Regulatory information - Méreau Finance

Date of last update: September 14, 2026

This page brings together the regulatory information that Méreau Finance makes permanently available to its clients, prospective clients, and the public as an authorized crypto-asset service provider, in accordance with Regulation (EU) 2023/1114 known as MiCA. It includes all public information relating to the handling of client complaints and the management of conflicts of interest.

1. Regulatory status

Méreau Finance is registered with the Autorité des marchés financiers as a digital asset service provider (DASP) under the number A2026-025, for the provision of crypto-asset portfolio management services on behalf of clients.

Méreau Finance does not provide crypto-asset custody services. Crypto-assets are held with authorized third-party partners, who exclusively manage the private keys.

Investing in crypto-assets carries a risk of partial or total loss of the invested capital. Past performance does not guarantee future results. Details of the company's identification can be found in the Legal Notice, and the pricing conditions in the pricing policy.

2. Customer complaint handling

2.1. Purpose and commitment

Méreau Finance is committed to processing complaints promptly, fairly, and transparently, in accordance with the MiCA regulation. The objective is to ensure a clear organization, transparent tracking, and an appropriate response for each client.

2.2. Scope

The procedure covers all activities of Méreau Finance and applies to all personnel: executives, employees, and service providers.

2.3. Responsibilities and access to information

The Compliance Department Manager is responsible for the complaint management processes. They have access to all relevant information, on a need-to-know basis and in compliance with applicable data protection laws.

2.4. General obligations of the company

Méreau Finance puts in place the means and procedures enabling its staff to identify and process complaints. The company undertakes to:

clearly inform its clients via its website, with an updated description of the procedure, a standard form, and the terms and conditions for submitting complaints; ;
publish these documents in all languages used for the marketing of its services, and make them easily accessible and downloadable; ;
provide the procedure upon the customer's request, as well as upon acknowledgment of receipt of a complaint; ;
communicate with clients in clear and tailored language; ;
send an acknowledgement of receipt within a maximum of two business days; ;
keep the customer informed of the progress of the processing and explain the possible remedies in the event of total or partial rejection; ;
ensure that the conditions for the admissibility of claims are fair and reasonable.

2.5. General communication rules

Communication relating to a complaint is conducted in writing, electronically or, at the customer's request, in paper form. Any communication addressed to a customer is drawn up in the language used by the latter to formulate their complaint, provided that this language is among those listed in section 2.7.

2.6. Deposit channels

All claims are filed and processed. free of charge. For any complaint regarding a product or service provided by Méreau Finance, the customer is invited to contact the Compliance Department:

by email to contact@mereau-finance.com ;
by post to Méreau Finance, 35 rue Jean Jaurès, 92800 Puteaux, France.

Complaints should be addressed to the attention of Gilbert Szymkowiak, Compliance Officer, 35 rue Jean Jaurès, 92800 Puteaux. It is important to indicate the nature of the request in the subject line of the email or mail, using the terminology «Complaint».

Complaints are received by email or post. For an oral complaint that does not allow the customer to obtain a dated copy of their request, the company invites the customer to formalize their dissatisfaction on a durable written medium if immediate and complete satisfaction cannot be provided.

2.7. Language of the complaint

Clients can file a complaint in the languages used by Méreau Finance for the marketing of its services and communication with its clients, namely French and the’English.

2.8. Conditions of admissibility and information to be provided

Claims may be submitted using the form reproduced in section 2.20, although its use is not mandatory. To be processed, a claim must contain:

the client's identification information; ;
the identity and capacity of the person filing the claim on behalf of the client, whose authorization may be verified; ;
the contact details to be used during the processing; ;
a precise description of the complaint: facts, dates, circumstances and grounds.

In the event of incomplete information, Méreau Finance contacts the client to obtain the necessary clarifications.

2.9. Communications not constituting a complaint

If a communication does not constitute a complaint, the procedure does not apply. In this case, even if the message was sent via a channel dedicated to complaints, Méreau Finance informs the client that their request is not classified as a complaint, explains the reasons for this classification, and warns them that their request has been redirected to the appropriate department.

2.10. Acknowledgment of receipt and verification of admissibility

Upon receipt of a complaint, a case manager is designated. Given the size of the company, this role is currently performed by the Compliance Officer. The process entails:

recording of the complaint in a dedicated register; ;
sending an acknowledgment of receipt to the customer within two business days, using a template that includes all mandatory elements; ;
the inclusion of a copy of the complaint when it was submitted via an electronic form; ;
the customer information regarding the admissibility of their complaint, immediately if possible, or within two business days after obtaining the necessary additional information.

