Partners team as at the date of publication.

The information published on this website may be amended at any time and without prior notice.

We encourage you to review this legal information regularly.

Any visitor to the website www.impact-partners.com acknowledges that they accept the rules governing the operation of the website.

 

PUBLISHER

IMPACT PARTNERS

22 rue de la Pépinière 75008 Paris France

RCS: 509 104 725 00015 Share capital: €155,390.00

Publication Director: Mathieu Cornieti, Chairman of the management company

 

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GOVERNING LAW

This website is governed by French law and subject to the jurisdiction of the French courts.

The official language of the website is French.

Last updated: 24 August 2026