- Selection policy
- Conflict of interest management policy
- Voting policy
- Report on intermediation fees in 2016
- Handling of claims
- Prevention of market timing practices
- Compensation policy
1. Best selection policy for financial intermediaries
The financial intermediaries’ selection policy is available for investors upon request to METROPOLE Gestion.
2. Conflict of interest management policy
In accordance with its principles and the prevailing regulations resulting from the transposition of MiFID, Metropole Gestion has defined a policy for identifying, preventing and managing conflicts of interest.
A conflict of interest may arise when an investment services provider carries out activities either on behalf of a client or on a proprietary basis, which come or may come into conflict with the interests of another client or group of clients if these activities are not organised and verified in an appropriate manner.
The purpose of this policy is to:
- establish formal procedures for identifying situations giving rise to or likely to give rise to a conflict of interest involving an appreciable risk of harming clients’ interests,
- define the procedures to be followed and the steps to be taken with a view to managing these conflicts.
These mechanisms are characterised by, inter alia:
- a business line organisation devised to avoid giving rise to conflicts of interest and decisions being made by the company contrary to clients’ interests,
- procedures based on the principles of fairness in the processing of the orders placed with financial intermediaries, in particular in terms of the allocation of assets or financial instruments,
- an employee remuneration policy not based on purely commercial objectives.
If the organisational and administrative measures taken by Metropole Gestion to manage conflicts of interest do not suffice to guarantee with reasonable certainty that the risk of harming the client’s interests will be avoided, prior to acting in its name Metropole Gestion will inform the client clearly of the general nature and/or the source of the conflict of interest. This information will be provided to the client on a durable medium and will be sufficiently detailed so that the client can make an informed decision.
Metropole Gestion will maintain an effective conflict of interest management policy that is appropriate with respect to the size, organisation, nature, importance and complexity of its activity.
3. Voting policy
The voting policy sets out the principles applied by METROPOLE Gestion when exercising voting rights at general meetings of companies whose shares are held in the portfolio.
The voting policy may be obtained by investors by clicking here.
Report on exercising voting rights
This report describes the conditions in which METROPOLE Gestion exercised its voting rights in line with its voting policy. The report on exercising voting rights may be obtained by investors by clicking here.
4. Report on intermediation fees in 2016
In the fiscal year of 2016 METROPOLE Gestion used investment decision-making and order execution services for the purpose of carrying out equity transactions held by UCITS, AIFs and institutional mandates.
In accordance with the provisions of Article 314-82 of the General Regulations of the Autorité des Marchés Financiers (French securities regulator), the breakdown of fees applied to investment decision-making and order execution services is as follows:
- 60% of total intermediation fees for investment-decision making services;
- 40% of total intermediation fees for order execution services.
In 2016, METROPOLE Gestion did not enter into shared fee agreements with market intermediaries.
The measures implemented to prevent or handle any conflicts of interest in the choice of service providers are defined and governed in the Intermediary Selection Policy and the Conflicts of Interest Management Policy.
No conflicts of interest were identified during the fiscal year.
5. Complaints handling
As required by the applicable regulations, METROPOLE Gestion has put in place a procedure for handling any complaints it may receive from clients. Note that: "a complaint is an expression of client dissatisfaction with the service provider. A request for information, an opinion, a clarification or a service does not constitute a complaint".
Complaints should be sent to Métropole Gestion, 9 Rue des Filles Saint Thomas, 75002 Paris. Clients will not be charged in connection with the complaints procedure.
The client will be sent a letter acknowledging receipt of the complaint within ten business days of receipt, unless a response has been given in the meantime. Subject to any duly justified special circumstances, the asset management company will respond to the client within two months of receipt of the complaint.
In the event of a persisting disagreement, clients may refer matters to the AMF mediator: Médiateur de l’Autorité des marchés financiers, 17 Place de la Bourse, 75082 Paris Cedex 02.
The AMF mediation application form and the mediation charter are available on the AMF website: http://www.amf-france.org
6. Prevention of market timing practices
Pursuant to the AMF’s position 2004-07 on the prevention of market timing and late trading risks, “the management company must refrain from disclosing the composition of the portfolio in real time.
The only exceptions are:
- For dedicated AIF, provided the information is disclosed simultaneously to all holders;
- For UCI in which professional investors supervised by the ACPR (French prudential supervision and resolution authority), the AMF or equivalent European authorities invest, in which case the management company may disclose — directly or indirectly through a third party — the composition of the fund portfolio to these investors within a period not less than 48 hours after publication of the net asset value, for the purposes of calculating the regulatory requirements relative to Directive 2009/138/EC (Solvency II)."
In view thereof, METROPOLE Gestion may send the relevant investors information on the composition of the portfolio in accordance with the foregoing.
7. Compensation policy
Details of METROPOLE Gestion's staff compensation policy
METROPOLE Gestion has devised a compensation policy, pursuant to regulations, based on compensation practices consistent with sound and effective management and discouraging inappropriate risk taking in view of the funds' risk profiles, regulations or prospectuses.
The policy applies to all METROPOLE Gestion staff.
METROPOLE Gestion's staff compensation comprises a fixed component, which may be supplemented by a variable component.
As the fixed component accounts for a relatively large proportion of total compensation, the variable component is optional.
The variable component comprises a cash bonus awarded at the Executive Management's discretion. There is no guaranteed variable compensation or signing bonus.
The policy specifies the rules on variable compensation for the categories of staff identified by the regulations, namely risk-takers, controllers and any employees who, in view of their total compensation, are at the same compensation level as the Executive Management and risk-takers whose professional activities have a significant impact on the risk profile of the company or funds.
METROPOLE Gestion has introduced a Compensation Committee to assist the Chairman and CEO in supervising the design, implementation and review of compensation policy.
The Compensation Committee is formed by four members, namely:
- two external members, including the Compensation Committee's Chairman, who has no executive role within the company;
- the company Chairman and CEO, who is not involved in operations management;
- the Deputy CEO.
It meets once annually following the financial year end.