Regulatory information

Index:

• Client complaints
• Intermediary fees summary
• Voting policy & voting right exercise report
• Best selection
• Conflicts of interest policy
• Taking ESG criteria into account
• Remuneration policy

Client complaints

Complaints can be sent by post to Mansartis at the following address: Mansartis, 8 place Vendôme, 75001 Paris, or by email to your usual manager.

Mansartis has established an efficient and rapid procedure for processing client complaints. Mansartis undertakes to process client complaints within the following deadlines:

• ten business days from the sending date to acknowledge it, unless a reply is sent to the client beforehand;
• 2 months maximum between the complaint sending date and the date a reply is sent to the client except under duly justified specific circumstances. This service is entirely free of charge.

Client complaints are centralised by the Head of Compliance and Internal Control.

Clients who are dissatisfied with the processing of their request can refer to the appropriate mediator, i.e. the AMF market regulator in the case of investment mandates, or the ACPR prudential supervisory authority regarding life insurance policies.

AMF market regulator mediator address: Médiateur de l’AMF - Autorité des Marchés Financiers, 17 place de la Bourse, 75082 Paris, Cedex 02 - www.amf-france.org

ACPR prudential supervisory authority mediator address: Médiateur de l’ACPR - Autorité de contrôle prudentiel et de résolution - DCPC/SIR, 61 rue Taitbout, 75436 Paris, Cedex 09 – www.acpr.banque-france.fr

Intermediary fees summary

Mansartis uses outsourced investment decision-making (financial research) and order execution services. Fees for these services are reviewed annually.

Breakdown between decision-making and order execution services provided for assets invested in equities, funds and management mandates:

• 25% in order execution service fees
• 75% investment decision-making service fees

Mansartis has arranged commission sharing agreements (CSA).

Research fees are available on request from the investment management company (global@mansartis.com)

Measures implemented to prevent or manage potential conflicts of interest in selecting service providers

The process for selecting and assessing service providers is governed by the best selection and conflicts of interests policy procedures outlined below.

POLITIQUE DE VOTE

Organization

Given its size, Mansartis decided to rely on the expertise and services of a proxy-voter. Mansartis has forged a partnership with the world leader in this area: ISS - Institutional Shareholder Services.

ISS provides support in the operational voting procedure thanks to its voting platform to which each manager has access. The latter is connected directly to the positions of our funds registered by our custodian (CACEIS Bank).

This platform allows automated monitoring of General Meetings for which Mansartis holds Ballot (s) and intends to exercise its right to vote.

The portfolio managers are responsible for the voting decisions taken. However, for the sake of efficiency, the operational procedure relies heavily on the ISS platform and the subscribed proxy-voting service: ISS pre-filled all the ballots for which Mansartis intends to exercise his / her vote (s) based on a specific voting policy to which Mansartis has subscribed and which is detailed below (Sustainability policy). The manager can modify the votes at any time, a justification will then appear in the tool. Unless otherwise advise by the manager, ISS recommendations will apply.

Principles of voting policy

Mansartis exercises its voting rights attached to the securities held in the fund it manages in the fund’s shareholders interest. To this end Mansartis relies on the policy formalized by ISS entitled "Sustainability Policy".

The guidelines of this policy emphasize the sustainability and long-term development of businesses through the promotion of best governance practices and the consideration of Environmental and Social issues.

The research approach of the ISS Sustainability Policy includes the use of ESG risk indicators, which cover several subjects and issues such as the environment, human rights, labor law, impact on local communities, monitoring of the supply chain, corruption issues etc.

The "Sustainability Policy" aims to promote publication and transparency in terms of reporting by companies on how they manage the sustainable development challenges they may face. For example, this policy generally supports resolutions that promote:

• Better publication of the environmental policies in place, including measures to combat climate change and the elements favoring carbon footprint reporting.
• Greater transparency of social policies such as those concerning discrimination in the workplace and efforts to diversify boards of directors, human rights and respect for human rights standards / codes of conduct; etc.
• Publishing reports on sustainable practices, including recycling, wood supply, water use, operations in sensitive or protected areas, energy efficiency / renewable energy and integration of performance measures linked to sustainable development in executive compensation…

The ISS Sustainability Policy nonetheless always focuses on a case-by-case assessment of these elements. For example, it may recommend voting "against" resolutions to create a new ESG oversight committee if analysis shows that the structure already in place is efficient in dealing with the issues in question.

In addition, this policy especially recommends to vote against all resolutions which are contrary to equality between shareholders and which favor excessive cumulation of director positions, a high number of directors who are not free of interest and increases in capital to protect yourself from takeover bids, in accordance with AFG recommendations.

Scope of exercise of voting rights

In accordance with its global engagement policy, Mansartis will always seek to exercise its voting rights for all of the securities held in funds’ portfolios under management, whatever the geographic area (with the exception of the cases described below).

