Complaints handling policy
In accordance with regulations, AMPERE Gestion has a complaints process that informs customers of how to submit claims and the standard procedures used to process these.
Once a complaint is received, AMPERE Gestion acknowledges receipt from the customer in question within ten days.
AMPERE Gestion’s teams respond to the complaint itself within two months.
The name and address of the person in charge of handling complaints is:
Ms Nathalie Caillard
Deputy Chief Executive Officer
100-104 avenue de France
75013 PARIS – France
Telephone: +33 1 55 03 31 25
If you are not satisfied with the response to your complaint, you may submit an appeal to the mediation service of the French financial markets authority (Autorité des marchés financiers – AMF) at the following address:
Ms Marielle Cohen-Branche
Médiateur de l’AMF
Autorité des marchés financiers
17, place de la Bourse
75082 Paris cedex 02 – France
Instructions on how to use the mediation services of the AMF are available on their website at
Application by AMPERE Gestion of the EU Directive on markets in financial instruments (MiFID)
MiFID contains various provisions designed to offer (i) greater transparency in financial markets, and (ii) better protection for investors.
Based on the nature of the funds managed by AMPERE Gestion, eligible investors are categorised as “professional clients” or “eligible counterparties”.
The criteria used to classify investors in one or other category include type of investor, financial criteria and investor knowledge and experience of financial real estate markets.
As a portfolio management company, AMPERE Gestion is covered by the MiFID Directive and must comply with the following regulatory provisions:
- Client categorisation: AMPERE Gestion categorises its investment clients at the very beginning of the business relationship. Clients may submit written, substantiated requests to change category.
- Product suitability: AMPERE Gestion has designed a questionnaire to ascertain the specific investment objectives of each client.
- Conflicts of interest: the policy for handling conflicts of interest may be consulted on the portfolio manager’s website.
To comply with the requirements of the French financial and monetary code (code monétaire et financier), AMPERE Gestion requires investors to complete the following:
- A “Know Your Customer” questionnaire drawn up in accordance with the aforementioned MiFID Directive to ascertain the client’s investment objectives.
- An “AML” questionnaire designed to comply with anti-money laundering regulations.
Conflict of interest management policy
AMPERE Gestion endeavours to identify conflict of interest situations that could arise in the course of its business.
AMPERE Gestion has set up specific necessary organisational processes (comprising both means and procedures) and controls to identify and manage situations that could jeopardize its clients’ interests.
In particular, AMPERE Gestion’s Head of Compliance and Internal Control, who reports directly to the Chief Executive Officer, is tasked with preventing conflict of interest situations, detecting potential conflict of interest situations in liaison with executive management and key managers, and resolving such situations with the managers concerned, or with providing appropriate client disclosures if it proves impossible to resolve these situations in a satisfactory manner.
AMPERE Gestion uses mapping techniques to identify actual and potential conflicts of interest together with the associated risks. This risk map is updated by the Head of Compliance and Internal Control on a regular basis. AMPERE Gestion employees have received awareness training in conflict of interest detection and management together with client disclosure requirements in the event that a conflict of interest cannot be avoided and resolved within the framework provided.
AMPERE Gestion’s conflict of interest management process comprises the following:
- Strict ethical guidelines
- Confidential treatment of information
- A process adapted to specific situations arising out of the relationship with SNI Group
For example, AMPERE Gestion shall ensure that any use of services provided by SNI Group is justified by the quality of said services and by potential synergies that may be unlocked by pooling these resources with due regard to AMPERE Gestion’s autonomy, and that the cost of these services is in line with market rates for equivalent-type services.
The Head of Compliance, who is independent of all operating functions, oversees control of this process.
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