Preventing the risk of conflicts of interest between the activities of LB-P Asset Management and those of LB-P
Conflicts of interest can only occur in a limited number of cases.
1.1 Rules between LB-P Asset Management and LB-P :
To avoid interference between LB-P Asset Management's business and LB-P's business, the following rules have been implemented.
a) No investment is made by any of the funds if it involves shares of listed companies that are the subject of a negotiated or accepted advisory engagement. This prohibition is extended to 6 months after the end of the mission,
b) If a consulting assignment of an unlisted company is followed by its IPO within 6 months of its completion, no investment in the shares of this company is made by the Managed Funds within 6 months this introduction,
c) Membership in a board of directors of a listed company of a person exercising functions in the LB-P Group ipso facto results in the transposition to LB-P Asset Management of the rules on the prohibition of director transactions when one of the Managed Funds holds securities of that company. If no security is held upon acceptance of the mandate, no investment can be made in the Managed Funds.
In order to ensure compliance with these rules, the staff member responsible for monitoring the contract shall notify the managers of LB-P Asset Management and his / her head of internal control of the projected consulting assignments by e-mail, as well as of the list submitted. regularly maintain mandates held in companies of all kinds. LB-P Asset Management is also informed of the completion of the assignments; the reports and conclusions are not brought to their notice, unless they are made public and at the moment they are. The statutory auditors, who are common to all LB-P Group companies, verify that this information has been duly and formally submitted in due time and makes reference to it in the special report. Finally, these rules are mentioned in the appropriate forms in the Managed Funds documentation.
1.2 Organization of advisory and management structures :
Advisory and management structures are organized to clearly define responsibilities
Persons who have confidential or privileged information refrain from communicating it to another person "outside the normal scope of their work, profession or function or for purposes other than those for which it was given to them". communicated ... "(Article 622-1 of the RGAMF).
Staff members would be responsible for any disclosure of confidential or privileged information in the event that they do not comply with the procedures themselves.
In case of departure, he is bound by a duty of care which must lead him to abstain from inciting the principals for whom he was responsible to transfer their assets to another establishment.
2.1 Interests of Unitholders :
Staff members acting as managers of the Funds must in particular:
2.2 "Buy-Sell" arbitrage transactions between UCITS, OTC transactions authorized by MIFID :
To date, no operation of this type has yet been carried out.
In the future, these operations can be carried out as follows:
3.1 General principles concerning management :
Staff members acting as managers of the Funds must at all times comply with the following rules:
If the Managers can intervene in their personal capacity in the units of the funds they manage and the shares of the companies in their investment universe, these movements are however declared without delay and controlled by the RCCI
3.2 Staff remuneration:
It is strictly forbidden for any member of the Personnel to receive remuneration, in any form whatsoever, from a counterparty, an intermediary or a client, directly or indirectly.
In the current state of affairs, given their variable remuneration, the managers could be encouraged to make a very large turnover of the portfolios for no economic or financial reasons and for the sole purpose of increasing the movement fees.
A specific control of the fund's turnover rate is carried out monthly by the manager.
The turnover rate is calculated according to the formula below:
(Purchases + Share sales) - (Subscriptions + Redemptions)
Average asset
3.3 Gifts and benefits:
In general, gifts, invitations and benefits in any form should be considered unacceptable if they could be of such a nature as to influence the recipient's professional behavior.
These principles must also apply in the opposite direction: Staff members declare to the RCCI the nature and value of the gifts they offer to their clients, counterparties and / or external suppliers with whom the Company is in contact with. case or is likely to be.
In both ways, gifts and benefits should never be money transfers.
All employees, in the interests of transparency, must declare to the RCCI, or in his absence to the Management of the Company, all gifts of a value equal to or greater than 100 euros, received at his place of residence or at the place of work, and offered by counterparties, intermediaries and / or external suppliers with whom the Company is or may be in business relationship.
Any advantage, invitation (shows ...) must also be declared under the same conditions.
Invitations to professional seminars / conferences / travel, etc ... must be professionally justified; they are subject to the prior notice of the RCCI and the authorization of the hierarchy. It is customary for the Company to bear a significant portion of the costs (plane ticket, hotel, etc.).
3.4 Independence rules:
The guidelines and decisions applied within LB-P Asset Management can only come from its decision-making body, to the exclusion of any interference or pressure from outside persons or entities, including the depositary, financial intermediaries or any other financial company directly or indirectly related to it.
