Shareholder commitment policy and voting policy
To find out moreEngagement report and report on the exercise of voting rights
To find out moreReport Article 29 of the energy and climate law
To find out moreObject
Object
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
- Financial instruments 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.
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 :
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.
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 the financial intermediaries is done at the end of each semester by assigning a score from 0 (the worst) to 5 (the best) for each of the conditions mentioned above.
- Best execution for our customers
- Analysis and research
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 : for orders relating to shares and bonds, DNCA Finance has selected the CIC, as intermediation table, authorized for the receipt / transmission of orders (approved as Establishment credit - Investment services provider by the ACPR (Prudential Control and Resolution Authority)).
Intermediation fees report for the year 2023
In accordance with Article 321-122 of the AMF GR
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 2023, for its collective management activity, DNCA Finance 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 2023 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;
- Execution costs thus accounted for 100% of the total intermediation costs paid in 2023.
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 2023. In addition, the intermediaries are assessed annually in order to estimate the quality of execution obtained from each of them.
ESG integration policy
Actions Quality Responsible Growth
DNCA Finance Luxembourg Branch particular attention to the clients satisfaction as well as to the investors protection. For that purpose a complaints handling procedure has been set up.
If there is no doubt that the communication is a complaint, specifying that a complaint is a « complaint filed with a professional to recognise a right or to redress a harm »[1], the file addressed to DNCA Finance Luxembourg will be immediately communicated to the Compliance Officer who has been designated responsible for complaints handling and follow-up.
Complaints can be filed to DNCA Finance Luxembourg Branch:
- by calling phone number : +352 28 48 01 55 20
- by sending an e-mail to : bsd@dncafinance.com
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by sending a letter to : DNCA Finance Luxembourg Branch
- Or by going directly to the office at the same address as above.
Requests can be expressed in English, French or Dutch.
In order to be admissible the request should include at least the complete identification of the complainant and describing the essence and details of the complaint.
Delay processing
An acknowledgement of receipt will be provided to the complainant within ten business days after receipt unless the answer itself is provided to the complainant within this period.
An answer will be provided within one month starting from the date of reception of the complaint except for particular circumstances. In this case, the complainant will be informed about the situation.
Escalation procedure
Where the complainant did not obtain an answer or a satisfactory answer from the Compliance Officer, he/she has got the opportunity to rise the complaint up to the branch manager of DNCA Finance Luxembourg Branch, who can be contacted at this address :
The out-of-court complaint resolution procedure at the CSSF
Where the complaint handling at the level of the branch manager did not result in a satisfactory answer for the complainant, DNCA Finance Luxembourg Branch shall provide the complainant with a full explanation of its position and inform the complainant in writing of the existence of the out-of-court complaint resolution procedure at the CSSF.
This procedure aims at facilitating the resolution of complaints against professionals without judicial proceedings. However it does not consist in a mediation procedure.
The opening of the CSSF procedure is subject to some conditions. In particular, the complaint must have been previously sent in writing to the branch manager of DNCA Finance Luxembourg Branch and the complainant has not received an answer or a satisfactory answer within one month from the date at which the complaint was sent.
The out-of-court complaint resolution procedure is framed by the CSSF regulation N°16-07 available on the CSSF website : http://www.cssf.lu/.
Any further information regarding the complaints handling procedure is available free on request.
Statement on due diligence policies regarding the main negative impacts of investment decisions on sustainability factors
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.
