The voting policy understood as in the 321-132 article from the AMF General Regulation cannot be applied to the company since MANCO.PARIS does not by nature carry out any investment decision.
Article 173 of the Energy Transition for Green Growth Act n°2015-992 of August the 17th of 2015 amends Article L. 533-22-1 of the Monetary and Financial Code, which now stipulates that “Asset Management Companies will provide subscribers of each fund under management information on how the investment policy considers criteria relating to social, environmental and governance objectives. They precise the nature of the latter criteria and the way that they apply them considering a presentation fixed by decree. They stipulate how they use their voting rights attached to the financial tools used given the choices made”.
MANCO.PARIS cannot integrate any criteria relating to social, environmental, and governance objectives since it does not by nature carry out any financial management activity and thus no investment. Yet, MANCO.PARIS attaches particular importance to the consideration of these criteria in the investment process of Asset Management Companies to which it delegates the fund management.
MANCO.PARIS and the delegated funds do not yet belong to any charter, code, initiative, or label related to ESG criteria.
Policy related to sustainability risks
The 3rd article of the EU Regulation n°2019/2088 (SFDR) on sustainability integration policy stipulates that all industry players shall publish information about their policies on the integration of sustainability risks in their investment decisions and investment advisory.
MANCO.PARIS cannot consider sustainability risks since it does not carry out any financial management activity. Yet it verifies that companies start considering these risks in their investment decision, especially climate and biodiversity risks. Likewise, the company ensures that regulatory documents of delegated funds comply with obligations as stated in articles 9 and 8. MANCO.PARIS insists that delegated management companies consider sustainability risks in their compensation policies. Regarding the investment advisor activity, MANCO.PARIS does not consider sustainability risks.
The 5th article of the EU regulation n°2019/2088 (SFDR) on sustainability‐related disclosures in the financial services states that compensation policies in Asset Management Companies support or do not discourage the consideration of sustainability risks in investment decisions or in investment advisory. MANCO.PARIS cannot integrate into its compensation policy sustainability risks since it does not carry out any investment decisions. Yet, Manco employees should consider sustainability risks in their activities. Besides, the facilities of the company are in an eco-responsible building located in an eco-responsible district.
MANCO.PARIS’ compensation policy is summarized on its website: www.manco.paris
Consideration of Principal Adverse Impact (PAI)
MANCO.PARIS cannot integrate the PAI since it does not carry out investment decisions.
Manco.Paris’s Compensation policy is developed by the company Management.
In accordance to AIFM and UCITS directives, MANCO.PARIS adopts a “proportional approach”, that allows the absence of a compensation committee, neither a deferral of variable compensation.
MANCO.PARIS created the policy to limit conflict of interest situations and align clients’ with Company’s interests.
Compensation at MANCO.PARIS consists of the 2 following elements:
- A fixed part
- A variable part
The fixed part of compensation is settled when the employee joins the Company. It can be reviewed annually, based on year end interviews/ reviews. The variable compensation depends on the overall performance of the company and is distributed on a discretionary basis.
MANCO.PARIS does not carry out any financial management of the assets for which it is responsible, there is no variable compensation depending on the performance of funds or mandates. Moreover, MANCO.PARIS cannot consider in its compensation policy the sustainability risks stated in the EU Regulation n°2019/2088 (SFDR) on the publication of information regarding sustainability in the industry of financial services.
The managing direction reviews and specifies each year the elements of the compensation policy.
The summary of the compensation policy described above is updated when the policy is. The latter is available on request to MANCO.PARIS
COMPLAINT PROCEDURE GUIDANCE
According to applicable regulation (i.e., art 321-40 of the General Regulation AMF), MANCO.PARIS has implemented a client complaint procedure (this procedure is available on request to MANCO.PARIS). Any complaint can be transferred to the following e-mail address: email@example.com, or by postal mail to: MANCO.PARIS, service Reclamation, 7 rue Roy 75008 Paris. The Company will make its best to respond to your request within a maximum period of two months from the reception of your request.
In case of a persistent disagreement, you can contact an Ombudsman, especially that of the AMF. The contact details of the AMF Ombudsman are the following : Autorité des marchés financiers, Médiateur de l’AMF, 17 place de la Bourse 75082 PARIS CEDEX 02. Mediation request forms are available on the AMF Website : www.amf-france.org.
CONFLICT OF INTEREST POLICY
MANCO.PARIS takes all necessary measures to detect the conflicts of interests situations that could appear in the conduct of its activities.
In accordance to regulation ,MANCO.APRIS has implemented a conflict of interest policy.
This policy establishes the procedures and the measures to handle conflict of interest situations, in order to protect the client’s interest and market integrity.
This policy is available for clients on simple request to the management company.
According to Regulation, MANCO.PARIS maintains a register listing all potential conflict of interest situations.
If a conflict of interest occurs, MANCO.PARIS informs the client of the observations and relevant measures taken. The information transferred to clients will be stored.
Furthermore, the identification of conflicts of interests led to the constitution of a conflict of interest mapping. This mapping identifies all the situations that give or are likely to give rise to a conflict of interest. It allows to detect, and if necessary to manage conflicts of interest that could occur, as part of its services, between MANCO.PARIS’s proper interests and that of its clients.
This mapping is focused in particular on identification and control of :
- The involvement of an employee in one or more investment services offered by the portfolio management company
- The separation of activities that may lead to the rise of potential conflicts
- The circulation of confidential or privileged information in the portfolio management company,
- Social mandates carried out by employees or managing directors of the management company in a private capacity or as part of their professional activities
- Commissions paid or collected in the name of services or carried out by or in favor of MANCO.PARIS
- Advantages or gifts eventually received by the management company employees as part of their professional activity
- Conflict of interest risks occurring during the selection process of intermediaries and service providers
- The implementation of an incident management procedure aiming to protect the client’s interest
- The implementation establishment of a personal transaction procedure
- The implementation of a Procedure of controls on gifts (made or received).
BEST SELECTION POLICY
When posting orders, Investment service providers must take reasonable measures to obtain the best results possible for the client considering the price, the cost, the speed, the execution probability, delivery, the nature of the order, and any other consideration relating to the execution.
MANCO.PARIS cannot select financial intermediaries since it does not carry out financial management activities.