Regulatory Information
- Important
Any investment in a UCI or any related product should only be made after reviewing the current regulatory documents.
The prospectuses and KIIDs of every UCI authorised by the Commission de Surveillance du Secteur Financier (Luxembourg financial supervisory authority or CSSF) are available from the website.
The other regulatory documents are available on request from SILEX Investment Managers, 32 Rue de Monceau, 75008 Paris, France.
Investment in financial products may involve risk. The value of a share in a SICAV the value of the securities and assets held in the portfolio and is subject to market fluctuations.
Investors may lose some or all of their capital, as the capital in the funds is not guaranteed.
- Best selection policy
All investment service providers have an obligation to act in the best interests of their clients when executing orders that result from investment decisions for the portfolios.
To this end, in its capacity as management company, and having regard to the nature of its business, SILEX Investment Managers is obligated to select intermediaries whose execution policy guarantees the best possible result when executing orders sent on behalf of its clients. SILEX Investment Managers nevertheless remains responsible for best execution with respect to the processing of certain transactions carried out directly on the market.
In accordance with the regulations, SILEX Investment Managers has put in place an order execution policy that allows it to obtain the best possible result with respect to client orders. The order execution policy notably requires that orders be registered and processed in a timely and accurate manner, having regard to market conditions.
This order execution policy is based on:
a standardised process for selecting financial intermediaries and counterparties
a process for selecting execution venues
an analysis and selection process with respect to the reporting provided by service providers as part of best execution.
SILEX Investment Managers uses a multi-criteria approach to select intermediaries that guarantee the best execution of market orders.
The criteria applied are both quantitative and qualitative. They depend on the markets for which the intermediaries provide services, in terms of both geographical area (global, pan-European or local intermediaries) and financial instruments traded (intermediaries specialised in equity, interest rate, convertible or derivatives markets).
Every analysis criterion is subject to an assessment, which is allocated a weighting coefficient, thereby enabling an overall rating to be attributed, subsequently allowing all intermediaries analysed to be ranked with a view to drawing up the list of intermediaries actually selected.
The analysis criteria notably cover the availability and proactiveness of the intermediary representatives, the financial situation of the intermediaries, their speed, the quality of the processing and execution of orders and intermediary fees.
The intermediaries’ ratings are updated every year. Based on this, the list of selected intermediaries is also reviewed annually.
The summary of our selection policy described above is updated whenever the policy changes. The policy can be obtained on request from the management company.
- Conflict of interest management policy
SILEX Investment Managers makes every effort to identify conflicts of interest that may arise in the course of providing investment or related services or fund management services.
SILEX Investment Managers has a conflict of interest management policy in accordance with current regulations.
This policy is commensurate with the size, structure, nature, importance and complexity of SILEX Investment Managers. It includes procedures to follow and measures to take in order to manage conflicts of interest, the aim being to ensure the primacy of clients’ interests and respect for market integrity.
This policy can be obtained from the management company on request.
In accordance with current regulations, SILEX Investment Managers also holds and updates a register that lists situations in which a conflict of interest has arisen whenever applicable.
When the organisational or administrative measures taken by SILEX Investment Managers to manage conflicts of interest are not sufficient to avoid the risk of damaging investors’ interests with a reasonable degree of certainty, the company will clearly inform investors of the general nature and/or source of these conflicts of interest. Based on the identification of conflicts of interest, a mapping of conflicts of interest has been drawn up. This mapping identifies the circumstances that give rise or may give rise to a conflict of interest. It makes it possible for SILEX Investment Managers to identify and, if necessary, manage fairly any conflicts of interest that may arise in the course of carrying out its services, between its own interests and those of its clients or between the interests of several clients.
- Voting policy
- Preamble
In accordance with regulations, SILEX Investment Managers has established a voting policy setting out the conditions under which it intends to exercise the voting rights attached to the securities held by the funds it manages.
- Organisation for exercising voting rights
The exercise of voting rights at general meetings is the responsibility of the investment managers who analyse the resolutions of general meetings. Managers can rely on recommendations from the French Financial Management Association (AFG). The fund managers always vote in favour of the good functioning and good governance of the company as well as in the interests of the shareholders.
- Cases of exercise of voting rights
Voting rights are systematically exercised when the proportion of the company's capital held by the UCIs is greater than 3%.
- Principles of voting policy
The principles of SILEX Investment Managers 'voting policy are based on respect for good corporate governance while respecting the interests of the unitholders, and taking into account the recommendations issued by the AFG.
- Conflict of interest prevention
The voting policy of SILEX Investment Managers is established independently. The voting rights are exercised strictly in the interests of the unitholders, without taking into account the specific interests of SILEX Investment Managers, and in compliance with the principles defined in this policy. SILEX Investment Managers has set up an organisation, procedures and control system to prevent any potential conflict of interest.
