REGULATORY INFORMATION AND COMPLAINTS HANDLING POLICY

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

AMPERE Gestion

100-104 avenue de France

75013 PARIS – France

Telephone: +33 1 55 03 31 25

ncaillard@groupesni.fr

 

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

www.amf-france.org

 

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.
The data gathered from these questionnaires are not automatically processed and shall only be communicated for the purpose of complying with legal and regulatory obligations.

 

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
These guidelines are set out in AMPERE Gestion’s code of ethics.

  • Confidential treatment of information
Both within AMPERE Gestion itself and in the relations between AMPERE Gestion and SNI Group, processes include restrictions on the circulation of information between employees working on behalf of clients that have or may have conflicting interests.

  • A process adapted to specific situations arising out of the relationship with SNI Group
AMPERE Gestion takes particular care to ensure that any dealings with other entities within SNI Group are conducted with a view to safeguarding clients’ interests and AMPERE Gestion’s autonomy.

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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Specific legal information

  1. Nature and scope of website
The products and/or services presented on this website shall not replace the legal documents for each investment fund.

The information presented on this website shall constitute neither an offer of products or services that form part of an offer to the public, nor any form of solicitation, investment advice, investment proposal or recommendation of an arbitrage or investment strategy to be deployed on the financial markets.

This information is taken from documents and media deemed to be reliable. However, AMPERE Gestion cannot guarantee that this information has been transcribed onto the website free from any material errors.

AMPERE Gestion shall endeavour to ensure the accuracy, timeliness and completeness of all information published on its website and reserves the right to change the content or presentation of said website at any time without prior notice.

AMPERE Gestion cannot be held liable, in any way whatsoever, for any direct or indirect harm that arises from using this information. The information contained on this website may not be reproduced, circulated or distributed, in part or in full, to any third party without the prior written consent of AMPERE Gestion.

 

  1. Restrictions arising from different international legal systems 
Persons who access, visit or use this website must ensure that the law of their own country allows them to access this information or else refrain from doing so.

 

  1. Market analyses and opinion posted on this website
Market analyses, opinions, convictions or interviews posted on this website represent the opinion of AMPERE Gestion at a given time and in relation to a given subject. They are likely to change over time and include by their nature forecasts and indications. AMPERE Gestion cannot be held liable, in any way whatsoever, for any harm suffered as a result of an investment decision made on the basis of such opinions, analyses and interviews, or for any change in these over time.

 

  1. Disclaimer regarding the products and services presented on this website 
Users are reminded that this website cannot be used to subscribe to any operation concerning the products and services presented.

Before entering into any operation, it is recommended that clients weigh up the investment opportunity in light of their financial, tax and legal situation as well as their investment objectives. We also recommend that clients seek advice from their usual advisers.

Users are reminded that before subscribing to any offering, all potential investors must have consulted the prospectus and regulatory documentation relating to the product and that documentary proof of identification will be requested in accordance with anti-money laundering legislation and other applicable regulations.

 

  1. Performance of the funds presented
Past performance is not a guarantee of future results and performances are not constant over time. Both income from and the value of the investment may fluctuate. No guarantees can be given as to the principal, income or performance of the funds presented. AMPERE Gestion cannot be held either directly or indirectly liable for the use that is made of the information that appears on this website.

 

  1. Liability of AMPERE Gestion
Both AMPERE Gestion and its employees shall endeavour to ensure the accuracy and timeliness of the information published on this website and AMPERE Gestion reserves the right to change its content at any time whatsoever, without any prior notice. However, they cannot guarantee the completeness of the content nor the absence of third-party modifications (intrusions, viruses, etc.). AMPERE Gestion and its contributors hereby disclaim any (direct or indirect) liability in the event of any delay, error or omission concerning the content of these web pages and the use to which they may be put by any person, including interruption or non-availability of the service.

 

  1. Governing law and jurisdiction
The official language of this website is French and it is subject to French law. Any dispute or litigation arising from the use of this website shall be submitted to courts within the jurisdiction of the Paris Court of Appeal.