Altamir - 2018 Registration document

1

Business description and activities

Internal control procedure implemented by the Company

COMBAT AGAINST MONEY LAUNDERING AND TERRORIST FINANCING

B)

n payment instructions are centralised with the Chairman of the management companies in the case of the funds, and with the Chairman of the Management Company of Altamir; n fund administration, together with the bank custodian, ensures that the legal documentation is completebefore submitting the documents to the Chairman for signing; n fund administration and the accounting department ensure the pari passu distribution of investments and divestments between the funds and Altamir (for investments historically made alongside fundsmanaged by Amboise Partners SA) and between the various investment vehicles of the Apax France VIII and Apax France IX funds. As previously reported, Altamir’s Supervisory Board has created an Audit Committee, which can be assisted by the Company’s Statutory Auditors. The second objective is the accuracy of financial reporting. The objective is achieved by cross-checking accounting data with data from the securities management system. Increasingly sophisticated automation limits the risk of human error. The third objective is compliance with laws and regulations in force. The Company does everything in its power to adhere not only to general regulations, but also to the regulations specific to SCRs (investment eligibility quotas) and to listed companies. The two asset management companies have each appointed a Compliance and Internal Control Officer. The Code of Ethics is an integral part of the Rules of Procedure. The Compliance and Internal Control Officers have opted to outsource second- level controls relating to compliance and internal control of the management companies to PCI. This assistance falls under Article 313-72 to 313-76 of the AMF General Regulation applying to management companies that delegate or outsource certain functions. Amboise Partners SA andApax Partners SAS areAMF-approved portfolio management companies. They are members of France Invest, a French professional association for private equity companies. France Invest has published a Code of Ethics and reference guides. Moreover, Amboise Partners SA, Apax Partners SAS and consequently Altamir comply with the International PrivateEquityandVentureCapital ValuationGuidelinesdeveloped by France Invest, Invest Europe, BVCA and others, and the COSO internal control framework. Apax Partners LLP is regulated by the FCA and is a member of the British Venture Capital Association (BVCA), whose rules and codes are equivalent to those of France Invest. It also belongs to the European private equity association Invest Europe. B) EXTERNAL ACCREDITATIONS

n As every year, Apax Partners and Amboise Partners SA employees took part in a training course on combatingmoney laundering and terrorist financing. n Controlssuitedtothenatureofthetransactionswereperformed. Article 242 quinquies , paragraph II of the French Tax Code and Article 171 AS bis of Appendix II introduced, starting with the 31 December 2006 closing, a detailed filing requirement enabling the tax authority to check that SCRs adhere to the 50% quota imposed on them. This statement is duly filed each year with the tax authorities based on data as of 31 December and complies with the detailed calculations already made by the Company.

GENERAL ORGANISATION OF THE COMPANY’S INTERNAL CONTROL PROCEDURES REGARDING THE PREPARATION AND PROCESSING OF ACCOUNTING AND FINANCIAL INFORMATION

INTERNAL CONTROL PARTICIPANTS AND THEIR ACTIVITIES

A)

The purpose of the Company is to invest, in principle, in securities of unlisted companies, either directly, or via investment vehicles such as French or European private equity funds. Altamir continues to create value and divest alongside the Apax France VII fund, managed by Amboise Partners SA. Since 2011, Altamir has invested via Apax funds managed by Paris-based Apax Partners SAS and, since 2012, via the Apax funds advised by London-basedApax Partners LLP. Occasionally, theCompany may co-invest with these funds. For these investments, it is assisted by investment and support teams. With respect to accounting and financial information, the first objective of internal control is to verify cash flows and assets. This is achieved by implementing the following processes: n the accounting and fund administration processes are segregated; n securities are registered in “pure” nominative form and periodically reconciled with the custodian and registrars of each company;

72 Registration document ALTAMIR 2018

www.altamir.fr