2.11. Incomplete claims and rejection

If a claim is incomplete, Méreau Finance informs the client upon receipt of the missing elements, with a maximum period of five business days to provide them. If the client does not transmit the requested information within this period, or if the claim is manifestly inadmissible, the company notifies them of the reasons for rejection:

within seven working days of the expiry of the completion period; ;
or within two working days if the inadmissibility is immediate and requires no further verification.

2.12. Processing of the complaint

When a claim is admissible, the case manager quickly assesses its clarity and completeness.

if it is incomplete or inaccurate, it requests the additional information within a maximum period of ten working days, and at the latest within two days following the identification of the need; ;
he cannot demand information already in the possession of Méreau Finance; ;
He collects and analyzes all relevant data, keeps the client informed of the processing steps, and responds without delay to any reasonable request for information.

2.13. Applicable deadlines

Step	Deadline
Acknowledgment of receipt	2 business days
Standard complaint response	1 month
Complex claim: customer information regarding the postponement	Before the end of the first month
Maximum exceptional delay, complex cases	2 months
Submission of additional information by the client	5 business days
Request for additional information under review	10 business days at most
Notice of rejection after the deadline for submitting supplementary documents has expired	7 business days
Notice of rejection in the event of immediate inadmissibility	2 business days

For complex claims, the client is informed before the end of the first month, with a justification for the delay and an indication of the new timeframe, which cannot exceed two months. If this two-month timeframe cannot be met, Méreau Finance sends an interim response specifying the reasons for the delay, the additional time required, and the final response deadline.

2.14. Response to the complaint

The response is complete, reasoned, and transmitted in writing, or on an agreed durable medium, within the scheduled timeframe. In the event of total or partial rejection, the case manager clearly explains the reasons for the decision and informs the client of the available avenues of appeal.

2.15. Consistency of decisions

Méreau Finance ensures consistency in the handling of similar complaints. A complaints register is kept up to date and the case manager checks for any precedents. In the event of a decision that differs from a comparable case, they consult Tristan Goutte, President of Méreau Finance, whose binding opinion is rendered within seven business days.

2.16. Monitoring and reporting

Méreau Finance continuously monitors data related to complaints: average processing times at each stage, total number of complaints received and missed deadlines, topics involved, and conclusions of the investigations conducted.

The Compliance Officer reports directly to management on the effectiveness of the procedure and the corrective measures to be taken. An annual report is submitted to management, including the ongoing analysis of the procedure and its recommendations, the dysfunctions identified and the corrective actions implemented, as well as the assessment of compliance with the procedure. More frequent reporting is carried out in the event of major corrective measures.

2.17. Governance, Training, and Preservation

The procedure is defined and approved by the management body, which ensures its correct implementation, with the unanimity of the managers being required. It is distributed to all staff by email, via internal channels, and on a dedicated space. Appropriate training is provided to each employee upon onboarding and is then renewed annually, with content adjusted according to their role and exposure to complaints. Case handlers also have a good command of the products, services, contracts, and tools, as well as the required level of authorization.

Complaints are archived in accordance with internal compliance procedures, in compliance with the regulatory obligations applicable to crypto-asset portfolio management companies, notably those defined by the AMF.

2.18. Mediation

If the customer remains dissatisfied with the proposed solution, or in the absence of a response within the maximum period of two months, they may refer the matter to a mediation service. In accordance with Title I^he of Book VI of the Consumer Code, every consumer has the right to use a consumer mediator free of charge.

The Autorité des marchés financiers makes available a public ombudsman competent within the meaning of Article L. 611-1, 7°, of the Consumer Code, in the event of a dispute between a professional and a consumer, the latter being defined as a natural person acting for purposes that do not fall within the scope of their commercial, industrial, craft, liberal, or agricultural activity. The AMF ombudsman may also be referred to in the event of a dispute falling within the competence of the AMF opposing a professional to a client company acting not for professional purposes, but in its capacity as a saver or investor.

electronically, by filling out the online form available at the AMF website ;
by post: The AMF Ombudsman, Autorité des marchés financiers, 17 place de la Bourse, 75082 Paris Cedex 02, France.

2.19. Revision of the procedure

The procedure is reviewed by the Chief Compliance Officer at least once a year, in January, or whenever significant legislative changes or identified deficiencies justify it. Any substantial modification is approved by the management body.

2.20. Complaint form

The use of this form is not mandatory. It can be copied into an email or letter addressed to the Compliance Department.

1. Customer contact information

Name or company name
Country of incorporation, if applicable
Customer number, if applicable
Address
Email
Telephone

2. Person filing the complaint, if different from the customer

Name
Quality or function
Email
Telephone

3. Description of the claim

Item or service concerned
Date of the incident
Detailed description
Attachments, if applicable

4. Desired response mode

By email
By mail

Date and signature.

