Please take time to read this page: it details both the legal and regulatory restrictions which apply to the information contained and investment products referred to within Veritas Investment Associates’ website.
1. GENERAL INFORMATION
The current website is managed by Veritas Investment Associates, SAS with a registered capital of 476 000 €, whose headquarter is located at 25, place de la Madeleine, 75008 Paris – RCS Paris 812 021 582.
This website’s main objective is to introduce the company Veritas Investment Associates’ (“VIA”) asset management activity (“VIA AM”) and the products it offers.
The main purpose of this website is informational – it does not correspond to any type of selling activity.
VIA AM’s clients, prospects or visitors confirm having taken full understanding of the below legal mentions and make commitment to respect them in visiting the present web site.
The publication is managed by VIA AM’s Director of Publication M. Guillaume Dolisi – also acting as VIA AM’s Chief Executive Officer. OVH is the company in charge of the hosting side of VIA AM’s website. WeThinkBeautiful (WTB) is in charge of the management and the design sides of the website.
2. ACCESS TO THE WEBSITE
The funds, entities of the Luxembourg SICAV VIA AM presented on this website can only be subscribed in geographical regions covered by a regulated license. In consequence, in some countries, the ability to access products displayed can be limited by legal restrictions or prohibitions. Any individual (physical or moral) having access to one of the products offered on this website must ensure to fulfil requirements imposed by the in-force regulation. Similarly, part of the financial products offered within this website will be available for consultation to a specific type of investor – granted with dedicated rights of access.
The funds mentioned on this website are not registered under the United States Securities Act of 1933, nor the United States Investment Company Act of 1940 and therefore may not directly or indirectly be offered or sold in the United States of America or any of its states, territories, possessions or other areas subject to its jurisdiction or to or for the benefit of a United States Person.
3. INTELLECTUAL PROPERTY
The general structure, as well as the software, texts, pictures, animation, know-how and every other features constituent of this website are either the property of VIA AM, either the intellectual property of a third party of which VIA AM disposes for user license and diffusion.
Any total or partial representation of this site by any individual or company whomsoever, without the special authorization of the operator of this website is forbidden and would constitute a forgery punished by articles L. 335-2 and following of the Code de la propriété intellectuelle. This website is the property of VIA AM. Any copy or reproduction of a part or the totality of this website, without the special and written allowance of VIA AM is strictly forbidden.
4. PRIVACY NOTICE
Please find here our Privacy Notice : VIA AM – Privacy Notice
5. CONTENT OF THE WEBSITE
VIA AM is not responsible for mistakes or absence of information occurring on its website, as well as its content, accuracy or reliability. Part of the information offered can’t be regarded as exhaustive. Hence, they must be closely checked or be further investigated.
VIA AM reserves itself the right to correct the content of this website – at any time and with no advanced notice. Any information and data offered on this website are by no mean educational and can’t be assimilated to any advice. Every visitor has to proceed to exactness’s verification and to reuse them with judgment and critical thinking. The information offered on this website exempts by no means the website visitor to get informed elsewhere, before any subscription to any fund.
6. TECHNICAL INFORMATION
VIA AM declines any responsibility in case of damages on files of the Web user (loss, impairment, etc.) due to a bug transmission during the consultation of this website.
Users are informed that when they visit the website a cookie may install itself automatically and retained temporarily in the user’s memory or hard disk. A cookie is a component which does not enable the user to be identified but which is used to record information about the user’s navigation on the website.
Users of the website acknowledge that they have been informed of this practice and authorize VIA AM to use it. Users may de-activate this cookie by using the settings contained in their navigation software program.
8. LAW APPLICABLE
This website falls within the competence of French jurisdiction and is ruled by French law.
