Disclosures

Smart Lenders Asset Management – Regulatory Information

March 2020

I. MONITORING POLICY AND CUSTOMER COMPLAINT REPORTING– CONSUMER MEDIATION

You can send your complaint to the Investor Relations Department, which will try to find a solution.

By e-mail to the address below, specifying in your message’s subject line that this is a claim: info@smartlenders-am.com

By post to the following address:

Smart Lenders Asset Management
109 Haussmann Boulevard
75008 Paris

By phone at +33 (0) 1 40 06 29 70

CLAIMS’ TREATMENT

We guarantee you a free, fast, transparent and as efficient as possible processing of your claim to find a solution that brings you satisfaction.

Smart Lenders Asset Management commits to meet the following processing deadlines:

  • A maximum of 10 working days from the receipt of your claim to acknowledge receipt, unless the answer itself is provided to you within this period;
  • A maximum of 2 months between the reception date of your claim and the date of dispatch of the reply that is given to you, unless the occurrence of special circumstances that we undertake to justify to you.

Customers holding units of a FAI marketed in a Member State of the European Union may send us their complaint in English or French and will receive a reply in that same language.

REFERRAL TO THE OMBUDSMAN OF THE FINANCIAL MARKETS AUTHORITY (AMF)

Smart Lenders Asset Management is a portfolio management company authorised by the Autorité des Marchés Financiers (AMF). The AMF has a mediation service available to you at any time, provided that you do not intend to initiate legal proceedings against us or that such an action is already taken.

The contact information for the AMF mediator is the following:

Autorité des Marchés Financiers
Médiateur de l’AMF
17, place de la Bourse
75082 PARIS CEDEX 02

The Request to Mediate form and the Mediation Charter are available at http://www.amf france.org.

II. POLICY ON THE DETECTION, PREVENTION AND CONFLICTS OF INTEREST MANAGEMENT

In accordance with the regulations, Smart Lenders Asset Management has a conflict of interest management policy and takes all measures to detect conflict of interest situations arising during the investment services provision, related services or the CIF management. The conflicts of interest identification has enabled the conflict of interest mapping development. This mapping identifies situations that give or are likely to give rise to a conflict of interest.

It permits to detect and, if necessary, manage cases of conflicts of interest which may arise, in the case of one of the provision performance, between its own interests and those of its clients or between the interests of several clients.

These include identification and control:

  • Separation of activities that could lead to potential conflicts (for example advisory and investment activities),
  • The circulation of confidential or inside information within the management company,
  • The participation of a collaborator in one or more investment services offered by the management company,
  • Company mandates or any other activities carried out by the management company employees on a private basis or in the context of their professional activities,
  • Commissions paid or received in respect of services or activities carried out by or in favour of the management company,
  • The way employees are rewarded in the context of the distribution of financial products,
  • Any benefits or gifts received by the management company employees in the context of their professional activity,
  • Conflict of interest risks in the selection procedure for intermediaries and service providers,
  • The procedure establishment for personal transactions.
  • Equal treatment of investors

The implementation of the conflict of interest management system is the responsibility of each management company’s employee. This system is subject to permanent control by RCCI and the Executive Management’s member.

For more detailed information on Smart Lenders Asset Management’s conflict of interest policy, please email info@smartlenders-am.com.

III. REPORT ON INTERMEDIATION COSTS

The total amount of intermediation costs was less than €500,000 in the previous exercise (2019).

The management company is therefore not required to prepare a report on the intermediation costs for the 2019 exercise.

IV. APPLICABLE POLICY ON THE EXERCISE VOTING RIGHTS

Under the FIA’s investment policy managed by Smart Lenders Asset Management, the management company managers do not invest in corporate securities or shares.

In fact, there is currently no applicable voting rights policy.

V. POLICY FOR SELECTION AND EVALUATION OF SERVICE PROVIDERS

In accordance with current regulations, Smart Lenders Asset Management has defined, as part of its duty to act in the best interests of its customers and the vehicles it manages, a counterparty selection policy with which it will place its orders for execution.

Smart Lenders Asset Management manages vehicles made up exclusively of unlisted assets, with a liquidity source.

Smart Lenders Asset Management uses only forward financial instruments in foreign exchange hedges.

In this context, Smart Lenders Asset Management has selected the depositary of its funds as its counterparty.

The selection of this counterparty was based on the following criteria:

  • Capacity and permissions required to deliver services;
  • Adequate resources to successfully deliver services;
  • Level of service, reporting and transparency to adequately control service performance;
  • Adequate financial and insurance cover;
  • Ability to effectively manage conflicts of interest;
  • Implementation of procedures to protect confidential information;
  • Implementation of an appropriate business continuity plan;
  • Fair pricing policy;
  • Contractual arrangements to ensure compliance with AIFMD requirements.

Documents collected during the selection and evaluation periods of service providers are archived in electronic format.

The assessment of contractors is done on an ongoing basis.

VI. REMUNERATION POLICY

Smart Lenders Asset Management has a compensation policy for its collaborators that aims to discourage excessive risk taking, to limit risks for the company and to ensure consistency between the behaviour of collaborators and the company long-term objectives.

Smart Lenders Asset Management has opted for the proportionality principle of the remuneration policy.

“Identified staff” within the meaning of the regulations has been defined. Smart Lenders Asset Management shall ensure that the fixed part of the employees’ remuneration involved in the FIA management activity is large enough to remunerate the professional with regard to the obligations related to his position, the level of competence required, the responsibility exercised, and the experience acquired. There is no guaranteed bonus. The annual variable remuneration per employee is limited to a maximum of 30% of the annual fixed remuneration or 100,000 euros. The individual variable remuneration of collaborators working on FIA funds managed by Smart Lenders Asset Management is determined on a discretionary basis by the

General Management, and depends on the following two criteria:

  • an objective criterion, according to Smart Lenders Asset Management’s turnover results for the year and the medium term,
  • a qualitative criterion, depending on the employee’s participation in the development of Smart Lenders Asset Management in the medium and long term.

Given the size of the company, the size of the FIA currently managed by Smart Lenders Asset Management, its internal organisation, the nature of its activities, the potential risks identified, the fact that the managed AIF has specific investment constraints that limit reckless risk-taking, the fact that all investment decisions are taken collegially, and that the management strategies implemented are not complex, Smart Lenders Asset Management uses the possibility provided by the Autorité des Marchés Financiers to adopt a proportional approach. Consequently, it was decided not to apply for all of its staff the requirements relating to the variable remuneration payment procedure envisaged by the Financial Markets Authority’s Position and not to have any compensation committee.