3. Management of Conflicts of Interest

3.1. Objectives

Méreau Finance's conflict of interest management policy complies with the requirements of the European MiCA Regulation (EU 2023/1114) applicable to crypto-asset service providers. It governs situations in which the personal, professional, or financial interests of an employee, manager, or partner might interfere with those of clients. The objective is to preserve integrity, transparency, and trust in the client relationship, ensuring that decisions are always made in their best interest.

3.2. Scope

The policy covers all staff members, including the risks associated with outsourcing and the use of external providers such as consultants. It addresses the entire conflict of interest management cycle:

Identification identification of potential situations based on internal experience and known scenarios; ;
Prevention procedures, training, monitoring, reporting, gifts policy and audits; ;
Management application of a defined process to handle detected conflicts, with a view to continuous improvement; ;
Disclosure transparent information for clients and authorities, in accordance with the MiCA regulation.

The policy takes into account cases related to potential membership in a corporate group, as well as internal or external conflicts affecting clients, companies, or partners. A conflict register is kept up to date. When risks cannot be completely eliminated, clients are informed in a clear and appropriate manner before any action is taken on their behalf.

3.3. Definition

A conflict of interest refers to any situation in which the personal, financial, or professional interests of an individual or the company may conflict with those of a client. These conflicts may be actual, potential—meaning likely to occur—or apparent, having no proven effect but likely to be perceived as such. They can arise between two clients, between the company and a client, or between an employee and a client, and may affect the objectivity, loyalty, or quality of the service provided.

3.4. Identification of risky situations

The policy identifies situations that may harm clients' interests in the context of the company's regulated services, in particular portfolio management and crypto-asset advisory. It adapts to the size, organization, and complexity of the activities. It covers, in particular, conflicts between Méreau Finance and its shareholders, related parties, management members, employees, or clients, as well as conflicts between multiple clients with opposing interests.

Sources of conflict include, in particular:

the simultaneous management of clients with competing interests on certain crypto-assets; ;
the granting of commissions, remuneration or gifts to related persons; ;
the payment of incentives to third parties, business introducers, or outsourced service providers; ;
dealing on own account in competition with that of clients; ;
the receipt of remuneration from counterparties in transactions; ;
market manipulation ;
the exploitation of confidential or non-public information for personal gain; ;
the performance of competing activities or functions within partner or competing entities; ;
the multiplicity of services provided to the same client, or the exercise of responsibilities in multiple entities; ;
failures to comply with obligations to combat money laundering and terrorist financing; ;
the holding, by an external service provider, of interests in competing companies, or the inappropriate use of sensitive data.

Personal, professional, economic, or political relationships with entities having divergent interests are also taken into account, including those that existed within the past three years.

3.5. Prevention measures

Overall, the company regularly trains its teams, maintains a proactive risk mapping and a register of potential and actual conflicts, ensures the competence of its service providers, and organizes the functional separation of departments that may have conflicting interests. The compliance department continuously monitors the policy, controls sensitive situations, and applies the four-eyes principle. Specific policies govern remuneration and personal transactions.

For related persons, the rules specifically prohibit participating in negotiations with a counterparty where a close relative is employed, receiving gifts of significant value, or becoming involved in activities that could compromise their objectivity. Procedures detect and prevent preferential access to information, front running practices, and preferential pricing treatments, backed by a fair and non-discriminatory pricing policy.

For members of the governing body, any conflict situation must be declared and recorded, and entails abstention from voting as well as exclusion from debates and related documents. External mandates in competing entities are prohibited.

Regarding third-party service providers, the company applies a transparent and objective selection process, conducted by individuals without personal interest, preceded by thorough due diligence and documented risk assessment. Contracts include strict clauses on confidentiality, prohibition of competitive use of data, and independence, and regular audits are conducted.

Regarding incentives and remuneration, the company eliminates any direct link between the revenues from one activity and those from another likely to create a conflict, and applies specific policies on remuneration as well as on gifts and entertainment.

Méreau Finance finally maintains a detailed register of actual or potential conflicts, mentioning the description, the parties concerned, the measures taken, and their follow-up. This register is kept for a minimum of five years and is accessible to the regulator upon request. The resolution of conflicts follows the risk mapping when they are listed therein, or is the subject of a formal decision by the compliance department.

3.6. Conflict Management Procedure

The procedure applies to all staff members, operational managers, and members of the executive body. Related persons continuously monitor their personal and professional situations and report any potential conflict without delay via a dedicated form. Operational managers process the declarations and implement corrective measures. The Compliance Officer, Gilbert Szymkowiak, maintains the conflict register, updates the risk mapping, advises management, and ensures compliance with the regulatory framework. Executive leaders define ethical guidelines, validate procedures, review sensitive cases, and ensure that decisions take clients' interests into account.

