Legal and regulatory notice

You have just accessed the website at www.hcvc.co published by Elephants & Ventures

Registered name: Elephants & Ventures, trading as “HCVC” (hereafter referred to as “HCVC”)
SAS – French simplified joint-stock company with share capital of €152,864
RCS (Trade and Company Register) No.: 791 826 837 Paris
VAT registration number: FR90791826837
Registered Office address: 59 rue Beaubourg – 75003 Paris (France)
Email: finance@hcvc.co

AMF approval number: portfolio management company approved by the Autorité des marchés financiers (AMF) under no. GP-16000031
Publication manager: Alexis Houssou
Hosted by: OVH SAS (OVHcloud), 2 rue Kellermann, 59512 Roubaix (France)

We draw your attention to the following points:

The information published on this Website is provided for general information purposes only. It does not constitute an offer to sell, a solicitation of an offer to buy or a recommendation to subscribe for or invest in any fund, security or service, nor investment, legal, tax or accounting advice, in any jurisdiction in which such an offer or solicitation would be unlawful or in which the person making it is not qualified to do so.

The funds managed by HCVC are alternative investment funds (FPCI / SLP) reserved for professional investors. They are not offered to the public and this Website is not directed at retail investors. Any subscription is made solely on the basis of the legal documentation of the relevant fund and in compliance with the applicable marketing rules.

Investing in venture capital funds involves a high degree of risk, including the risk of partial or total loss of the capital invested, illiquidity over the life of the fund and uncertainty as to valuation. Past performance is not a reliable indicator of future results, and no assurance is given that any investment objective will be achieved. Statements about future events or expectations are forward-looking and are subject to risks and uncertainties.

The distribution of the content of this Website and the offering of interests in HCVC funds may be restricted in certain jurisdictions. It is the responsibility of any person accessing this Website to inform themselves of, and to observe, such restrictions.

The content of this Website is not contractual and may be modified at any time without notice. HCVC takes reasonable care to ensure that the information is accurate and up to date but gives no warranty as to its accuracy or completeness. Links to third-party websites are provided for convenience only; HCVC has no control over, and accepts no liability for, their content.

By using this Website, you acknowledge that you have the skills and resources required to gain access to and to use the Website. Any use of the Website implies acceptance of this legal notice, whatever your status (investor, visitor, etc.).

HCVC shall not be liable for events beyond its control or for any damage to your technical environment, in particular to your computers, software, network and other equipment used to access or use the Website and/or the information provided. HCVC may suspend or restrict access to the Website at any time, in particular for maintenance purposes.

HCVC endeavours to publish reliable information. However, despite its IT security measures, modification of the Website by a third party (intrusion, virus or any other means) cannot be ruled out. To the extent permitted by law, HCVC shall not be liable for any direct or indirect damage resulting from access to or use of the Website and/or its information, including inaccessibility, data loss, deterioration, destruction or viruses, nor for any error, inaccuracy or omission in the information published. You use this information at your own risk.

You are reminded that unauthorised access or improperly remaining connected to an IT system, hindering or disrupting the operation of an IT system, and fraudulently adding to or changing data in an IT system are criminal offences for which you may be prosecuted (Articles 323-1 et seq. of the French Criminal Code).

This Website and its content are protected by copyright and/or by other intellectual property rights owned by HCVC or its licensors, in particular data, drawings, graphs, photographs and sound recordings. Any reproduction and/or use, circulation or redistribution of this Website by any means whatsoever, in whole or in part, without the prior express authorisation of HCVC is prohibited and constitutes copyright infringement punishable under Articles L. 335-2 et seq. of the French Intellectual Property Code.

The trademarks and logos shown on the Website are the property of HCVC, its partners or their respective owners. Any use of items on the Website to reproduce these trademarks or logos, in whole or in part, without the express authorisation of HCVC or its assigns is prohibited under Article L. 713-2 of the French Intellectual Property Code.

This Website does not set any cookie or similar tracking technology on your device, and it does not use audience measurement, advertising or social media tools. For this reason, no cookie banner is displayed. The fonts used on this Website are hosted on our own servers.

