Regulatory framework

Xerys Invest’s conflict of interest policy complies with the general principles laid down by the Markets in Financial Instruments Directive (MiFID) and incorporated into Articles 313-18 to 313-22 of the AMF’s General Regulations.

A conflict of interest is a situation in which, during the course of business, the interests of Xerys Invest and/or its employees or clients are in direct or indirect competition. Taking into account its size, organisation and activities, Xerys Invest has mapped potential conflicts of interest and put measures in place to ensure optimal identification and management of conflict of interest situations.

Should a conflict of interest prove impossible to manage, Xerys Invest will inform the client immediately before acting on his or her behalf.

XERYS Invest has set up and maintains an operating procedure to quickly and efficiently process clients’ claims. Claims can be sent by post to Xerys Invest, 73 boulevard Haussmann 75008 Paris, France, or by email to contact@xerys.com.

The management company acknowledges receipt of the claim within ten working days unless the client has already received an answer within this time frame. Except under special circumstances that can be duly substantiated, the management company will provide the client with an answer within the two months following the receipt of the claim. In the event of an unresolved claim, the client may contact a mediator, such as the AMF Ombudsman, at Autorité des marchés financiers, 17 place de la Bourse, 75082 Paris Cedex 02, France.

The AMF’s mediation request form and mediation charter are available on its website http://www.amf-france.org. 

The investment policies of the funds managed by Xerys Invest do not simultaneously take environmental, social and corporate governance criteria into account.

Xerys Invest only operates on the unlisted market. The Company therefore has no need to maintain an order execution or financial intermediary selection policy.

In accordance with Articles 314-100 to 314-102 of the AMF’s General Regulations, Xerys Invest has prepared a voting rights policy that sets out the conditions under which the Company intends to exercise the voting rights attached to shares held by the mutual funds it manages.

Xerys Invest only operates on the unlisted market. The Company therefore has no need to implement a voting rights policy.

Where applicable, the management company informs users about its “Report on Intermediation Fees”.

In accordance with the provisions of Article 314-82 of the AMF’s General Regulations, Xerys Invest is not required to prepare a “Report on Intermediation Fees”.