Our commitments

COMPENSATION POLICY

Compensation policy 2020 
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COMMITMENTS WITH RESPECT TO MIFID

The European markets in financial instruments directive (MiFID) took effect on November 1, 2007. It is a legislative and regulatory system that aims to :

  • harmonize the rules that apply to various investment service providers;
  • promote competition between order execution exchanges ;
  • offer greater protection for investors.

Ostrum Asset Management complies with MiFID requirements:

Order execution policy

The order execution policy for Ostrum Asset Management presents the overall organization of the company and the basic principles applied concerning in particular:

  • selection of intermediaries and counterparties ;
  • control and revision mechanisms used to obtain the best possible result for clients.

 

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The policy on the choice of intermediaries/counter parties and order execution

Prevention of conflicts of interest

A conflict of interest is a situation in which the management company in engaged in business activities which may prejudice the interests of clients if an appropriate organization is not implemented.
For Ostrum Asset Management, identifying, preventing and managing risk of conflicts of interest is achieved through the implementation of a specific organization as described in the document below.

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Summary of the policy for detecting, preventing and managing conflicts of interest

Information for clients and potential for clients concerning fees, commissions and other benefits

The General Regulations of the Autorité des Marchés Financiers (French Finance Markets Authority) set out the rules regarding fees, commissions and other benefits ("Inducements") which may be paid or received by fund managers (such as Ostrum Asset Management) in their capacity as investment service providers, in relation to the investment services they provide.
"Inducements" are amounts which may be paid indirectly by clients for services supplied to them by an investment service provider.
For your information, Ostrum Asset Management may:

  • receive Inducements from third parties :
    for selling third party collective investment schemes to its clients, or in relation to commission sharing agreement (for investment decision making aid services and order execution services).
  • pay Inducements to third parties:
    if the third party sells Ostrum Asset Management’s collective investment schemes to its clients,
    if a third party introduces clients to it,
    if a third party provides advice or assistance to it.

These Inducements may be a fixed sum or a percentage of the remuneration received by Ostrum Asset Management or the third party.
Further information will be supplied on request to clients and potential clients.

COMMITMENTS WITH REGARD TO VOTING POLICY

In accordance with the French law on financial security, the AMF requires that every management company which lanages UCITS produce a document titled "Voting policy".
This document formally sets out the principles which guide the management company in exercising voting rights pertaining to the shares held by the UCITS under its management.
Reporting on the actual exercise of voting rights provides information on the exercise of voting rights pertaining to securities included in the UCITS managed by Ostrum Asset Management, and reports the conditions under which Ostrum Asset Management exercised these voting rights.

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Voting policy

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Report voting rights

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Engagement report

ANTI-CORRUPTION POLICY

Corruption constitutes an act of fraud that is contrary to ethical standards and subject to severe criminal and administrative sanctions. Violations of anti-corruption regulations are serious and may cause Ostrum AM reputational damage.  Ostrum AM is committed in conducting its business with integrity so as to protect itself against all forms of influence peddling and corruption, which includes the giving or acceptance of bribes in commercial dealings and the corruption of public officials.

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Anti-corruption Policy February 2019

COMPLAINTS MANAGEMENT POLICY

General point and principles

Ostrum Asset Management has set up a complaint management system aimed at effectively, transparently and uniformly processing complaints from its customers, in accordance with applicable regulations.
Access to the Complaint Department is free of charge and customers can file their complaint according to the case (i) in French or (ii) in the or one of the official languages of the member state in which the UCITS is marketed or in which the service is provided.

Definition of a complaint

A complaint is a declaration that reveals the discontent of the customer towards the professional.
A request for information, an opinion, clarification or service is not a complaint.
Requests and complaints can in particular concern the portfolio management and performance, rate aspects or the legal documentation or any element concerning the service provided.

Processing complaints at Ostrum Asset Management

The complaint can be filed by mail, telephone or e-mail, or with the customer's usual contact. Claims filed by mail are sent to: Ostrum Asset Management – Service clients, 43, avenue Pierre-Mendès-France – 75013 Paris.
Claims made over the phone are recorded on the telephone sets of the customer assistance representatives.
Claims filed via e-mail must be sent according to the customer as follows:
For customers for whom the intermediary is the Caisse d’Epargne and Banque Populaire network distributors:

For all other customers:

Processing time

Ostrum Asset Management agrees to:

  • acknowledge receipt of all of the complaints that it receives within a maximum period of 10 days except when the response can be provided within this timeframe.
  • answer the complaints within a maximum of 2 months starting from the date they were received by Ostrum Asset Management
  • keep the customer informed in the event this timeframe cannot be met, of the unfolding of the processing for their complaint and the special circumstances that justify why this timeframe cannot be complied with.

