I - General framework

In accordance with its principles and the regulatory requirements, the management company puts the interests of its customers first with the aim of preventing any conflict of interest. Steps are taken to prevent the presence of differing interests at any given time from impeding the achievement of this objective.

  • Great care is taken in particular to ensure that customers’ interests take precedence over all others. Specific rules define the conditions under which funds must be marketed. The sales offer is based on knowledge of the customer and of their expectations and notably includes detailed information on the features of the funds offered and the characteristics of the product governance (MIFID II) relating to them.
  • Funds proposed by customers are treated equitably, with no particular advantage offered to one to the detriment of another. More generally, staff must perform their duties in an honest, diligent and loyal manner in accordance with the rules of ethics that apply to the management company. The customers’ interests prevail, whether it be over the personal interests of members of staff or over the interests of the entity to which they belong.
  • The pre-eminence of customers’ interests also demands that certain duties be exercised with due independence and confidentiality. The management company is structured into major business lines with a view to facilitating this approach. This involves “Chinese Wall” procedures aimed at avoiding the unwarranted circulation of confidential or privileged information.
  • Members of staff who, due to their roles, are particularly liable to find themselves in a conflict of interest or to hold confidential or privileged information, are subject to specific obligations for financial instrument transactions that they wish to perform on their own behalf.
  • The management company has put a mechanism in place to identify, prevent and manage conflicts of interest. The control departments are responsible for ensuring the proper application of the measures taken for this purpose as well as compliance with any associated regulatory requirements, notably those relating to customer information.

II - Main implementing arrangements

Identifying conflicts of interest

Mapping has been completed to identify conflicts of interest that may arise directly or indirectly between the different activities carried on or between entities of Crédit Mutuel Alliance Fédérale. Such conflicts of interest might arise between the service providers themselves, the persons under their authority or acting on their behalf or any other person who is in a direct or indirect control relationship with them, and their customers on the one hand or, on the other, between two customers, during the provision of any investment service or any related service or combination of such services.

To complete this mapping, potential conflicts of interest were identified based on the regulations in force and compliance with the principles referred to above with regard to the primacy of customers’ interests, equitable treatment of customers, the separation of business lines and independence of roles.

Preventing conflicts of interest:

The prevention of conflicts of interest hinges on the following key measures:

  • material provisions designed to prevent any inappropriate overlapping of activities (separate premises, specific clearances, rules on storing and transmitting information, etc.)
  • appropriate organisation of the departments themselves (notably with reporting lines that correspond to the duties performed)
  • procedures aimed, in particular, at highlighting the primacy of customers’ interests in the management and marketing of funds, preventing the unwarranted circulation of information, formally defining the applicable ethical rules and safeguarding the independence of functions that so require
  • regular audits of the application of these rules and procedures

Managing conflicts of interest:

Potential or existing conflicts of interest are catalogued and suitable measures are put in place to resolve them.

Should the measures taken prove insufficient to guarantee, with reasonable certainty, that the risk of harming the Customer’s interests has been removed, the Customer shall be informed, as required by the applicable regulations.