Responsible investment policy:
Our world has advanced more in the last century than in hundreds of millennia before that. This unprecedented level of development raises new challenges for the next 50 years. The companies that come out at the top will be those able to anticipate and adapt to new practices. This transition towards a new mentality, and more responsible culture, offers big opportunities.
See also the page on the SRI-certified BDL Transition fund.
Broker selection and assessment:
BDL Capital Management is required to ensure that orders placed on behalf of its managed funds are executed on the best possible terms, to act in unitholders’ best interests.
Given the nature of its collective investments and fact that it has no direct access to the market, BDL Capital Management has an obligation to select intermediaries whose best execution policies will ensure the best possible result when orders are executed.
As per regulations, BDL Capital Management establishes and operates a broker selection and assessment policy, which it reviews each year.
The main criteria used for selecting and assessing brokers and counterparties are: quality of research, quality of advice and recommendations,, quality of execution anddirect access to companies..
Brokers and counterparties are assessed every six months on the basis of criteria listed in the previous chapter. In monitoring operating risks, the risk manager may be involved in this assessment if it is felt that the problems relating to a broker could increase operating risks considerably. This assessment is submitted to the Investment Committee.
A score of 0 to 4 is is assigned to each of the items listed. These are then weighted to attach more importance to those criteria deemed most important by the management team.
The itemised results are compiled in an automated file, producing an overall score per broker. This assessment is then discussed at the Investment Committee meeting.
For any new counterparty, the Chief Compliance Officer checks the presence of onboarding documents before any transaction with this new counterparty.
If a broker or counterparty no longer meets the qualitative and/or quantitative criteria set by BDL CAPITAL MANAGEMENT, the Investment Committee may decide:
- to limit order flows with the broker;
- to suspend the relationship;
- to send a letter to the broker or counterparty discussing the problems identified
In cases where the criteria are no longer met, if BDL CAPITAL MANAGEMENT wishes to end the commercial relationship with a broker or counterparty, it must, where possible, unwind all outstanding transactions with the entity in question.
BDL Capital Management undertakes to inform clients of any important change to its order execution system or policy by updating the procedure on its website.
Exercise of voting policy
Conflict of interest management policy:
The prevention and management of conflicts of interest at BDL Capital Management reflect the general principles of Markets in Financial Instruments Directive 2004/39/EC, incorporated into French law on 12 April 2007.
Article L.533-4 of the French Monetary and Financial Code, articles 322-33 and 322-38 of the AMF General Regulation, article L.533-10 of the French Monetary and Financial Code, and articles 313-18 to 313-22 of the AMF General Regulation applicable as of 1 November 2007, set out the relevant obligations incumbent on any management company. BDL Capital Management established, and operates, a conflict of interest management policy to:
identify conflicts of interest;
hold a register of conflicts of interest encountered;
inform clients when conflicts of interest cannot be resolved.
The aim of BDL Capital Management's policy on preventing and resolving conflicts of interest is to establish organisational measures and administrative procedures with a view to identifying and managing conflicts of interest that may arise when providing investment services.
A conflict of interest is defined as: "a harmful conflict between the interests of the company and those of its clients, or between the interests of different clients of the company". BDL Capital Management has made arrangements under the responsibility of a Chief Compliance Officer.
If you wish, you can obtain more information about our conflict of interest management policy on request.
Complaints handling policy
BDL Capital Management has drawn up, and updates, an operating procedure to handle complaints quickly and efficiently. Any complaint may be sent by post to the Chief Compliance Officer at:
BDL Capital Management
24, rue du Rocher
BDL Capital Management undertakes to send clients an acknowledgement of receipt within 10 business days of receiving the complaint, and to respond within two business months of this same date, unless duly explained circumstances dictate otherwise.
If the dispute cannot be resolved, clients may contact the AMF mediator. The AMF’s mediators contact details are:
Médiateur de l’AMF
Autorité des Marchés Financiers
17, Place de la Bourse
75082 Paris Cedex 02
Access to the complaints service is free, so clients cannot be charged any specific fees for having the complaint dealt with.