Regulatory Information
Regulatory Information
Montpensier Arbevel has established and maintains an operational procedure to ensure the fair and prompt handling of any complaints submitted by its clients.
For any complaint, the client may submit their request to Montpensier Arbevel either:
Montpensier Arbevel
Compliance and Internal Control Officer
58 avenue Marceau
75008 Paris
France
Montpensier Arbevel undertakes, for any complaint received:
- To acknowledge receipt of the complaint within 10 business days from the date the written complaint is sent, unless the response itself is provided to the client within that period;
- To provide a response to the client within 2 months from the date the written complaint is sent;
- To adapt the processing time to the nature and complexity of the complaint, in order to provide a response as quickly as possible;
- To respond to the client’s requests for information on the progress of the complaint handling process and to keep the client informed should specific circumstances prevent Montpensier Arbevel from meeting the committed deadlines.
If dissatisfied with the outcome of the complaint, the client may contact, free of charge:
– The AMF (Autorité des Marchés Financiers) in the context of portfolio management;
– The ACPR (Autorité de Contrôle Prudentiel et de Résolution) in the context of life insurance.
AMF Contact Details:
Ombudsman of the AMF
Autorité des Marchés Financiers
17, Place de la Bourse
75082 Paris Cedex 02
Form: https://www.amf-france.org/en/amf-ombudsman/submit-your-mediation-request
ACPR Contact Details:
Autorité de Contrôle Prudentiel et de Résolution
DCPC / SIR
61 rue Taitbout
75436 Paris Cedex 09
Form: https://www.mediation-assurance.org/Saisir-la-mediation/Questions-prealables
Montpensier Arbevel has implemented an organization and strict procedures designed to prevent, identify and manage conflicts of interest, in accordance with the best interests of its clients.
In the event of an actual conflict of interest, the company undertakes to:
- Inform the client in a clear and transparent manner;
- Document the decisions taken;
- Refrain from the transaction if no fair solution can be implemented;
Montpensier Arbevel, controlled by its management, Weinberg Capital Partners and Amundi Asset Management, remains fully autonomous in the management of its investment vehicles.
Any request relating to a market sounding must be sent to the Compliance and Internal Control Department at the following address: sondages@montpensier-arbevel.com.
Please do not contact any employee of the company directly before reaching out to the Compliance and Internal Control Department.
In accordance with the provisions of the UCITS V and AIFM Directives, as well as ESMA guidelines, Montpensier Arbevel has implemented a remuneration policy (the “Policy”) designed to:
- Promote sound and effective risk management;
- Prevent any incentive to take excessive risks, inconsistent with the risk profiles of the funds or discretionary portfolios under management;
- Align the interests of staff, investors, and the management company.
In accordance with the MiFID Directive (2004/39/EC) transposed into French law on 21 April 2004, Montpensier Arbevel has implemented a policy for selecting intermediaries aimed at acting in the best interest of its clients and the funds it manages.
Order Transmission
Montpensier Arbevel delegates order transmission to Amundi Intermédiation, authorized by the CECEI as an investment service provider to receive and transmit orders on behalf of third parties for most financial instruments referred to in article L. 211-1 of the Code Monétaire et Financier, which is deemed to take all reasonable steps to obtain the best possible result.
Broker Selection
The selection of execution brokers is carried out jointly by Montpensier Arbevel and Amundi Intermédiation, based on the criteria defined in the latter’s selection policy.
Counterparty Selection
Montpensier Arbevel also applies an internal procedure for selecting counterparties and intermediaries, based on its investment decision-making needs
Montpensier Arbevel may disclose elements relating to the composition of the assets of the funds it manages, in order to enable certain investors (notably institutional ones) to comply with their obligations, in particular those arising from Directive 2009/138/EC (Solvency II) regarding transparency.
Beforehand, Montpensier Arbevel ensures that these investors confirm they are aware of the AMF Position DOC-2004-07 (“Market Timing and Late Trading Practices”), and that they have implemented appropriate procedures to comply with these provisions, particularly regarding sensitive information management and the prohibition of “market timing” or “late trading”.
