this document aims to inform our clients of the selection policy for the financial intermediaries to which we entrust order execution as part of the management under mandate, such as ucits management.

it has been prepared in accordance with articles l 533-18 of the french monetary and financial code (code monétaire et financier) and 314-75-1 of the general regulations of the french financial market authority (autorité des marchés financiers, hereinafter 'AMF').

• Clients concerned

The selection policy in force at our company applies uniformly to all our clients, whether professional or otherwise. the implementation of this policy's principles differs depending on whether collective management or management under mandate is involved.

• Financial instruments concerned

The selection policy in force at our company applies to all financial instruments traded by our company. dnca finance systematically entrusts its orders to an intermediary, whatever the financial instrument.

Our market intermediary selection policy takes account of :

• Best execution for our customers

The conditions taken into account are price, cost, speed (order transmission not execution), the probability of execution and settlement (in particular the cost and security of settlement and delivery), size, type of order and any other consideration relating to order execution (such as place of execution and market effect). dnca finance has taken steps to be categorised as a professional client with all intermediaries it seeks to use such that these are required to provide it with the best execution that it itself has to guarantee for its clients.

• Analysis and research

French research (database coverage and accessibility), european research (database coverage and accessibility), analysis quality (pertinence, originality against consensus, rigour in financial analysis and monitoring of recommendations), the relationship with companies (organisation of financial presentations and face-to-face meetings with managers) and the availability of the research office (presentations on-site, frequency of contacts with the analyst).

A rating of between zero (the worst) to five (the best) for each of the conditions mentioned above.

DNCA Finance has authorised all its intermediaries to manage the orders it originates on key regulated markets, multilateral trading facilities and systematic internalisers, in order to be able to benefit from the best implementation conditions on offer.

Special case of the selection of interest-rate financial instruments : since march 2009, dnca finance has used the services offered by BP2S Dealing Services (formely fin'ams) a bnp group company to outsource the placing of orders – that is, their trading – on all interest-rate financial instruments whenever it appeared suitable.

Special case of the management under mandate investment service : the managers of the accounts opened with cm-cic securities may prefer to use cm-cic securities as financial intermediary whenever the ease and speed of execution take priority over other considerations.

In accordance with Article 321-122 of the AMF GR

In accordance with Article 321-122 of the AMF GR, the Management Company shall draw up a document entitled ‘Reporting on intermediation costs’ when using Investment and Order Execution Services and intermediation fees for the previous financial year amounted to more than 500000 euros.

Conditions under which DNCA Finance has used investment decision support and order execution services:

In 2019, collective management and mandate based management services used financial intermediaries who provided execution and investment decision support services, under the conditions defined in the ‘Financial intermediaries selection and execution policy.’

Intermediation fees are received directly or indirectly by third parties that provide services to assist in the investment decision making and execution of orders.

Expenses related to investment decision support services are borne in full by DNCA Finance out of its own resources.

The key to the allocation for 2019 between the execution costs and the fees for the investment decision support and order execution services is therefore as follows:

• Fees related to investment decision support and order execution services accounted for 0% of total intermediation costs since they were borne by DNCA Finance out of its own resources (including using the remainder derived from previously shared commission agreements);
• Execution costs thus accounted for 100% of the total intermediation costs paid in 2019.

As of 31/12/2019, DNCA Finance no longer had commission agreements shared with third parties.

Regarding the mandate investment service, DNCA Finance mainly retains the service of reception and transmission of orders offered by the custodian account holder of the managed accounts.

Conflict of interest prevention

DNCA Finance has put in place a policy for preventing and managing conflicts of interest incorporating the prevention of potential conflicts of interest related to the selection of intermediaries:

• The Company does not receive soft commissions from its intermediaries;
• Each intermediary is subject to a prior selection procedure (see intermediary selection procedure);
• The agreements put in place do not include any minimum volume requirement or incentive pricing arrangements;
• DNCA Finance does not receive any retrocession of transaction fees from its intermediaries.

