Regulatory information

Policy of selection of the intermediaries

DNCA Finance Luxembourg fully adheres to the below described “Policy of selection of the intermediaries” of DNCA Finance (its parent company).


1-A

Object

Object

this document aims to inform our clients of the selection policy for the financial intermediaries to which we entrust order execution as part of the management under mandate, such as ucits management.

it has been prepared in accordance with articles l 533-18 of the french monetary and financial code (code monétaire et financier) and 314-75-1 of the general regulations of the french financial market authority (autorité des marchés financiers, hereinafter 'AMF').


1-B
Scope
Scope
  • Clients concerned
  • The selection policy in force at our company applies uniformly to all our clients, whether professional or otherwise. the implementation of this policy's principles differs depending on whether collective management or management under mandate is involved.

  • Financial instruments concerned
  • The selection policy in force at our company applies to all financial instruments traded by our company. dnca finance systematically entrusts its orders to an intermediary, whatever the financial instrument.


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Methods of selection and evaluation of the intermediaries
Methods of selection and evaluation of the intermediaries

Our market intermediary selection policy takes account of :

The conditions taken into account are price, cost, speed (order transmission not execution), the probability of execution and settlement (in particular the cost and security of settlement and delivery), size, type of order and any other consideration relating to order execution (such as place of execution and market effect). dnca finance has taken steps to be categorised as a professional client with all intermediaries it seeks to use such that these are required to provide it with the best execution that it itself has to guarantee for its clients.

French research (database coverage and accessibility), european research (database coverage and accessibility), analysis quality (pertinence, originality against consensus, rigour in financial analysis and monitoring of recommendations), the relationship with companies (organisation of financial presentations and face-to-face meetings with managers) and the availability of the research office (presentations on-site, frequency of contacts with the analyst).

A rating of the financial intermediaries is done at the end of each semester by assigning a score from 0 (the worst) to 5 (the best) for each of the conditions mentioned above.

  • Best execution for our customers
  • Analysis and research

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Place of order execution
Place of order execution

DNCA Finance has authorised all its intermediaries to manage the orders it originates on key regulated markets, multilateral trading facilities and systematic internalisers, in order to be able to benefit from the best implementation conditions on offer.

Special case of the selection of interest-rate financial instruments : since march 2009, dnca finance has used the services offered by BP2S Dealing Services (formely fin'ams) a bnp group company to outsource the placing of orders – that is, their trading – on all interest-rate financial instruments whenever it appeared suitable.

Special case of the management under mandate investment service : for orders relating to shares and bonds, DNCA Finance has selected the CIC, as intermediation table, authorized for the receipt / transmission of orders (approved as Establishment credit - Investment services provider by the ACPR (Prudential Control and Resolution Authority)).

Policy of management of the conflicts of interests

Intermediation costs

Report on intermediation expenses for the year 2014


Pursuant to article 314-82 of the AMF general regulations
Conditions under which the portfolio management company has made use, for the previous financial year, of services for investment decision-making assistance and order execution :

In 2014 the collective-management and management by mandate services made use of financial intermediaries who provided execution and investment decision-making assistance services, under the conditions defined in the 'financial intermediaries selection policy'.

Intermediation fees applied to UCITS are published in the annual accounts which are certified by independent auditors and are available on our website. Annual accounts are also available on request from our registered office.

Distribution key established between :
  • The intermediation expenses relating to the receipt and transmission service and to the order-execution service ;
  • The intermediation expenses relating to services for investment decision-making assistance and order execution.

At the end of fiscal 2014, the breakdown between the execution service and the investment decision-making assistance service is estimated at 36/64 for equity intermediation, and at 53/47 for intermediation on fixed-income products. This analysis concerned 20 equity brokers and 20 fixed-income product brokers. This breakdown is a summary of the evaluation sheets completed for each financial intermediary by the managers, management assistants and the head of the middle office.

It should be pointed out that the above results are those of the intermediation which DNCA FINANCE uses in connection with its collective management business. Regarding the management-by-mandate investment service, DNCA FINANCE uses mainly the order receipt and transmission service offered by the account-keeper that is the custodian of the managed accounts.

Percentage found for the previous financial year, compared with all the intermediation expenses and the fees referred to in b of 1° of Article 314-79 paid to third parties within the framework of shared commission agreements mentioned in Article 314-81.

As of 31 December 2014, two commission-sharing agreements have been validated and one of these agreements is active. In 2014, an amount equivalent to approximately 5% of total brokerage fees paid was available as soft commissions for one or several third parties.