Information is disclosed at least 48 hours after publication of the NAV.
As a management company, Montpensier Arbevel publishes an annual report on the quality of order execution in its discretionary management activity, in accordance with the requirements of Directive 2014/65/EU (MiFID II) and the Delegated Regulation of 8 June 2016.
This report presents the identity of execution venues and/or financial intermediaries used, as well as analysis of the quality of execution obtained.
As part of its commitment to the UN Principles for Responsible Investment, Montpensier Arbevel integrates ESG criteria into its management and promotes best governance practices. This commitment is reflected in:
- An engagement policy applied to active equity and convertible bond management;
- The systematic exercise of voting rights, taking ESG considerations into account;
- Constructive dialogue with companies, led by portfolio managers and the ESG team, to encourage improved ESG practices.
Montpensier Arbevel bases its engagement on:
- ESG research from MSCI;
- Voting policy recommendations from ISS Governance;
- Collective engagement initiatives via ISS Ethix;
- Internal analysis by its portfolio management and ESG research teams.
Engagement Policy
Principles
Targeted companies are those with a low ESG rating or exposed to controversy, with the aim of supporting them towards sustainable performance, in line with the UN’s 17 Sustainable Development Goals. The engagement approach may also be structured around ESG themes in line with the sustainability priorities to which investment strategies are likely to be exposed.
Individual and collective engagement actions
Montpensier Arbevel engages directly with companies or participates in collective engagement actions implemented by ISS as part of its ISS ESG program.
Reporting
Montpensier Arbevel communicates the results of discussions with target companies and any management decisions in an annual engagement report.
Voting Policy
Montpensier Arbevel considers voting at General Meetings to be an essential component of its management, carried out in the exclusive interest of shareholders. Its policy aims to promote responsible governance and sustainable investment returns.
Organization
- Portfolio managers analyze the resolutions and rely on the recommendations of ISS Governance (Sustainability policy);
- Operations team monitors progress via the ProxyExchange platform, in conjunction with CACEIS, custodian;
- Montpensier Arbevel subscribes to ISS Proxy Research services, ensuring independent analysis governed by a conflict of interest prevention policy.
Voting principles
Portfolio Managers vote independently, based on ESG and ethical criteria. They may consult the Chief Compliance and Internal Control Officer (CCO) in case of doubt. Votes are guided by the principles of alignment of interests between stakeholders.
Voting Methods
- Voting is mainly conducted by correspondence;
- Physical attendance at general meetings is possible, with prior notice;
- Proxy voting is exceptional and subject to compliance oversight.
Conflicts of Interest
Any potential conflict must be reported to the Compliance Officer before voting to ensure primacy of investors’ interests.
Transparency
Montpensier Arbevel publishes an annual report on the exercise of voting rights.
Download Montpensier Arbevel Engagement Policy
Download Montpensier Arbevel Voting Policy
Download Montpensier Finance annual engagement report
Download Arbevel annual engagement report
Download Montpensier Finance annual report on the exercise of voting rights/u>
Download Montpensier Finance annual report detailling resolutions on exercising voting rights/u>
Download Arbevel annual report on the exercise of voting rights
In accordance with article L.533-22-1 of the Code Monétaire et Financier the following information concerns the respect of social, environmental and governance (ESG) criteria.
Information concerning criteria relating to the respect of social, environmental and governance (ESG) objectives has been published on the investment management company website since July 1st 2012 and in the annual reports relating to financial years since the year starting on January 1st 2012.
Its ESG approach includes:
- Adapting management processes to integrate ESG factors into investment analysis and selection;
- An exclusion policy, structured across different levels depending on the characteristics of the funds;
- LPublication of a TCFD report for relevant funds, in line with Article 173 of the French Energy Transition Law;
- Providing a transparency code for funds labelled ISR, available on each fund’s dedicated webpage.
All of these elements are presented on the Responsible Commitment page of Montpensier Arbevel website, as well as in the funds’ annual reports and regulatory documents.