Statutory Documents

ESG POLICY

COMPENSATION POLICY

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.

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.

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 manages 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.

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.

COMPLAINTS MANAGEMENT POLICY

Ostrum Asset Management has set up an operational procedure for the quick and efficient handling of complaints from its clients.

Any claim can be sent:

• to your usual contact person by any means at your convenience (telephone, mail or e-mail);
• by letter to the Client Experience team – Ostrum AM, 43, avenue Pierre Mendès-France, 75013 Paris;
• by email at [email protected].

Ostrum AM will acknowledge receipt of the complaint within a maximum of ten working days from the date of sending the claim, unless the answer itself is provided to the customer within that period. Unless there are duly justified special circumstances, a response will be provided to you within two months of sending the claim.

Mediation of the regulation authority

You can contact the AMF (Autorité des Marchés Financiers) mediator. The contact details of the mediator are as follows:
Autorité des marchés financiers
Mediator of the AMF
17 place de la Bourse
75082 PARIS CEDEX 02
The application form for mediation with the AMF and the mediation charter are available at http://www.amf-france.org.

SWING PRICING

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.

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.

This document can also be obtained on request from the Service Client department by e-mailing [email protected] or sending a letter to:
OSTRUM ASSET MANAGEMENT
Service Client
43, avenue Pierre-Mendès-France – 75013 PARIS – France

Policy on financing research

REPORT ON INTERMEDIATION COSTS

ANNUAL REPORT ON THE TOP FIVE VENUES

Article 29 French Energy-Climate Law, TCFD and Sustainability Risks Report

Policy on management of sustainability risks and adverse impacts