Disclaimer.

1. Investor Type

The site www.walnut.ai is a website dedicated to professional investors who are able to understand all of the information disclosed therein and the specific risks attached thereto. If you are not a professional investor, we invite you to refrain from accessing, visiting or using this website.

2. Performance Information

Past performance is not necessarily indicative of future results and there can be no assurance that any Walnut Investments fund or strategy will achieve comparable results, or that any investments made by Walnut Investments in the future will be profitable.

3. General

Neither Walnut nor any of Walnut affiliates makes any representation or warranty, express or implied, as to the accuracy or completeness of the information contained herein. Unless otherwise specified, the source for all graphs, charts and information in the Materials is Walnut.

Certain information contained in the Materials has been obtained from sources outside Walnut. While such information is believed to be reliable for purposes used herein, no representations are made as to the accuracy or completeness thereof and Walnut does not take any responsibility for such information. Certain information contained in the presentation discusses general market activity, industry or sector trends, or other broad‐based economic, market or political conditions and should not be construed as research or investment advice.

4. Forward‐Looking Statements

These Materials may contain forward‐looking statements which reflect Walnut’s current views with respect to, among other things, Walnut operations and financial performance. You can identify these forward‐looking statements by the use of words such as “outlook,” “believes,” “expects,” “potential,” “continues,” “may,” “will,” “should,” “seeks,” “approximately,” “predicts,” “intends,” “plans,” “estimates,” “anticipates” or the negative version of these words or other comparable words.

Such forward‐looking statements are subject to various risks and uncertainties. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. These factors should not be construed as exhaustive and should be read in conjunction with the other cautionary statements that are included in this presentation. Walnut undertakes no obligation to publicly update or review any forward‐looking statement, whether as a result of new information, future developments or otherwise.

5. Not an Offer

These Materials are provided as an overview of Walnut research and development efforts and are for informational purposes only, and do not constitute an offer to sell, or a solicitation of an offer to buy, any security or instrument, or a solicitation of interest in any particular Walnut fund, account or strategy. Any decision to invest in a fund or strategy should only be made after reviewing the offering document, conducting such investigations as an investor deems necessary and consulting the investor’s own legal, accounting and tax advisors in order to make an independent determination of the suitability and consequences of an investment

6. Exclusion of Liability

Walnut Investments is not liable for any losses or damages arising in any way from (i) the information contained on this website, (ii) any information transmitted via this website or (iii) the functioning or non-availability of this website. Walnut is not liable for any losses or damages that may be caused to any equipment and other software due to any viruses, defects or malfunctions in connection with access or use of this website.

7. Privacy Policy

We appreciate your interest in our website and our company. We make every effort to protect your personal data when it is collected, processed and used during your visit of our website. Your data is protected in accordance with statutory requirements, including the General Data Protection Regulation (EU) 2016/679, whose implementation is described in the personal data protection policy below.

Personal data is collected and processed on our website as far as you have actively provided such data by registering yourself. Walnut may collect different categories of personal data such as, in particular: last Name, first Name, email, profession, company, phone number, job title, country.

Walnut is also likely to collect IP addresses, cookies, and information about your browser in order to perform security or statistical analysis-related processing on an anonymous basis.

The purpose of the personal data use is to enable the carrying out of statistical analysis operations in order to improve the services offered and to enhance the security of the website. This information also allows the provision, if any, of data relating to collective investment vehicles managed by Walnut.

Personal data is disclosed to service providers in order for them to carry out the services specifically dedicated to Walnut’s scope of activity.

Walnut outsources some of its processing and might in this instance transfer data outside of the European Union. In such a case, Walnut is committed to have the service providers contractually agree to adequate data protection.

Walnut is committed to storing your personal data no longer than necessary for the purpose for which it was processed. Furthermore, Walnut stores your personal data in accordance with the retention period imposed by current regulations.

Policies and disclosures.

1. Privacy policy

We appreciate your interest in our website and our company. We make every effort to protect your personal data when it is collected, processed and used during your visit of our website. Your data is protected in accordance with statutory requirements, including the General Data Protection Regulation (EU) 2016/679, whose implementation is described in the personal data protection policy below.

Personal data is collected and processed on our website as far as you have actively provided such data by registering yourself. Walnut may collect different categories of personal data such as, in particular: last Name, first Name, email, profession, company, phone number, job title, country.

Walnut is also likely to collect IP addresses, cookies, and information about your browser in order to perform security or statistical analysis-related processing on an anonymous basis.

The purpose of the personal data use is to enable the carrying out of statistical analysis operations in order to improve the services offered and to enhance the security of the website. This information also allows the provision, if any, of data relating to collective investment vehicles managed by Walnut.

Personal data is disclosed to service providers in order for them to carry out the services specifically dedicated to Walnut’s scope of activity.

Walnut outsources some of its processing and might in this instance transfer data outside of the European Union. In such a case, Walnut is committed to have the service providers contractually agree to adequate data protection.

Walnut is committed to storing your personal data no longer than necessary for the purpose for which it was processed. Furthermore, Walnut stores your personal data in accordance with the retention period imposed by current regulations.

2. Best selection and execution policy

Walnut has an obligation to act in the best interests of its clients and of the funds it manages or sub-manages. To this end, the company is subject to an obligation of best selection and best execution and applies a dedicated procedure.

Best Selection: under the supervision of Walnut’s investment committee, financial intermediaries & brokers are selected based on the following criteria:

  • Intermediation / brokerage costs
  • Quality and reliability of execution
  • Capacity to deal with large orders
  • Quality of confirmation flows and back office processes

The fund managers are required to monitor that actual execution flows are in line with the above. Quality is assessed globally and not deal by deal. Failure to execute, confirm and settle orders within Walnut’s quality standards is reported to Walnut’s management and investment committee.

