Complaints & Policies

COMPLAINTS HANDLING

In accordance with applicable regulatory requirements (cf. art. 321-40 of the RG AMF), Sanso Longchamp Asset Management has a complaints handling procedure (available free of charge on request from Sanso Longchamp AM). For any specific request, please contact +33 1 84 16 64 40, send an e-mail to contact@sanso-longchamp.com or send a letter to 17 rue de Chaillot, 75116 Paris. Management will do its utmost to respond to your request as quickly as possible, and in any event within a maximum of two months from receipt of your request.

In the event of persistent disagreement, you may contact a mediator, including the AMF Ombudsman. Contact details for the AMF Ombudsman are as follows: Autorité des marchés financiers, Médiateur de l’AMF, 17 place de la Bourse 75082 PARIS CEDEX 02. The AMF mediation request form and the mediation charter are available at http://www.amf-france.org.

CONFLICT OF INTEREST POLICY

Potential conflicts of interest can be of three kinds:

  • Conflicts of interest involving several portfolios managed by Sanso Longchamp AM
  • Conflicts of interest involving Sanso Longchamp AM and managed portfolios
  • Conflicts of interest involving Sanso Longchamp AM employees

Conflicts of interest may concern :

  • Financial management: shareholder equity, inter-portfolio transactions.
  • Direct or indirect remuneration paid or received: transparency of information to unitholders, choice of intermediaries, benefits, etc.
  • Sanso Longchamp AM organization: segregation of duties, employee compensation, etc.
  • Proprietary trading by Sanso Longchamp AM, its managers and employees
  • The primacy of client interests
  • External activities of Sanso Longchamp AM employees

Avoiding conflicts of interest

Sanso Longchamp AM is an independent, entrepreneurial asset management company.

Sanso Longchamp AM is an asset management company whose activity is management on behalf of third parties.

Its own management activity is limited to cash management.

In accordance with article 321-48 of the RG AMF, Sanso Longchamp AM has a procedure for managing conflicts of interest.

The prevention of conflicts of interest is based on the principles of the Sanso Longchamp AM Code of Ethics. The code of ethics is given to each employee on recruitment and each time it is updated (in accordance with the procedures defined in the “Procedure for Disseminating Rules of Professional Conduct”).

The RCCI raises awareness of the Code of Ethics among all employees on an ongoing basis.

In addition, the RCCI is systematically involved in the work carried out by the management team.

To prevent conflicts of interest from arising, Sanso Longchamp AM has put in place the following procedures:

  • pre-allocation and placing of orders
  • selection and evaluation of intermediaries

Managing conflicts of interest

The RCCI keeps the company’s conflict of interest management policy up to date. As soon as a potential (but not proven) conflict of interest is identified, it must be entered in the appropriate register. This document must list the potential conflict of interest and the measures put in place to prevent it from materializing.

Customer information

If a conflict of interest is identified, Sanso Longchamp AM will inform the client of the situation and the measures envisaged. Information sent to clients will be archived.

VOTING POLICY

In accordance with article 321-132 of the RG AMF, Sanso Longchamp AM has drawn up a voting policy setting out the conditions for exercising the voting rights attached to the securities held in the portfolios it manages.

Until 2018, Sanso Longchamp AM’s voting policy was to vote when the management company held more than 5% of a company’s capital, which in practice meant not voting at any General Meetings.

The SRI Steering Committee has decided to modify the voting policy as from the 2019 financial year in order to make it more consistent with Sanso Longchamp AM’s Socially Responsible Investment approach.

As the study of resolutions and the exercise of voting rights are technical and time-consuming subjects, Sanso Longchamp AM has selected a service provider capable of assisting it in the analysis of resolutions and the implementation of the voting policy based on the following criteria:

  • Global coverage of the service provider, as Sanso Longchamp AM invests in companies of all market capitalizations, listed on all developed markets.
  • Existence of a voting policy aligned with the principles of corporate social responsibility supported by Sanso Longchamp AM.
  • Ability to work closely with customers.

Based on these criteria, Sanso Longchamp AM decided to contract a “Proxy Voting” service with Institutional Shareholder Services Europe (hereafter ISS), selecting the “SRI” voting policy.

Voting policy applicable from January 1, 2019

Of all the companies held in the portfolios it manages, Sanso Longchamp AM exercises its voting rights on the 30 companies in which it has the largest stake.

The list of these companies is updated and sent to ISS on a monthly basis.

The recommendations made by ISS as part of its SRI policy are systematically followed by Sanso Longchamp AM.

Voting policy applicable from January 1, 2019

Of all the companies held in the portfolios it manages, Sanso Longchamp AM exercises its voting rights on the 30 companies in which it has the largest stake.

The list of these companies is updated and sent to ISS on a monthly basis.

The recommendations made by ISS as part of its SRI policy are systematically followed by Sanso Longchamp AM.

EMPLOYEE COMPENSATION POLICY

Sanso Longchamp AM’s remuneration policy complies with the provisions of European Directive 2014/91/EU (“UCITS V Directive”).

Remuneration policies and practices at Sanso Longchamp AM do not include performance criteria, but exclusively qualitative criteria, and apply to all managers and employees: fund managers, RCCI and support functions.

The Remuneration Committee meets once a year.

Sanso Longchamp AM’s remuneration policy :

  • Promotes sound and effective risk management
  • Does not encourage risk-taking that would be incompatible with risk profiles, regulations or the fund’s constitutive documents.
  • Is consistent with the company’s business strategy, objectives, values and interests
  • Is consistent with the UCITS it manages and those of its unitholders
  • Is consistent with the mandates it manages and their clients
  • Includes measures to avoid conflicts of interest

Compensation at Sanso Longchamp AM is structured as follows:

  • Fixed remuneration represents the employee’s principal sum in relation to the obligations of the position, the level of competence required, the responsibility exercised and the experience acquired. It is reviewed annually, and may be increased or maintained at the time of the annual appraisal.
  • Variable remuneration is based exclusively on qualitative criteria for all employees. It is paid in the form of a bonus in one or two instalments during the year.
  • Another form of remuneration is a company savings plan (PEE).

A detailed remuneration policy is available on request.