Mediation via the Autorité des Marchés Financiers

The Autorité des Marchés Financiers (Financial Markets Authority) has a Mediator that can be contacted by any interested party, whether an individual or a legal entity, in the framework of a dispute of an individual nature falling within the scope of its competences, i.e. financial investments.
You can send a letter via the post to the following address:
Médiateur de l’AMF
Autorité des marchés financiers
17 place de la Bourse
75082 PARIS CEDEX 02
A form to request mediation is available online on the AMF's internet website (amf-france.org">www.amf-france.org).

Claims policy for refund of foreign withholding tax for mutual funds managed by Ostrum Asset Management/Natixis Investment Managers International

French and Luxembourg mutual funds may receive dividends net of withholding tax on foreign securities held. The withholding tax rate applied to dividends for French and Luxembourg mutual funds may in certain cases be different from the rate applicable to dividends paid to mutual funds in the security issuer’s state. Following the ruling from the European Court of Justice of May 10, 2012, this means that claims can be filed with the relevant authorities in certain European Union countries for a refund of the difference in rate.
The asset manager’s policy is to file these claims for the mutual funds it manages, when there is a reasonable likelihood of obtaining a refund at a reasonable cost and in a reasonable timeframe in the interests of and on behalf of investors, and materiality thresholds may be assessed with this in mind.
However, the effective and definitive amounts of refund and the timeframe can vary, so the mutual funds may incur external costs without benefiting from the refunds expected. The fees spent and refunds obtained as part of this policy will be outlined in the mutual funds’ annual reports.

In its wish to safeguard the interests of its long-term holders, Ostrum Asset Management has decided to introduce the swing pricing mechanism (protection of holders from fund dilution) based on the methodology recommended by the French Asset Management Association's (AFG) charter.
The introduction of swing pricing solely concerns funds that would benefit from this mechanism.
A shareholder who purchases or redeems an amount below the threshold is not guaranteed to be executed on an unswung NAV. Indeed, the swing pricing trigger is appreciated globally, taking into account all inflows/outflows, ie the net balance of subscriptions / redemptions of all shareholders.
Moreover, Ostrum Asset Management has the right to change at any time the swing pricing parameters, especially during a crisis situation.

Fund names
Ecureuil Investissements Ostrum Euro High Income Fund
Fructi Actions France Ostrum Euro Inflation
Fundy O Ostrum Euro Short Term Credit
Livret Bourse Investissements Ostrum Europe Smaller Companies Fund
Ostrum Actions Euro Micro Caps Ostrum European Convertible Bond
Ostrum Actions Europe Value Ostrum Global Aggregate
Ostrum Actions Européennes Ostrum Global Convertible Bond
Ostrum Actions Small & Mid Cap Euro Ostrum Global Emerging Bonds
Ostrum Actions Small & Mid Cap Ostrum Global Emerging Equity
Ostrum Asia Equity Fund Ostrum Global Inflation Fund
Ostrum Convertibles Euro Ostrum Global Subordinated Debt
Ostrum Convertibles Europe Ostrum Pacific Rim Equity Fund
Ostrum Credit Opportunities Ostrum Short Term Global High Income Fund
Ostrum Emerging Europe Equity Fund Ostrum Souverain Euro
Ostrum Euro ABS IG Ostrum Souverains Euro 1-3
Ostrum Euro ABS Opportunities Ostrum Souverains Euro 3-5
Ostrum Euro Aggregate Ostrum Souverains Euro 5-7
Ostrum Euro Bonds Opportunities 12 Months Ostrum Sustainable Euro Sovereign 1-3
Ostrum  Euro Credit Ostrum Ultra Short Term Bonds Plus

Un porteur qui souscrit ou rachète un montant inférieur au seuil de déclenchement n’a pas la garantie d’être exécuté sur une VL non swinguée. En effet, le franchissement d’un seuil de déclenchement s’apprécie globalement en prenant en compte l’ensemble de la collecte, à savoir le solde net des souscriptions/rachats de tous les porteurs.
D’autre part, Ostrum Asset Management a la possibilité de modifier à tout moment, notamment en cas de crise sur les marchés financiers, les paramètres du mécanisme du swing pricing.

A FAQ is available on our Ostrum AM’s website. The purpose of these FAQs is to respond to the various questions of holders regarding the working of the mechanism and its impacts. It applies to professional and non-professional clients within the meaning of the Markets in Financial Instruments Directive.

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Swing Pricing FAQ

This document can also be obtained on request from the Service Client department by e-mailing contact@ostrum.com or sending a letter to:
OSTRUM ASSET MANAGEMENT
Service Client
43, avenue Pierre-Mendès-France – 75013 PARIS – France

RESEARCH FUNDING

Ostrum Asset Management has decided to carry on its own income statement the cost of Equity and Fixed Income research for all the portfolios it manages: mandates, dedicated funds and open-end funds.

In our role as asset manager, we believe that research fees are an integral part of our investment management process, so these costs should be included in our expenses. In exceptional circumstances and when Ostrum Asset Management delegates financial management to another asset manager, the delegate company’s policy on research funding will apply. In some situations, portfolios may therefore bear the related costs.

The intermediation fees on Ostrum Asset Management's portfolios are exempt from research fees.

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