Altamir - 2018 Registration document

Business description and activities

Internal control procedure implemented by the Company

1.5 INTERNAL CONTROL PROCEDURE IMPLEMENTED BY THE COMPANY

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GENERAL FRAMEWORK

In the remainder of this document, unless otherwise specified, the term “Company” refers to both Amboise Partners SA and to Altamir. The Company keeps an internal control and procedures manual, which is reviewed and expanded on a regular basis. The latest complete revision was in December 2018. The manual continues to be updated periodically.

Amboise Partners SA and Altamir use the internal control principles described in the COSO (Committee of Sponsoring Organizations of theTreadwayCommission) report as aguideline. COSO defines internal control as follows: “Internal control is a process, effected by an entity’s board of directors, management andother personnel, designed toprovide reasonable assurance regarding the achievement of objectives in the following categories: n effective and efficient operations; n accuracy of financial reporting; and n compliance with laws and regulations.” The report also details the components of internal control: n “Control Environment; n Risk Assessment; n Control Activities: adopting standards and procedures that contribute to ensuring that management’s priorities are implemented; n Information andCommunication: relevant informationmust be identified, capturedandcommunicated ina formand timeframe that enables people to carry out their responsibilities; n Monitoring: internal control systems must themselves be monitored – a process that assesses the quality of the system’s performance over time.” An internal control system designed to address the objectives described above does not guarantee that the objectives set will be achieved, because any procedure has inherent limits. Concerning effective and efficient operations, Amboise Partners SA and Altamir have a three-part objective: 1) identify and carry out the best investments possible in line with the Company’s strategy, 2) oversee the performance of the companies in the portfolio and adhere to the plan approved with their managers, 3) protect its own assets or assets under management by controlling cash flows, financial instruments and securities in the portfolio. Altamir invests either on a pari passu basis with the funds managed by Amboise Partners SA, or as an investor in the Apax France VIII-B, Apax France IX-B and Apax Development funds managed by Apax Partners SAS, or in the Apax VIII LP, Apax IX LP and Apax Digital funds, advised by Apax Partners LLP. Occasionally, Altamir co-invests with these funds. The procedures relating to Altamir are therefore inextricably linked to those of Apax Partners.

MEASURES TAKEN IN 2018

The Company made progress in several areas: n an external team continued to perform periodic internal controls; n the manual of procedures was completely updated to include processes outsourced to Apax Partners SAS; n IT security rules were reinforced.

CONTINUED PERIODIC CONTROLS OF INTERNAL CONTROL AND THE CORRECT APPLICATION OF THE REGULATIONS SPECIFIC TO SCRs (QUOTAS)

A)

Controls carried out during the year included the following: n ensuring the staff at Apax Partners and Amboise Partners SA adhered to the Code of Ethics, especially regarding personal investments; n monitoring legal registers; n adhering to regulatory ratios applicable to SCRs; n adhering to the regulations governing voting at Annual General Meetings; n monitoring short-term investments of cash; n ensuring compliance in howprocedures for combatingmoney- laundering and terrorist financing are applied; n monitoring the corporate officer responsibilities of Apax Partners’ staff; n verifying that themethods used toprevent and resolvepotential conflicts of interest are in compliance. No significant anomalies were detected. The Company will continue to be vigilant and to strengthen procedures in all the areas identified.

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ALTAMIR 2018

Registration document