In accordance with the Regulation, VIA AM is processing claims stating:
- the obligation for the Management Company, to commit to respond to the claim of a customer or an investor within a maximum period of two months, except in special circumstances duly justified, and, if the answer is not immediately made, to acknowledge receipt within a period of ten working days maximum
- the process implemented allowing an equal and harmonized treatment to the claims
- the allocation of the resources and expertise necessary to ensure this treatment
- the obligation to follow-up on claims in order to identify and remedy potential malfunctions
VIA AM has established and maintains an operational procedure with a view to ensuring a fast, effective and free treatment of the claims submitted by its customers or investors within its activities of:
- management of the FIA within the context of the Directive No. 2011/61/EU (Directive AIFM), but financial management only by delegation
- portfolio management for the account of a third party within the context of the directive no. 2004/39/CA (MIF Directive)
- marketing of UCITS/AIF managed by another manager
- Investment Advisory
- development of indices on strategies
By “claim”, the current procedure means a statement detailing the discontent of the customer toward the professional: the latter considers that the benefit received, provided or advised by VIA AM does not correspond to its expectations or its needs.
A request for information, opinion, clarification, service or benefit is not a claim.
Are therefore not considered as claims:
- requests for specific marketing information/derogations
- service requests
- requests for information or those related to a simple misunderstanding
b. Terms Of Reference Of The Management Company
Any subscriber wishing to submit a claim to VIA AM is invited to send a mail to the following address:
VERITAS INVESTMENT ASSOCIATES
Guillaume Dolisi, Dirigeant et RCCI
25, 27 place de la Madeleine, 75008 Paris
A claim may also be addressed to VIA AM by email to firstname.lastname@example.org.
Depending on the communication channel used, VIA AM reserves the right to request a letter of complaint to the client so that there is no doubt on the object or the reason for the claim.
c. Procedure Details
- Opening the case:
- recording the case
- collecting elements of answer
- if necessary, sending an e-mail acknowledging receipt within a maximum period of 10 working days
- Recording the case:
- drafting the reply to client/bearer
- internal validation of the draft response and process of sending in a maximum period of 2 months
- Monitoring and Closing the case:
- following the claim up to its effective closing
- updating reporting and internal communication of the claim
- archiving and conservation
d. Appeal to the Ombudsman
VIA AM does not own an internal mediation service per se. However, if the Management Company rejects the claim or refuses to comply to it in whole or in part, the response addressed to the client informs him of the possibility to request the independent mediator from the AMF:
Mme Marielle Cohen-Branche
Médiateur de l’Autorité des Marchés Financiers
17 place de la Bourse, 75082 Paris Cedex 02
The AMF request for mediation form as well as the charter of mediation are available on the website
10. COUNTERPARTY SELECTION & BEST EXECUTION PROCEDURE
a. Controls targets
Controls made by the management company are intended to:
- ensure the quality of the choice and then the delivery of intermediaries according to the criteria of selection and assessment defined within this policy
- check the obligation of best execution of orders advised by the intermediaries
- act in the best interests of the managed portfolios
To this effect, the management company has put in place a control mechanism based on two levels:
- a First Level Control implemented by the concerned operational people, in particular the management team: it aims to ensure the use of an intermediary authorised in the order taking context and also allows to ensure the quality of services issued by the brokers,
- a Second Level Control implemented by the RCCI (or its delegate): in addition to the compliance with this policy, it aims to ensure that the management company has an efficient and operational process in the area of selection and also assessment of financial intermediaries
The procedures for the exercise of stagecoaches described below are adapted:
- to the nature of the operations carried out and to the underlying assets handled by the management company
- to its mode of implementation
- to the rights and obligations defined contractually
c. Chosen Method
The control process is based on the First Level controls achieved by the managers within their functions, thus aiming to ensure:
- the selection of financial intermediaries following the criteria defined within this policy
- their identification in the list of authorised intermediaries
- monitoring the execution treatment of the orders advised
- the efficiency of the relationship with the financial counterparties
- the annual assessment of intermediaries according to the criteria defined in this policy
- the annual review of the policy in place
A Second Level control is done by the RCCI (or its delegate), to ensure the effective implementation and the effectiveness of the means put in place in the area of selection and monitoring of the relations with intermediaries to act in the best interests of the portfolios managed by the management company.
d. Financial counterparties selection
Prior to opening the relationship, VIA AM verifies that intermediaries have the authorization and the means granted to the Management Company to periodically ensure their commitments relating to their policy of best execution of operations.
