Provisions relating to the policy governing the management of conflicts of interest and ”Inducements”
1.1. The Bank's primary concern is to best serve the interests of the Client equitably and correctly. The Client is therefore informed that the Bank has created an organisational structure, systems, separation of tasks and segregation of activities, "Chinese walls", designed to prevent or manage any conflict of interest.
1.2. "Chinese walls" means organising the Bank in such a way that no confidential information filters between different operating entities, which must act independently of one another.
Various measures, such as electronic organisational procedures or even physical separation, are therefore in place to prevent/control the exchange of information to persons liable to be exposed to conflicts of interest within the scope of their activities.
These measures and procedures are designed to create barriers to the transmission of confidential information (non-public or liable to change the price of a security, for example) to prevent the exchange of such information with persons answerable to a different department, if such an exchange is likely to prove detrimental to the interests of one or more Clients or of one Client vis-à-vis another.
In general terms, at operational level, the persons concerned will be managed by different persons in accordance with the principle of double signature, in line with internal procedures, so that undue influence on the part of a single operator will be minimised. Any temporary derogation from these principles must be justified and scrupulously controlled.
Further information is obtainable on request.
2.1. To enable the Client to access a diversified range of investment opportunities, the Bank offers a wide range of products, in particular its "in-house" and “Group” Undertakings for Collective Investment in Transferable Securities (UCITs) and third-party Collective Investment Undertakings, for which the Bank is a distributor. The Client may subscribe on his own initiative to any of these, the Bank refraining from giving advice in this respect.
2.2. The Client is informed that, in consideration of the Bank’s provision and updating of this information, the UCIT or its representatives may pay the Bank a commission, in general calculated on the basis of the management fee charged by the latter, which may vary by a few percent or a few tens of percent depending on the asset class, the investments made/volumes attained, and the rates negotiated under the terms of the distribution contract.
2.3. The Bank may be paid this commission if it provides investment advice or makes a recommendation. By the same token, the manager Bank may, in the event that UCITs are placed in the portfolios of its Clients, receive a management fee from the UCIT or its representatives, to be calculated in line with the criteria stipulated above.
2.4. This commission is intended to promote an independent third-party fund selection policy, with the aim of providing an optimum response to the needs of the Client. It constitutes a management tool designed to optimise investor satisfaction and maximise the return/risk ratio on investments through diversification in varied classes of assets, different geographical areas, wide-ranging or specific market segments and targeted management styles. The expertise and know-how of external managers, from which the Client ultimately benefits, are reinforced and the quality of the service provided is enhanced.This means the Bank will seek out experienced management and undertake an analysis of the fund industry in particular.
This selection policy, based on objective criteria both quantitative and qualitative, such as performance, management style, capacity to manage risk, capacity to "outperform" the market and rigorous adherence to a management style, calls for a specific infrastructure and ongoing monitoring (analysis of investment strategy, due diligence, meetings with UCIT managers, monitoring of performance, investment strategy, compliance of portfolios with management style...)
2.5. The Bank may also, for example, obtain financial analyses to be used, in conjunction with other information, to determine its investment strategy and enrich the investment advice provided.
2.6. However, the policy relating to management of conflicts of interest in place within the Bank guarantees to the Client that the investment proposals put forward by the Bank are free of bias and not influenced by commission or other benefits.
2.7. The Bank may in addition remunerate certain third parties through whom the client has entered into a relationship with the Bank and without whom the client would not have entered into the relationship. This is therefore a question of interests common to all parties concerned; the Bank selects third parties likely to present them with clients, the third parties select clients looking for a bank for one service or another in accordance with their wishes. Hence this role of reciprocal selection may in certain cases justify payment of an ad hoc or recurrent fee, with the specific aim of preserving the stability of the relationship between all parties involved; the relationship between the third-party and the Bank, the relationship between the Bank and the client and, where applicable, the relationship between the client and third-party, if the latter wishes to defend or even manage the interests of the client vis-a-vis the Bank.
This remuneration may consist in the payment of a commission calculated on the basis of a proportion of the commission received or to be received on the transactions made or to be made by the Client or an amount proportional to the assets on deposit or an amount proportional to the entry fees paid by the client on certain UCITs or, more generally, a percentage of the gross profitability of the Client introduced. This percentage is generally between 5% and 25%. Payment of this fee may be staggered over time. Finally, this selection process is entirely in line with the conflicts of interest management policy.
2.8. Under all the circumstances outlined above, further details of different aspects (type, value of benefits or, if the amount cannot be established, the method of calculation) are obtainable on request.
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