How we integrate sustainability risks into the investment decision-making process (SFDR Article 3)

The thesis of HCVC funds is to back founders who digitize, automate, and decarbonize the world. We believe that new technologies can change how we produce energy, transport goods and people, manufacture products, and grow food, and that a significant part of the next wave of profitable investments will come from such technologies. Consequently, we consider sustainability in every investment decision. We further believe that everyone in the team has a collective responsibility toward affirming our ESG values.

Although we believe that our investments may contribute to the fight against climate change, we do not market our funds as impact funds, and they do not promote environmental or social characteristics or have sustainable investment as their objective. The funds managed by HCVC come under Article 6 of Regulation (EU) 2019/2088 (SFDR).

We take a holistic approach to sustainability, reviewing every element of an investment, such as quantitative elements like the company’s financial position, qualitative elements like the company’s values and ESG policies, in the context of our investment. In line with our investment thesis, we are always cognizant of the potential of an investment in a new technology to improve sustainability. As a result of the holistic nature of our approach, we do not set a consistent set of KPIs across all investments. We do, however, require companies we invest in to sign a letter affirming their adherence to our values with respect to money laundering, sexual harassment, and prohibited activities. Sustainability risks (environmental, social or governance events or conditions that could have an actual or potential material negative impact on the value of an investment) are assessed during due diligence and monitored during the holding period. Where a sustainability risk is identified, HCVC decides on a case-by-case basis whether to proceed with the investment and may apply measures to mitigate that risk.

HCVC’s investment policy prohibits investments in, among other things, the production of or trade in tobacco and distilled alcohol, the production of or trade in weapons or ammunition, casinos, or human cloning.

HCVC is committed to the fight against money laundering and incorporates screening on such risks into every investment.

Statement on principal adverse impacts of investment decisions on sustainability factors (SFDR Article 4)

In accordance with Article 4(1)(b) of Regulation (EU) 2019/2088 (SFDR), HCVC does not currently consider the principal adverse impacts of its investment decisions on sustainability factors. This is because of the size, nature and scale of HCVC’s activities, and because the funds invest in early-stage, non-listed technology companies, which generally cannot provide reliable data for the mandatory adverse impact indicators in a proportionate way. HCVC does not currently intend to consider such impacts.

Nevertheless, HCVC takes sustainability into account in its investment process, as described in the section on sustainability risks, and monitors information from its portfolio companies through its quarterly survey. We require our portfolio companies to answer quarterly surveys on their quantitative and qualitative performance on many factors. We update this survey every quarter based on the evolution of our understanding of our portfolio and potential ESG risks.

To date, HCVC has not identified any material adverse sustainability impact related to its investments. If we identify any adverse effects, we will consider them on a case-by-case basis, in the context of the size of the investment, the nature of the transaction, and the resources we can bring to help mitigate such impacts.

Remuneration policy and sustainability risks (SFDR Article 5)

Information on how HCVC’s remuneration policy takes sustainability risks into account is set out in section 10 (Compensation policy) below.

EU Taxonomy

The investments underlying the financial products managed by HCVC do not take into account the EU criteria for environmentally sustainable economic activities.

HCVC publishes the annual report required by Article 29 of Law No. 2019-1147 of 8 November 2019 (Article L. 533-22-1 of the French Monetary and Financial Code) on how it takes ESG and climate criteria into account in its investment policy. Latest report (financial year 2025):

HCVC places great importance on the protection of your personal data. The processing of your personal data is subject to EU Regulation 2016/679 of April 27, 2016 (“GDPR”) concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, and to the amended French Data Protection Act of 6 January 1978. The data controller is Elephants & Ventures, trading as HCVC (contact details above).

Purpose of the Policy

This policy aims to provide detailed information on how HCVC collects, protects, and stores personal data, as well as the reasons for its use and sharing. This policy also aims to inform data subjects about their rights regarding the collection and processing of personal data and the procedures for exercising these rights. It applies to visitors to the Website, recipients of our communications and persons in contact with HCVC.

