- ESG Policy
- COMPENSATION POLICY
- COMMITMENTS WITH RESPECT TO MIFID
- PREVENTION OF CONFLICTS OF INTEREST
- INFORMATION FOR CLIENTS AND POTENTIAL FOR CLIENTS CONCERNING FEES, COMMISSIONS AND OTHER BENEFITS
- COMMITMENTS WITH REGARD TO VOTING POLICY
- ANTI-CORRUPTION POLICY
- COMPLAINTS MANAGEMENT POLICY
- PROTECTING HOLDERS FROM FUND DILUTION (SWING PRICING)
- Financing research
- REPORT ON INTERMEDIATION COSTS
- ANNUAL REPORT ON THE TOP FIVE VENUES
- POLICY ON MANAGEMENT OF SUSTAINABILITY RISKS AND ADVERSE IMPACTS
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.
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.
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 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.
Voting policy 2021
2021 Report on exercice of voting rights
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
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 (www.amf-france.org).
Complaints Management Policy
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.
|OSTRUM SHORT TERM GLOBAL HIGH INCOME FUND||OSTRUM GLOBAL INFLATION FUND|
OSTRUM CREDIT OPPORTUNITIES
|OSTRUM SOUVERAINS EURO|
|OSTRUM EURO ABS IG||OSTRUM SRI EURO BONDS 1-3|
|OSTRUM EURO ABS OPPORTUNITIES||OSTRUM SOUVERAINS EURO 5-7|
|OSTRUM SRI EURO AGGREGATE||OSTRUM EURO SOVEREIGN 1-3|
|OSTRUM EURO BONDS OPPORTUNITIES 12 MONTHS||OSTRUM CREDIT ULTRA SHORT PLUS|
|OSTRUM EURO CREDIT||OSTRUM MULTI ASSET GLOBAL INCOME|
|OSTRUM EURO HIGH INCOME FUND||OSTRUM SRI CREDIT 12M|
|OSTRUM EURO INFLATION||OSTRUM SRI CREDIT EURO|
|OSTRUM EURO SHORT TERM CREDIT||OSTRUM ISR OBLI CROSSOVER|
|FUNDY O'||OSTRUM SRI EURO BONDS 3-5|
|OSTRUM GLOBAL AGGREGATE||OSTRUM GLOBAL SUBORDINATED DEBT|
|OSTRUM GLOBAL EMERGING BONDS|
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.
Swing Pricing FAQ
This document can also be obtained on request from the Service Client department by e-mailing email@example.com or sending a letter to:
OSTRUM ASSET MANAGEMENT
43, avenue Pierre-Mendès-France – 75013 PARIS – France
Policy on financing research
Policy on financing research
REPORT ON INTERMEDIATION COSTS
Report on intermediation costs 2021
ANNUAL REPORT ON THE TOP FIVE VENUES
Download the Annual report on the top five venues in 2021
POLICY ON MANAGEMENT OF SUSTAINABILITY RISKS AND ADVERSE IMPACTS