- Financial intermediary selection and assessment policy
- Report on intermediation fees
- Information on the top five execution brokers
- Conflict of interest management policy
- Voting policy
- Handling of claims
- Prevention of market timing practices
- Compensation policy
- Personal data
1. Financial intermediary selection and assessment policy
In order to comply with its regulatory obligations, in particular the MiFID regulatory package and the fiduciary duty to provide the best execution for clients under US SEC (Security Exchange Commission) regulations, METROPOLE Gestion is required to take all necessary steps to obtain the best possible result for its clients when transmitting orders for execution as part of its asset management activity. It therefore selects financial intermediaries whose execution policies will ensure the best possible results to that end.
The best execution obligation takes the form of a best selection obligation.
The selection policy applies to all financial instruments and to all funds and mandates managed by METROPOLE Gestion, which invariably uses a financial intermediary to place orders.
- Place of execution
METROPOLE Gestion authorises its financial intermediaries to process orders on all markets in order to benefit from the full range of products available and to be in a position to obtain the best possible result for its clients. It expressly consents to orders being executed on:
- regulated markets;
- multilateral trading facilities;
- systematic internalisers; and
- organised trading facilities.
- Selection and assessment of financial intermediaries
- Selection of financial intermediaries
METROPOLE Gestion has established a Broker committee to oversee the selection of financial intermediaries who are to execute orders, and to verify that those financial intermediaries comply with their best execution obligations. This Broker committee meets every six months. It reviews the performances of the selected financial intermediaries over the course of the previous period in light of the chosen criteria and decides whether to retain them on the selection list.
All financial intermediaries must first be approved by the Broker committee. Orders may not be transmitted to a non-selected financial intermediary. Financial intermediaries are selected solely on the basis of objective criteria defined in the financial intermediary selection and assessment policy.
METROPOLE Gestion expects its financial intermediaries to obtain the best results when executing orders, based on the following criteria:
- Execution price;
- Costs of execution;
- The probability of execution and settlement;
- Other considerations relevant to the execution of the order.
METROPOLE Gestion checks that these criteria are included in the selected financial intermediaries’ execution policies.
- Assessment of financial intermediaries
The following assessment criteria are used to score financial intermediaries:
- Overall price and compliance with instructions;
- Ability to source liquidity;
- Effective settlement of transactions;
- Quality of reports.
The rating scale, as applied to the various criteria, produces an overall score, that is used to classify selected financial intermediaries for the subsequent period. The relative weightings of each criterion, which are set by the Broker committee, depend on the financial instrument.
When transmitting orders for execution, the key factor is the overall price (representing the price of the financial instrument and costs associated with execution).
- Selection of financial intermediaries
- Conflicts of interest
METROPOLE Gestion is an independent management company owned by its founders and employees; it has no ownership relationships that may lead to conflicts of interest with other companies that offer brokerage services on the financial markets. Brokers are selected solely on the basis of the criteria defined in the selection policy.
- Disclosure of the policy
The financial intermediary selection and assessment policy is available on request from the management company.
- Review of the policy
The financial intermediary selection and assessment policy is reviewed at least once every year. Any changes to the policy is formalised and justified. Historic policies are stored for at least five years.
2. Report on intermediation fees
In accordance with the MiFID 2 Directive that came into force in January 2018, investment research services must be priced separately from execution services, with the aim of providing better protection for investors and limiting the risks of conflicts of interest. METROPOLE Gestion is subject to this obligation with respect to its discretionary mandate activity. METROPOLE Gestion applies this separation of costs to all its asset management activities. Thus, 100% of all intermediation costs are allocated to execution services. Research services are funded directly by the company.
METROPOLE Gestion did not enter into commission-sharing agreements with market intermediaries.
Measures implemented by the company to prevent or deal with any conflict of interest in the choice of service providers are laid out in the framework of the Intermediary Selection Policy and the Conflict of Interest Management Policy.
No conflict of interest was identified over the financial period.
3. Information on the top five execution brokers
In accordance with the MiFID 2 Directive as supplemented by the Delegated Regulation of 08/06/2016, regarding the annual publication of information on execution brokers, information on the top 5 execution brokers for the discretionary management activity is available here.
For the purpose of providing a representative overview of the activities of METROPOLE Gestion, information on the top 5 execution brokers for the entire equities management activity is also available here.
4. 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.
5. 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 is available to by investors.
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 is available to investors.
6. 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
7. 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.
8. 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 (including as regards sustainability), 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 compensation 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. Furthermore, METROPOLE Gestion takes sustainability into account in all aspects of its business and recognises that each team contributes to the implementation of the company’s overall strategy. The entire investment process includes taking sustainability risks and, for those funds concerned, ESG (Environment, Social and Governance) criteria into account, starting from the preliminary selection of assets making up the funds or mandates.
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.
9. Personal data
All personal information processed by METROPOLE Gestion is subject, in particular, to the provisions of the French data protection act, Loi n° 78-17 Informatique et Libertés of 6 January 1978 as amended by the Act of 6 August 2004 and by the EU General Data Protection Regulation (GDPR) of 27 April 2016 and all rules of national law issued in the implementation thereof. To consult our personal data management policy, please click here.
The policy sets out the following points:
- How and why your personal data are collected.
- How we ensure the pertinence, integrity and security of your personal data.
- Your rights regarding the personal data held in our systems.
For any questions regarding your personal data and its protection, please contact the team in charge of data privacy at the following address: firstname.lastname@example.org