Regulation
Altan Capital, SGIIC, S.A,U, as well as their funds, are subject to the inspection of the CNMV (Comisión Nacional del Mercado de Valores- Spanish Securities and Exchange Regulator). Just as the management company, the hedge funds managed by it are subject to the “Law 35/2003, of 4 November, on Collective Investment Institutions, and subsequent amendments” and to “Royal Decree 83/2015, of 13 February, amending Royal Decree 1082/2012, of 13 July”, approving the Regulations implementing Law 35/2003, of 4 November, on collective investment institutions.
In addition to the above regulation, the Management Company and its funds are subject to other regulations and supervisors:
Circulars from the National Securities Commission
These documents pertain to, among other things, the accounting standards that management companies and their funds must follow, as well as the reserved statements that they must send to the CNMV (Comisión Nacional del Mercado de Valores- Spanish Securities and Exchange Regulator) annually to carry out their supervisory tasks.
Fiscally Normative
The Management Company and its funds must forward the settlement of their taxes periodically to the Tax Office, entity in charge of the management, inspection and collection of the taxes.
FATCA
On July 1, 2014, the provisions approved by the United States, known as the “Foreign Account Tax Compliance Act” (FATCA), came into force, whose purpose is to facilitate the control and taxation of U.S. taxpayers to avoid tax evasion outside its borders. The funds managed by Altan will operate with the following “Global Intermediary Identification Numbers” (GIIN) for FATCA purposes
The obligations of the entities subject to FATCA are found in the “Agreement between the Kingdom of Spain and the United States of America for the improvement of international tax compliance and the implementation of the Foreign Account Tax Compliance Act – FATCA, made in Madrid on May 14, 2013″ as well as in the “Order HAP/1136/2014, of June 30, regulating certain matters related to the information and due diligence obligations established in the agreement between the Kingdom of Spain and the United States of America for the improvement of international tax compliance and the application of the U.S. tax compliance law for foreign accounts and approving the annual information return on financial accounts of certain U.S. persons, model 290″.
CRS
On the 1st of July 2016, “Royal Decree 1021/2015, dated the 13th of November, came into force, establishing the obligation to identify the tax residence of the persons who own or control certain financial accounts and to report on them in the context of mutual assistance”, and is applicable to the funds managed by Altan Capital, S.G.I.I.C., S.A.U.
These regulations derive, within the framework of the OECD, from the multilateral agreement on the automatic exchange of information on financial accounts and, within the framework of the European Union, from Directive 2011/16/EU, amended in December 2014 by Directive 2014/107/EU.
Prevention of money laundering and the financing of terrorism
Protection of personal data
ALTAN fully complies with its data protection obligations. Derived from this compliance, ALTAN has a Data Protection Delegate who is in charge of supervising all the related tasks in order to comply with the obligations derived from the data protection regulations. Contact with the supervisor is available through the e-mail address dpo@altamarcapital.com or by sending a communication to the address Paseo de la Castellana, 91, 28046, Madrid.
Identification of Web treatments:
- Contact: The user will be able to complete a contact form. The purpose of the processing of data obtained from this form is to meet the request submitted. This link details the basic information on data protection of the contact form.
- Cookies: This website treats own technical Cookies (necessary for web navigation). This link details the Cookie Policy.
Processing of personal data in Altan’s activity:
Among the main purposes of the data processing carried out by ALTAN are those necessary to execute the specific agreements reached, as well as to comply with the legal and fiscal obligations that may arise from the relationship with ALTAN. ALTAN will only transfer clients’ personal data between the companies of the AltamarCAM for commercial purposes, when it has the consent of its client
ALTAN has identified all the data processing it carries out, and has adopted the necessary security measures to avoid any loss and incidents in accordance with the provisions of data protection regulations.
ALTAN is committed to ensuring that all communications of personal data are to be considered confidential. However, depending on the product contracted, different entities may be assignees of personal data. Among others: (i) where applicable, the entities that are the depositories of the contracted funds, (ii) regulatory bodies and public institutions of the General State Administration, of the Autonomous and Local Administrations or authorities that may be located within or outside the European Economic Area, to which you are legally obliged to provide them, (iii) entities of the AltamarCAM, or (iv) service providers such as IT services, administration or consultancy.
The User may access, rectify, delete, as well as exercise the other rights indicated in the additional information, upon request signed by the interested party and accompanied by ID or document proving his identity, and sent to the address indicated above of the ALTAN Data Protection Delegate.
You can consult the detailed information on data protection in the following link: Altan’s Data Protection Policy. ALTAN reserves the right to unilaterally modify its privacy policy, always in accordance with current legal regulations, without affecting the processing of your data. The interested parties will be informed immediately of the change so that they can exercise the rights they consider appropriate.
In addition, you can consult the detailed information on data protection of the Depositary in “Data Protection Policy of the Depositary“.
Engagement
Directive (EU) 2017/828 of the European Parliament and of the Council of 17th May 2017 amending Directive 2007/36/EC and Law 5/2021 of 12th April, which amends the consolidated text of the Capital Companies Law, approved by Royal Legislative Decree 1/2010 of 2nd July, and other financial regulations, as regards the encouragement of long-term shareholder engagement in listed companies, as far as asset managers are concerned, aims to encourage the involvement of shareholders or shareholder managers in the companies in which they invest. As of this, greater shareholder involvement in corporate governance is one of the instruments that can contribute to improving the financial and non-financial performance of companies, also in terms of environmental, social and management factors.
To this end, management companies of collective investment vehicles must draw up and publish an engagement policy describing how they integrate their involvement as shareholders or shareholder managers into their investment policy. The purpose of this policy is to describe the principles followed by the management companies of collective investment vehicles in relation to the execution of the voting rights of the companies in which their investment vehicles hold open positions. You can find below the Altan Capital S.G.I.I.C., S.A.U. Engagement Policy.