Concerning the brokers with which the orders initiated by the Management Company will be transmitted for execution, VIA AM ensures that it well receives, prior to the signing of a convention, the execution policy of the intermediary. The latter is the subject of an archiving within the folder broker related thereto.
The lack of commitment of the broker to ensure a “best execution” process would make any contract agreement impossible.
An “entry into relationship” sheet describing the new counterparty can be established by the management team.
Following the beginning of a new relationship with a counterparty, the list of authorised counterparties is updated by the management team, and then validated by the Management. A distribution of this list is then carried out to the management team, to the middle / back office, to the Branch and the RCCI.
The supporting documents which must constitute the file of the counterparty are requested by the manager who wishes to have recourse to the services of this broker and are centralized by VIA AM’s middle/back office.
The file will therefore contain:
- the convention of services signed with the counterparty
- the letter in which the intermediary categorizes VIA AM as a professional client, allowing the management company to benefit from a high level of protection in the context of the implementation of the operations initiated by itself, as well as elements of information from the financial intermediaries to ensure the respect of their commitments
- Documents relating to the identity and the ability of the counterparty (statutes and the extract of the certificate of incorporation) in cases where the latter would not be a financial institution within the context of article L. 562-1 of the Code Monétaire et Financier. For structures appointed in France by the AMF and by the CAPRA, this verification can be informal
- the policy of Best Execution transmitted by the broker
- the policy of prevention and management of conflicts of interest of the broker
- the list of places of execution where the broker provides to intervene (if not specified within the Convention)
- the broker’s pricing modalities (if not specified within the Convention)
- the consent of VIA AM for the transactions carried out outside a regulated market, where appropriate
- if applicable, the confirmation that the Broker supports the statements of transactions to the AMF (RDT)
Selection and Evaluation Criteria
The main criteria used for the selection and the evaluation of the financial intermediaries are:
- the cost of the intermediation/cost of brokerage
- the quality and reliability of the orders execution
- the ability to handle orders batches
- the quality of the administrative processing of orders (sending confirmations, quality of the back office…)
These criteria are designed to select and evaluate the intermediary based on its the orders execution delivery.
Other criteria may be added going forward, with the aim of improving the assessment carried out by the Management Company. VIA AM permanently monitors the relationship with its intermediaries on the basis of these criteria.
Relationship efficiency follow-up
The relationship follow-up with the intermediaries is permanently assured by the managers through the application of the best execution of orders tracking the market conditions evolution and the environment, and this in the exclusive interest of the portfolios managed.
This best possible result will not necessarily be reached on a case by case basis, for each individual order sent; it will therefore be appreciated through a series of transactions. Indeed, the best execution is monitored as a whole and not transaction by transaction and is only constitutive of an obligation of means.
The evaluation of each intermediate is carried out by each member of the management team through the filling of the two evaluation grids held under Excel format:
- the evaluation grid to assess the quality of execution of orders,
- the evaluation grid to assess the quality of the analysis and research is optional – VIA AM is not using the broker research as a decision-making tool
The overall results, criterion by criterion, are compiled and give rise to a general appreciation that allows the managers to take a decision on maintaining or not the relationship.
All failures and shortcomings identified by the collaborators linked with intermediaries will be reported to the RCCI (or its delegate) and to the management, to make the corrections accordingly.
The composition of the Audit Committee will at least include the members of the Direction, the management team and the RCCI.
With regard to the brokers, it has for missions to:
- validate a list of counterparties and financial intermediaries to which are transmitted the market orders for the account of the portfolios managed by the management company
- assess the brokers on the basis of the strict and constant evaluation criteria, defined in the process for the selection of financial intermediaries
- decide to integrate a new intermediary or, on the contrary, to end the relationship with a broker
- ensure compliance with and the periodic update of the present policy
It is the subject of the accounts signed by the participants, taking notice of decisions made. The documents are then archived within a dedicated directory in order to ensure the traceability and the audit trail of the process of evaluation of brokers implemented.