The manager who has been the victim of this type of pressure or deontologically reprehensible facts such as misinformation, manipulation of courts, insider trading, must inform his superiors.
No Personnel must accept or solicit direct or indirect compensation from a client, intermediary, supplier or competitor that may compromise its impartiality or independence of decision or alter its autonomy. because of privileged relationships.
3.5 Primacy of the interest of the bearers:
LB-P Asset Management manages only one fund as of the date of update of this procedure.
In the event that LB-P manages several funds, the following provisions are provided to respect the interests of the holders of each fund.
All orders must be allocated to one or two of the managed funds prior to their transmission to the financial intermediary. The timestamp of the order attests to the chronology of the process, which is framed by a specific procedure.
Managers must give priority to the interests of unitholders or shares of the Managed Funds while respecting the integrity of the market, acting in all circumstances with due diligence, loyalty, honesty, discretion, neutrality and impartiality.
3.6 Conflict Resolution Procedure:
The procedures put in place within LB-P Asset Management must make it possible to prevent possible conflicts of interest.
If any such conflict arises, the persons concerned should seize the RCCI, which would then give its opinion in writing.
In the event of a conflict of interest concerning a customer, he or she will be duly informed in accordance with MiFID principles.
The purpose of this document is to define the procedure for dealing with customer complaints that may be addressed to LB-P AM. This procedure complies with Article 313-8 of the AMF General Regulation as supplemented by AMF Instruction 2012-07, which stipulates in particular that the ISP must establish a procedure and a device for reporting and rapid processing. claims against non-professional clients.
A claim is a declaration by a client or a UCITS holder stating his dissatisfaction with the Management Company. A request for information, opinion, clarification or service is not a claim. A complaint can take the form of a written letter or an email. Upon receipt of the customer complaint, it is sent to the RCCI who notifies the account manager. RCCI retains a duplicate of this claim.
A claims register is maintained to list all claims that may be submitted to LB-P AM. The elements on this register will be:
In the event that the complaint is considered incomplete, a request for additional information will be sent to the client in order to process the file.
Each claim will be the subject of a separate file containing the following elements:
o the written complaint of the client,
o the actions and solutions provided to this claim,
o a copy of the response sent to the client.
An investigation will be conducted to gather all information necessary for the study and the response to this claim.
The concerned manager acknowledges receipt of the complaint to the client within a maximum of 10 working days from receipt of the complaint and prepares the response to be addressed to him.
The draft reply is submitted to the RCCI and the General Management of the company.
Once validated, the response is sent to the customer within a maximum of two months after receipt of the complaint and a copy indicating the date of sending the mail is recorded in the register of complaints.
LB-P AM undertakes to respond to the customer's requests for information on the progress of the processing of its claim, particularly in the event of the occurrence of special circumstances that would not meet the deadlines on which the company is committed.
In case of rejection or refusal to grant the claim in full or in part, customers will be informed in the response to possible remedies, outside the usual legal channels.
It is indeed possible for the client to seize the Mediator of the AMF. To make a complaint to the AMF Mediator, the client can use two methods:
o To connect on the website of the AMF at the following address: www.amf-france.org, go to the link indicated at the bottom of the frame entitled "The Mediator", select the tab "The Ombudsman, instructions ", choose" Referral Modes "and complete the" Mediation Request Form ".
o Contact the Mediator of the AMF by mail at the following address:
Autorité des marchés financiers
Mediation
17, Place de la Bourse
75082 Paris Cedex 02
Claims are chronologically tracked by the RCCI to detect any delays in processing and to take the necessary action.
Permanent monitoring regularly ensures that claims have been processed, that the response has been communicated to the client, and that there are no claims pending. In case of malfunction, it implements corrective actions.
In the annual report on compliance and internal control, the RCCI reports on the malfunctions identified through the claims and indicates whether measures have been taken to prevent their recurrence.
Shareholder engagement policy 2024
Information to unitholders :
We inform the unitholders of the fund "Euro Immo-Scope Income" (part P1: FR0010696468, part P3: FR0010696500, part I1: FR0010696526) that LB-P Asset Management, the management company of the fund, has decided to simplify the name of this fund, which will henceforth be called "Euro Immo-Scope", from 30 November 2015.