However, in the interests of the holders, Mansartis reserves the right not to exercise its right to vote. For example, to ensure total control over the liquidity of the fund under management, Mansartis will not vote at General Meetings for which title blocking procedures are implemented. In the context of the Swiss market where these procedures are frequent, the manager will decide, on a discretionary basis, whether he wishes to exercise the voting rights attached to the securities held in the funds, but for a maximum of 80% of the rights. In addition, Mansartis will abstain if excessively complex POA (Power of Attorney) procedures are necessary to exercise its right to vote.

Voting report

In accordance with regulatory requirements, a voting report is drawn up by the management team annually and is available here : Rapport de vote 2019.

Best selection

In application of article L. 533-18 of the French monetary code and article 21 of the MIF Directive and articles 314-75 and 314-75-1 of the AMF market regulator rules, Mansartis Gestion is obliged to act in the best interests of its clients.

Our best selection procedure consists of selecting brokers for order execution. Under the procedure we take all reasonable measures to achieve the best execution possible for orders placed on behalf of portfolios managed by the investment management company.

Brokers are selected according to their specialisation by type of financial instrument (equities/fixed-income products) and their regional presence in Europe, North America and Asia.

In order to facilitate the search for liquidity and rapid order execution, Mansartis authorises its intermediaries to trade outside of regulated markets on multilateral trading systems or with market-makers and on other trading platforms.

Mansartis adopts a multi-criteria approach in selecting intermediaries guaranteeing the best order execution:

• Execution quality
• Research quality

NB selected brokers may be selected for one or both types of service.

Order execution assessment

Prior to testing execution quality, new brokers are assessed based on their reputation, creditworthiness, best execution policy and resources deployed.

Approved brokers are rated on the basis of:

• Order execution quality (price, algorithms, order routing technology, rapidity, etc.)
• Middle-office confirmation efficiency and seamless transaction settlement
• The ability to provide liquidity

Research quality assessment

The fund management team has defined a multi-criteria approach to assess research:

• The intrinsic quality of reports and presentations
• The investment universe covered
• Corporate presentations and seminars
• Direct access to analysts
• Added-value from sales contacts

Brokers are reviewed for reselection every semester by the approval committee based on the criteria referred to above. Intermediary selection is therefore reviewed twice per year. New brokers are selected at committee review meetings.

Our full selection policy is available on request from the investment management company.

CONFLICT OF INTERESTS POLICY

We have implemented precautionary measures in order to prevent the risk of conflicts of interest within the group.

In compliance with the regulations in force, Mansartis has implemented an appropriate conflict of interests management policy with regard the size of the company, its organisation and profile and business activity. The policy details the measures to be taken in order to manage conflicts of interests by ensuring the protection of client interests and the respect of market integrity.

Mansartis specifically undertakes to:

• detect and record potential conflict of interest situations;
• implement and maintain an efficient conflict of interests management policy;
• keep a log of services or business activities generating potentially damaging conflicts of interests;
• inform clients in the event of unresolved conflicts of interests.

Consequently, the policy outlines precautionary measures and control procedures put in place by Mansartis:

• Physical and hierarchical ring-fencing of business activities which may generate conflicts of interest (e.g. segregating Mansartis Gestion from Mansartis Finance);
• Transparency regarding personal transactions;
• Transparency regarding professional or private executive positions occupied by managers or employees;
• Monitoring the quality of outsourced duties and services provided;
• Transparency regarding gifts and perks received or granted in a professional context;
• Managing a restricted-stocks list;
• 1st and 2nd level permanent control measures.

A conflict of interest mapping procedure has also been established to identify potential conflicts of interest. The procedure ensures that conflicts are detected and managed equitably. Furthermore, in accordance with article 313-22 of the AMF general regulations, Mansartis has also put in place a register of detected conflicts of interests.

The policy can be obtained upon demand from the investment management company.

INFORMATION REGARDING ENVIRONMENTAL, SOCIAL & GOVERNANCE CRITERIA

Mansartis believes that taking ESG into account in our asset management helps reduce risks and enhance financial performance.

Mansartis has therefore decided to integrate ESG criteria over the medium term across all of its asset management activities, i.e.

• 7 open-ended funds
• 13 dedicated funds
• Investment mandates managing physical securities.

For total assets under management of €1024M on 31st December 2023.

The ESG integration project is currently in place for the following managed funds:

All information regarding SRI investment management process applied for those funds are available in the Transparency Code (AFG / FIR) available on each funds’ page.

We have not yet implemented an ESG approach that strictly respects the criteria of the french public SRI label within the investment management process of the following funds.

Mansartis may set up a specific approach for dedicated funds on clients request.

Information to be made available to mutual fund shareholders of the management company (art. L533-22-1 of the Monetary and Financial Code).

Mansartis’ response to the law on ecological transition is available here: Rapport Article 173.