Measures implemented to prevent or deal with potential conflicts of interest in the choice of service providers.

The activity involving financial intermediaries, regardless of the service provided, is subject to periodic review by a financial intermediaries selection and monitoring committee.

Politics ESG
Policy for taking into consideration criteria concerning compliance with environmental, social and governance objectives
In application of article D533-16-1 of the French monetary and financial code (CMF)

As a reminder, DNCA FINANCE is obliged to act solely in the interests of investors. In this respect, DNCA FINANCE takes into consideration all environmental, social and governance criteria that meet the objectives set (strategy, objective, portfolio composition) while growing its clients' assets.

As such, the various investment policies applied to the funds currently managed by DNCA FINANCE (either directly or by delegating management) do not simultaneously and automatically take into account the three ESG (environmental, social and governance) criteria forming part of a Socially Responsible Investment (SRI) approach.

Given investors' growing interest in Socially Responsible Investment, DNCA Finance outsources on a regular basis the analysis of its two largest funds to an external service provider specialised in this area each year. All stocks held in these funds' portfolios are rated based on these three criteria and an overall SRI score is attributed to investments. Until now, this score has been communicated directly to investors who expressed an interest in this assessment of the ESG quality of the funds' management.

At least one European country in which our funds are distributed has adopted a national law prohibiting the financial sector, and hence portfolio management companies, from doing business with companies involved in the manufacture of anti-personnel mines and cluster bombs. In our view, this ethical provision respects ESG criteria. The portfolio managers of the funds concerned systematically obtain and analyse the annual reports of companies that may be involved in any activities that do not respect these provisions. DNCAs policy is to not invest into any shares or bonds issued by these companies.

Complaints management policy

DNCA Finance Luxembourg pays particular attention to the clients satisfaction as well as to the investors protection. For that purpose a complaints handling procedure has been set up.

If there is no doubt that the communication is a complaint, specifying that a complaint is a « complaint filed with a professional to recognise a right or to redress a harm »[1], the file addressed to DNCA Finance Luxembourg will be immediately communicated to the Compliance Officer who has been designated responsible for complaints handling and follow up by the management of DNCA Finance Luxembourg.

Complaints can be filed to DNCA Finance Luxembourg: 

  • by calling phone number : +352 28 48 01 55 23
  • by sending an e-mail to : bsd@dncafinance.com
  • by sending a letter to :   DNCA Finance Luxembourg
  Service Réclamations
  1 Place d’Armes
  L – 1136 LUXEMBOURG
 
  • Or by going directly to the office at the same address as above.

Requests can be expressed in English, French or Dutch.

In order to be admissible the request should include at least the complete identification of the complainant and describing the essence and details of the complaint.

 

Delay processing

An acknowledgement of receipt will be provided to the complainant within ten business days after receipt unless the answer itself is provided to the complainant within this period.

An answer will be provided within one month starting from the date of reception of the complaint except for particular circumstances. In this case, the complainant will be informed about the situation.

 

Escalation procedure

Where the complainant did not obtain an answer or a satisfactory answer from the Compliance Officer, he/she has got the opportunity to rise the complaint up to the level of the Management of DNCA Finance Luxembourg. The relevant conducting officer can be contacted at this address :

DNCA Finance Luxembourg
To the attention to M. Thomas Péan
1 Place d’Armes
L – 1136 LUXEMBOURG 

 

The out-of-court complaint resolution procedure at the CSSF

Where the complaint handling at the level of the Management of the company did not result in a satisfactory answer for the complainant, DNCA Finance Luxembourg shall provide the complainant with a full explanation of its position and inform the complainant in writing of the existence of the out-of-court complaint resolution procedure at the CSSF.

This procedure aims at facilitating the resolution of complaints against professionals without judicial proceedings. However it does not consist in a mediation procedure.

The opening of the CSSF procedure is subject to some conditions. In particular, the complaint must have been previously sent in writing to the relevant conducting officer of DNCA Finance Luxembourg and the complainant has not receive an answer or a satisfactory answer within one month from the date at which the complaint was sent.

The out-of-court complaint resolution procedure is framed by the CSSF regulation N°16-07 available on the CSSF website : http://www.cssf.lu/.

 

Any further information regarding the complaints handling procedure is available free on request.

 

[1] Article 1 of CSSF Regulation N°16-07 of 26 october 2016.

 

Last update : 24/11/2016

Remuneration policy