Best execution: when selecting a new broker, Walnut requires that such broker provides its own best execution policy.

3. Conflicts of interest policy

Walnut has drawn up an official policy for the management of conflicts of interest and introduced specific provisions in organisational terms (means and procedures) and monitoring in order to prevent, identify and manage situations of conflict of interest which may harm the interests of its customers.

Nevertheless, if any conflicts of interest appear, the latter will be managed in the interest of the customer, that’s to say in a fair manner, and providing them with complete and relevant information.

So, in relation to situations of conflict of interest Walnut will permit itself to:

  • Carry out the activity or transaction insofar as the organisation allows the potential situation of conflict of interest to be managed appropriately;
  • Inform the customer should certain conflicts of interest exist and give them the necessary information on their type and origin;
  • Where applicable, not carry out the activity or transaction which leads to a conflict of interest.

It must be reiterated that Walnut is a company managed independently of any banking or financial group. The internal control of the company is adapted to its size and its activity. The aim of this policy is to indicate the main measures which allow us to achieve this objective of managing conflicts of interest. In this regard:

  • The agreements concluded with investment vehicle or managed or consulted portfolio providers will remind them of their obligations with regard to the duty to advise, which should prevent any situation of conflict of interests at their level;
  • Walnut has drawn up guidelines and procedures for personal transactions;
  • Walnut does not benefit from any retrocession of turnover fees from the depositary or other forms of retrocession from financial intermediaries selected to negotiate orders;
  • There is no soft commission with these different partners;
  • Walnut is totally independent of the financial intermediaries it selects;
  • Walnut has drawn up guidelines and procedures on gifts and benefits.

Walnut has a duty to manage all conflicts of interest, from their detection to appropriate management. In this regard, Walnut has established an organisation which will:

1°. Avert the appearance of conflicts of interest, by raising awareness of the rules and codes of good in-house practice amongst all its staff, and by the introduction of strict rules and procedures:

  • The setting up of an in-house control system;
  • The separation of duties which may generate conflicts;
  • Permanently ensuring that the offer of products and services which Walnut offers its customers clearly matches their profile and expectations, and is never in conflict with their interests;
  • Prohibition of transactions of a personal nature which do not comply with the rules set by the company:
  • Training for all staff and raising of their awareness of good professional practice;
  • Prohibition of the use of the services of service providers or connected companies, unless this is declared;
  • Formalisation of these rules in relation to operational procedures and normative documentation: code of ethics, procedures;

2°. Ensure that staff comply with the professional obligations to which they are subject in the exercise of their activities and comply with the regulatory provisions applicable to the latter. In this connection, organisational measures and procedural rules have been put in place to prevent conflicts of interest, in particular:

  • Ethical rules which impose an obligation of discretion and confidentiality for any information collected during transactions with customers and aiming to guarantee the fairness and loyalty required in relationships with customers;
  • Identification and monitoring of payments received or paid by branches when transactions are carried out with customers;
  • Monitoring of personal transactions for the staff concerned;
  • Transparency in relation to staff payments;
  • Transparency in relation to gifts or benefits received in relation to professional activities;
  • Transparency of corporate powers exercised by the heads of branches or their employees in connection with their professional duties or in a private capacity;
  • Monitoring and control of the quality and legality of commitments and services provided by external service providers.

3°. Identify situations of conflict of interests which may damage the interests of customers, by drawing up a risk map of these conflicts of interests. This map will specify the activities or transactions in which a conflict of interest is likely to occur. The RCCI (Internal Control Compliance Manager) of Walnut has a duty to ensure that this mapping is kept up-to-date;

4°. Manage potential situations of conflict of interest:

  • By giving customers complete and objective information, refraining from using biased arguments while indicating restrictions and risks associated with certain products or transactions;
  • By requiring employees to declare the gifts and benefits they have received to the Internal Control Compliance Manager in accordance with the rules set by Walnut and, as soon as they occur, any situations of conflict of interest in which they find themselves, where applicable (the Internal Control Compliance Manager will then take charge, with the people concerned, of resolving this conflict).

Walnut Investments is a French portfolio management company regulated by the Autorité des Marchés Financiers (AMF) under number GP-18000021 with a share capital of 1 010 000€.


Walnut Investments is registered with the NFA as a Commodity Pool Operator & Commodity Trading Advisor under number 0523913.


The material on this website is provided for informational purposes only and does not constitute an offer to sell, a solicitation to buy, or a recommendation or endorsement for any security or strategy, nor does it constitute an offer to provide investment advisory services by Walnut.


In addition, the material offers no opinion with respect to the suitability of any security or specific investment. No information contained herein should be regarded as a suggestion to engage in or refrain from any investment-related course of action as none of Walnut nor any of its affiliates is undertaking to provide investment advice, act as an adviser to any plan or entity subject to the Employee Retirement Income Security 
Act of 1974, as amended, individual retirement account or individual retirement annuity, or give advice in a fiduciary capacity with respect to the materials presented herein. If you are an individual retirement or 
other investor, contact your financial advisor or other fiduciary unrelated to Walnut about whether any given investment idea, strategy, product or service described herein may be appropriate for your circumstances. All investments involve risk, including loss of principal. Walnut makes no guarantees as to the accuracy or completeness of the views expressed in the website. The views are subject to change, and may have become unreliable for various reasons, including changes in market conditions or economic circumstances. As Walnut Algorithms is fully dedicated to this sole project, its team as been presented in this website along with the Walnut Investments team.