What Personal Data Does HCVC Use?

HCVC may collect various types of personal data including:
-Identification information (name, first name, nationality, date and place of birth, gender);
-Contact details (postal and email address, phone number);
-Information related to education, profession, professional experience, and financial knowledge;
-Data collected during exchanges, on its website or social networks, or during meetings, fairs, interviews, telephone conversations, emails;
-Technical data (e.g. IP address, browser type and pages consulted, recorded in the technical logs of our hosting provider).

For What Purpose Does HCVC Use Personal Data?

-To comply with its legal or regulatory obligations (legal obligation);
-To conclude a contract with a person or to contact them, at their request, with a view to concluding a contract (performance of a contract or pre-contractual measures);
-To periodically communicate about its news or that of the participations of the funds managed by HCVC (legitimate interest or, where required, consent);
-To invite data subjects to participate in events it organizes (legitimate interest). Personal data is used by HCVC and will not be sold. It may, however, be communicated to third parties in the limited cases described below.

Who Does HCVC Share Personal Data With?

-To judicial or financial authorities, state agencies, or public bodies, upon their request and within the limits allowed by regulation;
-To service providers performing services on behalf of HCVC (hosting, IT, fund administration, etc.) and to other professional service providers such as custodians and auditors, which may act as independent data controllers;

How Long is Personal Data Retained?

HCVC keeps personal data:
-As long as necessary for the purposes for which they were collected and processed (for example, contact data of prospects is kept for a maximum of 3 years from the last contact);
-For the duration necessary to comply with applicable regulations, including applicable limitation periods (for example, anti-money-laundering records are kept for five years after the end of the business relationship);
-For a duration defined in light of its operational constraints (customer relationship management, etc.);
-To respond to legal requests or requests from authorities and regulators.

What Are the Rights of Data Subjects and How Can They Exercise Them

Subject to the conditions set out in the GDPR, you can exercise the following rights:
-Right to information: you have the right to be informed in a precise, accurate, transparent, and accessible manner;
-Right of access: you can obtain information regarding the processing of your personal data as well as a copy of these data;
-Right of rectification: if you believe your personal data are inaccurate or incomplete, you can request that these data be corrected or completed accordingly;
-Right to erasure: you can request the deletion of your personal data, within the limits permitted by regulation;
-Right to restriction of processing: in certain cases, you can request the limitation of the processing of your personal data;
-Right to withdraw your consent: if you have given your consent for the processing of your personal data, you can withdraw this consent at any time, without affecting the lawfulness of the processing carried out before the withdrawal;
-Right to data portability: when this right is applicable (processing based on consent or on a contract and carried out by automated means), you can ask HCVC to provide you with your personal data in a structured, commonly used and machine-readable format or, where technically feasible, to transfer them to another controller.

You also have a right of objection, allowing you to object to the processing of your personal data for reasons related to your particular situation. You have the absolute right to object at any time to your data being used for commercial prospecting purposes, or for profiling if this profiling is linked to commercial prospecting.

You may also give instructions regarding the retention, erasure and disclosure of your personal data after your death.

If you wish to exercise the aforementioned rights or if you simply have questions regarding the processing of your personal data, you can send an email to the following address: finance@hcvc.co or send a letter to the following address: HCVC 59 rue Beaubourg 75003 Paris

In accordance with applicable legislation, in addition to the rights mentioned above, you have the right to lodge a complaint with a data protection authority, such as the CNIL in France (www.cnil.fr – 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07).

HCVC may update its data protection policy at any time and post it online indicating the revision date. We invite you to regularly consult the HCVC website to keep informed of these updates.

HCVC has set up a procedure for the reasonable and prompt handling of complaints from its clients and investors. A complaint is a statement by the client officially recording its dissatisfaction with the management company. A request for information, for an opinion, or for a product or service clarification is not considered as a complaint.

Any complaint can be sent to HCVC by email to finance@hcvc.co.