If a financial intermediary no longer meets the criteria defined by the management company, the Audit Committee may decide:
- to limit the flow of orders with the Broker concerned
- to send a mail to the intermediary in order to express the potential dysfunctions
- to suspend the relationship
In the case where the criteria are no longer met and if VIA AM wishes to stop the commercial relationship with a financial intermediary, it must, if possible, settle all the transactions in progress with the corresponding establishment. It will then conduct the withdrawal of the convention signed with the Broker concerned.
e. Order Execution Policy
The Management Company do not have a direct access to the markets but uses the services of financial intermediaries (brokers).
Similarly, the policy of “best execution” that must be put in place by the management company passes before any by the following two points:
- the application, ex ante, of a policy of “best execution” of brokers ensuring services of the best intermediaries,
- the application, ex post, of a number of controls to check the extent of the best possible result in the orders execution
This policy is subject to an annual review by the Audit Committee. It is held at the disposal of the AMF and customers who would formulate the request from the Management Company.
f. Report on the cost of intermediation
In accordance with the rules applicable (art. 314-82 of the General Regulation of the AMF), when the Management Company has uses the services investment decision services of assistance and orders execution and that the costs of intermediation (execution of orders) have represented, for the previous fiscal year, an amount higher than €500 000, VIA AM must develop an “account relating to the costs of intermediation”.
This document specifies the conditions under which VIA AM had recourse, for the previous year, to services of execution of orders and assistance to the investment decision.
It also details the measures implemented to prevent or treat any potential conflicts of interest in the choice of providers.
Where appropriate, this document will be made available on the website of VIA AM.
In addition, the management report of each mutual fund managed and the management account of each portfolio managed under mandate then directly refer to this document.
11. VOTING RIGHT POLICY
In accordance with the regulations, VIA AM establishes and maintains adequate policies, procedures and measures relating to the exercise of voting rights.
It is thus recalled that UCITS are required to vote the securities listed as assets and their decisions must always be taken in the interests of unit or shareholders.
a. Cases in which voting rights are exercised or not
Given the size of VIA AM and outstanding funds, it is physically difficult to participate and therefore vote at all meetings.
Indeed, participation in meetings depends on material constraints such as the procedure of immobilization of the securities, the accessibility of the documents necessary for the vote, the possibility of being physically present at the meetings and the actual cost of the vote.
- Subject to the limitations specified below, VIA AM participates in the voting at the general meetings of the companies it holds, for all the UCITS / AIFs it manages, at least 5% of securities in the same category or voting rights. It is specified that for the calculation of this threshold, the UCITS / AIF are aggregated.
The choice of this threshold is motivated:
- by the significant crossing thresholds,
- by the fact that below such a threshold the participation is not significant.
- Voting rights will be exercised for French issuing companies in which the UCITS managed by the management company hold securities.
- punctually or on an event outside the above cases, if the manager wishes to express a support vote or to express his disagreement, or in the event of significant difficulties posing an important risk to the shareholders, a vote may also be exercised.
b. Current method of exercising the voting rights
Depending on the availability of the management team, VIA AM votes according to these different methods:
- physical participation in the General Assembly,
- postal vote,
- proxy vote,
- electronic vote,
- allocation of his vote to the President.
The choice of voting method depends on the files and the internal organization of the company.
c. Conflicts of interest management
In the event of a conflict of interest, the manager informs the RCCI, which takes the necessary measures to resolve the conflict of interest.
In this case, VIA AM, unless expressly motivated, decides to base its voting decisions on the recommendations of the AFG.
Since VIA AM funds are not invested in affiliated companies, there are no Chinese walls as yet. Conflicts of interest related to, or having an impact on the present procedure are dealt with in procedure I.4 “Policy for the prevention and management of conflicts of interests”.
For any further information on this voting right policy, please send a request to email@example.com or by writing to VERITAS INVESTMENT ASSOCIATES 25, 27 Place de la Madeleine 75008 Paris, clearly indicating your first name, last name and contact information.
12. CONFLICTS OF INTEREST
In accordance with the applicable regulatory requirements, VIA AM establishes and maintains an efficient operational policy in order to manage conflicts of interest. It is written down and appropriate regarding VIA AM’s size, as well as the nature, size and complexity of VIA AM’s activities. This policy should thus enable the prevention, identification and treatment of conflicts of interest, to prevent them from adversely affecting the interests of clients and unitholders – and thus avoid any risk of reputation.