- Method of exercising voting rights
Voting rights are in principle exercised by correspondence, by proxy, by electronic voting. Nevertheless, the fund managers may attend general meetings from time to time.
- Report and communications
An annual report is prepared within four months of the close of SILEX Investment Managers'fiscal year, which takes place at the end of December, reporting on the conditions for exercising voting rights. It specifies the number of companies in which SILEX Investment Managers has exercised its voting rights in relation to the total number of companies in which it has voting rights, as well as the cases in which it has deemed unable to respect the principles set out in this voting policy. Situations of conflicts of interest encountered during the exercise of voting rights are also incorporated into this report.
report shall be made available to the Autorité des marchés financiers and to all holders of the UCIs or principals who request it. It is also published on the website of SILEX Investment Managers. If SILEX Investment Managers does not exercise its voting rights, no annual report is published in accordance with the applicable regulations in this case.
- Preamble
- Report on intermediary fees
In accordance with, when SILEX Investment Managers uses order execution and investment decision support services, and intermediary fees for the previous financial year exceeded EUR 500,000.00 SILEX Investment Managers has drawn up a document entitled “Report on intermediary fees” and available : XXXX
- Processing client complaints
In compliance with the regulations in force, SILEX Investment Managershas implemented and maintains an operational procedure to quickly and efficiently process complaints made by its clients.
This client complaints procedure applies to all customers regardless of their category.
Any complaint may be sent via:
Registered mail to Executive senior manager & Head of Compliance and Internal Control at SILEX Investment Managers, 32 Rue de Monceau, 75008 Paris, France,
by email to reclamation-silex-im@silex-partners.com.
SILEX Investment Managers will acknowledge receipt of the complaint within ten working days of the date on which it was received, unless a response has been issued to the client in the intervening period. Except in duly justified exceptional circumstances, a response will be issued to the client within two months of receipt of the complaint.
The communication sent by the client must clearly state that it is a claim.
In the event of an ongoing dispute, the client may contact the AMF mediator. The address of the AMF Ombudsman is:
Autorité des marchés financiers
Madame Marielle Cohen-Branche
Médiateur de l'AMF
17 place de la Bourse
75082 Paris Cedex 02The AMF mediation request form and the Mediation Charter are available online at http://www.amf-france.org.
Proceedings are confidential, free, contradictory and non binding. Each of the parties may terminate it whenever they so wish and retains the right to bring the matter before the courts.
However, before referring the matter to the AMF Ombudsman, it is necessary for the client to make his first approach to the Chief Executive Officer of SILEX Investment Managers.
- Portfolio inventory transmission policy
In accordance with the AMF's ‘Market Timing and Late Trading (DOC-2004-07)’ position, this section details the conditions under which SILEX Investment Managers intends to provide unitholders with the detailed inventories of the funds in which it is the statutory management company.
In order to avoid the practice of market timing, SILEX Investment Managers Managers does not communicate real time details of the Fund's portfolio to a prospect, client, distributor, consultant or other external counterparties or intermediaries.
The associated principles and procedures referred to in this section do not apply to mandates, the information of which may be communicated at any time to their principals and to dedicated funds provided that the information is communicated concurrently to all holders.
- Rules for the dissemination of sensitive information
- Standard rules
Recipient Type of data Date of the information to be transmitted Waiting time before distribution Confidentiality Commitment Unitholders or shareholders of the UCI Portfolio structure or top 10 positions Last NAV data for the previous month 5 days No Full portfolio composition 1 month Yes Leads Portfolio structure or top 10 positions Last NAV data for the previous month 5 days No - As professional investors subject to supervision by the ACPR, the AMF or equivalent European authorities subject to Solvency 2 requirements (Directive 2009/138/EC)
SILEX Investment Managers may provide these investors with the information necessary to enable them to fulfil their regulatory obligations, with the signature of a confidentiality commitment. SILEX Investment Managers may provide a report, within a deadline of no less than 48 hours with effect from the latest publication of the net asset value.
- Standard rules
- Rules for the dissemination of sensitive information
- List of sub-custodians
In certain countries, custodians delegate the custody of assets:
access the list of sub-custodians used by CACEIS (SILEX RISK MANAGED SICAV Custodian)
access the list of sub-custodians used by CBP QUILVEST (SILEX FUND SICAV Custodian).
- Remuneration policy
SILEX Investment Managers ’s Remuneration Policy has been approved by the Board of Directors of the management company. The provisions of the Remuneration Policy are reviewed on a regular basis by the Remuneration and Appointments Committee and are adjusted to fit the changing regulatory framework. The remuneration policy includes a description of how remuneration and benefits are calculated. A copy of the policy is available free of charge upon request.
- Report 29 of the Energy and Climate Law