No conflict of interest was detected in the selection of our intermediation providers in 2019. In addition, the intermediaries are assessed annually in order to estimate the quality of execution obtained from each of them.

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DNCA FINANCE has established and maintains an operational procedure for handling complaints from its customers in respect of all management and investment services provided by DNCA FINANCE and its branches.

A complaint is defined as a statement of dissatisfaction by the customer that requires a response. A request for information, advice, clarification, service or provision is not a complaint. (AMF Instruction 2012-07).

Customers (professional or non-professional) may submit any complaints they may have, free of charge, either to their usual contact person (within the company or within one of the company's delegated agents) or directly to the company's Head of Compliance and Internal Control (RCCI) by writing to the company's registered office (19 Place Vendôme, 75001 Paris, France).

After receipt at the company's registered office, the portfolio management company has ten days to acknowledge receipt and a maximum of two months to respond to any complaint from the date the complaint was sent.

In France, customers who are dissatisfied with the action taken on their complaint through DNCA Finance's internal mediation channel have a possible recourse outside the usual legal channels:

• For disputes concerning a financial instrument, an investment service or, more generally, a matter falling within the AMF's remit: The AMF Ombudsman, whom they can contact by post (Médiateur de l'Autorité des Marchés Financiers, 17 place de la Bourse, 75082 PARIS CEDEX 02, France) or by completing the mediation request form available on the AMF website https://www.amf-france.org/fr/le-mediateur. 
• For services related to DNCA Courtage's insurance brokerage service: the Médiation de l'Assurance, by post (Médiation de l'Assurance, TSA 50110, 75441 Paris Cedex 09) or by internet via their website: https://www.mediation-assurance.org/Saisir+le+mediateur

Last update: 05/12/2023 

Article 4 of the SFDR (EU) 2019/2088 on sustainability reporting in the financial services sector requires transparency on negative sustainability impacts on sustainable investment objectives or on the promotion of environmental or social characteristics in the investment decision making of our relevant products.
DNCA Finance wishes to strengthen the consideration of negative sustainability impacts in its decisions and organisation. The governance of these topics will be defined in procedures to clarify the roles and responsibilities of the different teams.
DNCA Finance already considers negative sustainability impacts on investment objectives and has published various documents confirming this.
Indeed, DNCA Finance has published its Responsible Investment Policy, which outlines its environmental, social and governance (ESG) investment policies and practices. It illustrates the commitments to responsible investment in all its activities, in compliance with French and international regulations and their evolution. The policy is available on the management company's website.
In addition, DNCA Finance has developed a voting policy that defines the principles it intends to apply when exercising voting rights at general meetings. These principles reflect best practices in corporate governance and form the basis of our philosophy and vision of a quality corporate governance system.
This voting policy includes a "Corporate Responsibility" section that describes DNCA Finance's belief in integrating extra-financial elements into management to improve the risk/return ratio over time.
Although DNCA Finance votes on social, political or environmental shareholder proposals on a case-by-case basis, we systematically support any resolution where we consider the subject matter - after analysis - to be conducive to more responsible practices by the company's business. In addition, DNCA Finance will vote in favour of shareholder resolutions requesting the inclusion of non-financial criteria in executive remuneration policies, unless such requests represent constraints that are not in the interest of the company and its shareholders.
DNCA Finance is also committed to combating climate change. In addition, DNCA Finance is working with a leading climate provider to offer its clients solutions to integrate climate risks such as transition risk and physical risk into their investment management.
Finally, a number of initiatives are also described in the general CSR policy of the Natixis Group.
DNCA Finance is not currently in a position to monitor all the indicators with a negative impact on sustainability, as a certain amount of data, the sources of which have not yet been identified, does not allow for all the reports required by the SFDR regulation to be provided at entity level. DNCA Finance will do its utmost to be able to provide and produce them in a comprehensive manner and will modify its position accordingly.
However, DNCA Finance is already able to assess the climate risks associated with all its investments in corporate securities (equity and debt) and plans to provide a set of non-financial performance indicators for the majority of these investments by the end of June 2021.

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