The scope as well as the conflicts of interest prevention and management processes and the conflicts of interest reporting are available on request.
13. ESG ratings
Article 173 of the Loi sur la Transition Energétique pour la Croissance Verte no 2015-992 dated 17 August 2015 modifies article L. 533-22-1 of the Financial and Monetary Code, which now states that asset managers have to provide detailed information relating to the inclusion in their investment policy of social, environmental and governance criteria and on the criteria themselves, to all subscribers to any fund they manage.
a. Integration of ESG criteria
VIA AM is fully aware of the importance of Environment, Social and Governance. However, VIA AM does not consider any such criteria in the management process of its funds. VIA AM may review this position in the future and opt for the inclusion of ESG ratings.
b. Information channels, frequency
VIA AM communicates on its website how its ESG policy is applied in its management process (Legal / ESG Ratings)
c. List of funds incorporating ESG criteria
None of the VIA AM funds accounts for ESG ratings.
d. Stewardship policy
VIA AM is not a signatory of the United Nations Principles for Responsible Investing
VIA AM considers that anti-personnel mines, cluster munitions, chemical, biological or nuclear weapons are controversial weapons. Listed companies acting as arms manufacturers not respecting the principles of the treaties and conventions listed below, or deriving a significant part of their revenues from the storage, transport or sale of such weapons, are excluded from the investment universe integrated into VIA AM’s fund management process.
- Ottawa Treaty on the Prohibition of Anti-personnel Mines
- Oslo Convention on the Prohibition of Cluster Munitions
- Paris Convention on the Prohibition of Chemical Weapons
- Convention on the Prohibition of Biological Weapons
- Treaty on the Non-Proliferation of Nuclear Weapons
VIA AM also complies with any mandatory investment restrictions imposed by the United Nations, the European Union or the United States on controversial countries.
Alpha: measure of performance on a risk-adjusted basis. Alpha, often considered the active return on an investment, gauges the performance of an investment against a market index used as a benchmark, since they are often considered to represent the market’s movement as a whole. The excess returns of a fund relative to the return of a benchmark index is the fund’s alpha.
Asset Class: group of securities that exhibit similar characteristics, behave similarly in the marketplace, and are subject to the same laws and regulations. The three main asset classes are equities (stocks), fixed-income (bonds) and cash equivalents (money market instruments).
Benchmark: benchmark is a standard against which the performance of a security, mutual fund or investment manager can be measured. Generally, broad market and market-segment stock and bond indexes are used for this purpose.
Beta: measure of the volatility, or systematic risk, of a security or a portfolio in comparison to the market as a whole. Beta is used in the capital asset pricing model (CAPM), a model that calculates the expected return of an asset based on its beta and expected market returns.
Maximum Drawdown: the maximum loss from a peak to a trough of a portfolio, before a new peak is attained. Maximum Drawdown (MDD) is an indicator of downside risk over a specified time period
Net Asset Value (NAV): A mutual fund’s price per share or exchange-traded fund’s (ETF) per-share value. In both cases, the per-share dollar amount of the fund is calculated by dividing the total value of all the securities in its portfolio, less any liabilities, by the number of fund shares outstanding.
Recovery Period: Time for an investment fund to recover from its maximum drawdown loss
Share Class: specified type of security such as common stock or mutual fund units. Companies that have more than one class of common stock usually identify a given class with alphabetic markers, such as “Class A” shares and “Class B” shares. Different share classes within the same entity typically confer different rights on their owners.
Sharpe Ratio: statistical measure for calculating risk-adjusted return, and this ratio has become the industry standard for such calculations. It was developed by Nobel laureate William F. Sharpe. The Sharpe ratio is the average return earned in excess of the risk-free rate per unit of volatility or total risk.
Tracking Error: divergence between the price behaviour of a position or a portfolio and the price behaviour of a benchmark. This is often in the context of a hedge or mutual fund that did not work as effectively as intended, creating an unexpected profit or loss instead.
Volatility: statistical measure of the dispersion of returns for a given security or market index. Volatility can either be measured by using the standard deviation or variance between returns from that same security or market index. Commonly, the higher the volatility, the riskier the security.