Responsible Engagement Overlay
Selection and assessment of order execution and research entities
Brokerage fee report - Management of mutual funds
In accordance with the provisions of Article 321-122 of the AMF General Regulations, PROMEPAR AM is required to report the conditions under which it called on third parties to provide investment decision-making and order execution services in 2022.
When an asset management company uses investment decision support and order execution services on behalf of its UCITs and the intermediation fees paid to market intermediaries (also called ” brokers “), represented for the previous financial year an amount greater than € 500,000, it is preparing a document entitled “Report on intermediation costs”.
In 2022, PROMEPAR AM paid less than € 500,000 to market intermediaries and therefore does not publish this report.
Conflicts of interest management policy
Conflicts of interest management policy
PROMEPAR Asset Management places a premium value on fairness and the priority of its clients’ interests.
In accordance with the law, PROMEPAR Asset Management has established a policy aimed at preventing and managing conflicts of interest liable to arise during the provision of investment services or related services, or a combination of such services, to one or more clients.
A conflict of interest is a situation in which several parties have an opposing interest on a given deal or transaction. Conflicts may arise between the interests of :
- the company and a client
- an employee and a client
- two entities of the BRED Banque Populaire Group
- two clients
The conflicts of interest prevention system enacted by PROMEPAR Asset Management involves the implementation of organisational measures and administrative procedures for processing and verifying transactions, with the aim of :
- detecting situations giving rise, or liable to give rise, to conflicts of interest
- preventing conflicts of interest
- establishing and maintaining an appropriate conflicts of interest management policy
- establishing procedures to implement the principles of fairness in the execution of orders placed with brokers, particularly in terms of allocation of assets or financial instruments
- establishing and maintaining a register of activities for which conflicts of interest have arisen or are liable to arise
- notifying clients when, for a specific transaction, the measures undertaken were not sufficient to reasonably ensure that the risk of a detrimental impact to the client’s interests could be avoided
This policy takes into account that PROMEPAR Asset Management belongs to the BRED Banque Populaire Group.
PROMEPAR Asset Management ensures that its staff meet their professional obligations in the course of exercising their duties, as well as the regulatory provisions applicable to said duties.
If, despite the precautions taken, conflicts of interest liable to prove detrimental to the client’s interests could not be avoided, PROMEPAR Asset Management’s procedures call for appropriate measures to be sought and undertaken in each situation.
However, should such measures prove unable to avoid the risk of a detrimental impact to the client’s interests with virtual certainty, PROMEPAR Asset Management will clearly inform the client in sufficient detail, before acting on the client’s behalf, of the general nature or source of the associated conflicts of interest, in order to allow the client to make an informed decision.
Complaint review procedure
In accordance with the provisions of Articles 318-18 and 321-40 of the AMF General Regulations, and of Article 26 of the Commission Delegated Regulation (EU) of 25/04/2016, clients or unit/shareholders are notified if their complaints and claims may be addressed either to their portfolio manager or to General Management :
- By post, attn Chief Executive Officer – PROMEPAR AM – Immeuble LE VILLAGE 1 – Quartier VALMY – CS 50246 – 33 place Ronde –92981 Paris la Défense Cedex
- By e-mail to firstname.lastname@example.org
BRED clients may also contact BRED’s Quality Division :
- BRED Banque Populaire, Direction de la Qualité – 18, Quai de la Rapée – 75012 Paris – Tel : 01.40.04.71.15
We undertake to send you a letter acknowledging receipt within 10 business days of receiving your complaint, and to answer your complaint within 2 months of that same date. If you are dissatisfied with the handling of your complaint, you may contact the AMF (for portfolio management mandates) or the ACPR (for life insurance vehicles) ;
- By post, attn. AMF Ombudsman – Autorité des Marchés Financiers – 17, place de la Bourse – 75082 Paris Cedex 02
- By e-mail to http://www.amf-france.org /le médiateur