Complaints may also be sent by post to HCVC (Elephants & Ventures), 59 rue Beaubourg, 75003 Paris, France. Complaints can be made in English or French. Complaints are handled free of charge.

An acknowledgement of receipt will be sent within a maximum of 10 business days from the date the written complaint was sent (the postmark being proof for postal mail), unless a response has been given before this period. A response will be given to the client within a maximum of 2 months from the date the written complaint was sent, unless duly justified special circumstances arise; in that case, the client will be informed of the reasons for the delay. If the response given is unsatisfactory, or if no response is given within that period, a client may refer the matter to the AMF’s mediator at the following address: Autorité des Marchés Financiers, Mediation Service, 17 place de la Bourse - 75082 PARIS-CEDEX 02 - FRANCE

For further information: http://www.amf-france.org/fr/le-mediateur
Link to the AMF Ombudsman Charter: https://www.amf-france.org/fr/le-mediateur-de-lamf/le-mediateur-mode-demploi/quelles-regles-encadrent-la-mediation
Link to the AMF mediation request: https://www.amf-france.org/fr/le-mediateur-de-lamf/votre-dossier-de-mediation/vous-voulez-deposer-une-demande-de-mediation

The AMF Ombudsman’s service is free of charge.

In accordance with regulations, HCVC has implemented organizational measures and administrative procedures to detect and manage conflicts of interest that may arise during the provision of collective management services.

The prevention and management of conflicts of interest are conducted under the general principles established by Directive 2011/61/EU (AIFM Directive, Article 14) and Commission Delegated Regulation (EU) No 231/2013 (Articles 30 to 37), which notably include the following obligations:

-Establishing a conflict-of-interest management policy;
-Detecting situations of conflicts of interest;
-Maintaining a register of encountered conflict of interest situations;
-Informing investors when conflicts of interest have not been resolved.

The conflicts of interest management policy is available at HCVC’s registered office and will be provided within 8 days on simple request by email (finance@hcvc.co) or by post.

The shareholder engagement policy of the management company is in line with Directive 2017/828, known as the "shareholders' rights" directive, aimed at promoting the long-term engagement of shareholders and mentioning the following obligations:

-Monitoring of strategy, financial and non-financial performance, risks, capital structure, social and environmental impact, and corporate governance;
-Dialogue with held companies;
-Cooperation with held companies and other stakeholders;
-Prevention and management of conflicts of interest;
-Reporting on the shareholder engagement policy.

2025 report: Voting Policy Report 2025

HCVC has a compensation policy for its staff in accordance with Article 13 of Directive 2011/61/EU (AIFM Directive), Article L. 533-22-2 of the French Monetary and Financial Code and Article 319-10 of the AMF General Regulation. HCVC applies the ESMA Guidelines on sound remuneration policies under the AIFMD (ESMA/2013/232, as amended by ESMA/2016/579), which the AMF has incorporated into its position DOC-2013-11 “Remuneration policies for alternative investment fund managers”. This compensation policy is reviewed annually by the management of HCVC to ensure its compliance with applicable regulations, taking into account the size of HCVC and of the funds it manages, its internal organization, and the nature, scope and complexity of its activities.

In accordance with Article 5 of Regulation (EU) 2019/2088 (SFDR), HCVC informs that sustainability risks are not integrated into its remuneration policy. As the funds managed are classified as Article 6 funds, no incentive mechanism related to the consideration of these risks has been implemented in the remuneration policy.

For more information: finance@hcvc.co.

This Website is governed by French law. Any use hereof must take place in compliance with French law and shall be deemed to have taken place on French territory. Only the courts within the jurisdiction of the Paris Court of Appeal are competent to hear any dispute relating to the Website, without prejudice to any mandatory rules of jurisdiction. Visitors accessing the Website from abroad must ensure compliance with locally applicable laws. HCVC may amend this legal notice at any time without notice; the applicable version is the one published on the Website.

HCVC Fund II benefits from support from the European Union under the European Investment Fund and the InvestEU Fund.

This information was last reviewed on October 22, 2026.