Identification is based on self-assessment forms, individual interviews, permanent access to the policy, and quarterly reminders. Any identified situation must be reported; failure to comply with this obligation may result in disciplinary sanctions ranging from a warning to dismissal, depending on the severity and impact, with the right to an internal appeal.

The declarations are reviewed within five days by the Compliance Officer, who analyzes the nature, causes, and consequences of the conflict. It is then managed according to the existing mapping, or integrated into it if it is new. Three main strategies can be applied:

abstention, excluding the person concerned from decisions related to the conflict; ;
the reassignment, by modifying its missions to eliminate the risk; ;
transparency, while informing stakeholders of the measures taken.

Regular monitoring is ensured through quarterly reviews, with documentation and archiving of all actions. When internal measures cannot reasonably eliminate the risk to clients' interests, clients are informed prior to any intervention, with an appropriate level of detail to enable them to make an informed decision. All stages, from reporting to resolution, are tracked and retained for at least five years.

3.7. Internal Controls and Audits

The policy is reviewed at least once a year, or more frequently if necessary. Any identified deficiency leads to the implementation of appropriate corrective measures. The internal control system is based on three complementary levels:

Level 1, permanent operational control The Compliance Officer provides and updates the forms required to comply with procedures on an annual basis. Any failure to use them or non-compliance must be reported to them. Depending on the severity, measures may include updating the policy within two weeks, corrective training, or disciplinary action.
Level 2, annual audit jointly prepared by the Compliance Officer and the legal department, it verifies the proper identification and treatment of risks by the first line of defense. Corrections include updating the policy within one month, specific training, and, if necessary, sanctions.
Level 3, biennial periodic inspection conducted by an independent Level 1 and 2 committee, it assesses the adequacy of detection criteria, the relevance of risk assessment, compliance with procedures, and the effectiveness of the alert and sanction system. Its frequency can be adjusted based on changes in activities and the volume of operations.

Each audit results in a report listing the detected weaknesses and corrective actions.

In accordance with Article 72 of the MiCA Regulation, this page constitutes the clearly identifiable space on which Méreau Finance publishes the nature and sources of conflicts of interest, as well as the measures implemented to prevent or mitigate them. This information is regularly updated, permanently accessible, and available in the languages used by the company with its clients. Disclosure to clients does not, in itself, constitute a sufficient management measure: it complements internal prevention and control measures.

3.8. Indicator monitoring

The effectiveness of the policy is measured using four key performance indicators:

Number of conflict of interest declarations inventory of potential or proven conflicts recorded via the dedicated form and entered in the register, in order to assess the transparency and vigilance of the staff.
Average resolution time measurement of the processing time for declared conflicts, reflecting operational efficiency.
Number of policy violations : monitoring omissions or non-compliances in declarations, making it possible to identify implementation gaps.
Training rate Percentage of employees who have completed the mandatory training on conflicts of interest.

The Compliance Officer submits a detailed report annually to the management body, and on an ad hoc basis in the event of significant breaches. This report describes the situations encountered, the preventive and corrective measures taken, as well as the shortcomings identified and the actions initiated. The management body defines and approves the policy, oversees its implementation, periodically evaluates its effectiveness, and ensures that shortcomings are corrected. The policy is supplemented by a declaration form template and a separate document containing the company's specific risk mapping.

3.9. Review and continuous improvement

The policy is subject to a formal review at least once a year, in January. An immediate update is triggered as soon as a significant change in the legislative or regulatory framework, the business model, the internal organization, or the risk profile is observed: launch of a new service, entry into a new market, major modification of operational processes, or occurrence of a significant compliance incident.

Each revision cycle is based on structured feedback, making it possible to identify best practices to be sustained, difficulties encountered in implementing the policy, and areas for improvement noted during level 1, 2, and 3 controls. It includes a systematic update of the risk mapping, incorporating newly identified scenarios, business developments, and trends observed in the sector.

Any substantial modification is subject to the approval of the governing body. The validated changes are immediately communicated to all related individuals through internal channels and, if necessary, are the subject of targeted training. The effectiveness of the adjustments is monitored over time using key performance indicators, ensuring a complete continuous improvement loop.

4. Documents to download

[DOWNLOAD LINKS TO BE ADDED] The documents «Information regarding the handling of client complaints» and «Information regarding the management of conflicts of interest» are made available in PDF format, free to download, and provided to any client upon request as well as upon acknowledgment of receipt of a complaint.

5. Contact

For any questions regarding the information on this page: contact@mereau-finance.com, or Méreau Finance, 35 rue Jean Jaurès, 92800 Puteaux, France.