CLARESCO Finance
Public limited company with capital of €2,039,484 - RCS PARIS 420 307 167
Portfolio management company - AMF approval GP-98042 of 10/16/1998
6 Rue Lamennais - 75008 Paris
Such. 01.53.45.38.00 - www.claresco.fr
Site manager: Edouard Ferri
CLARESCO Finance
Public limited company with capital of €2,039,484 - RCS PARIS 420 307 167
Portfolio management company - AMF approval GP-98042 of 10/16/1998
6 Rue Lamennais - 75008 Paris
Such. 01.53.45.38.00 - www.claresco.fr
Site manager: Edouard Ferri
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TRANSPARENCY CODE
SHAREHOLDER ENGAGEMENT POLICY
POLICY FOR TAKING ACCOUNT OF SUSTAINABILITY RISKS
SELECTION OF INTERMEDIARIES
In accordance with article 314-75-1 of the RGAMF, CLARESCO has put in place a policy for the selection and evaluation of financial intermediaries which enables it to best protect the interests of its clients. The selection of financial intermediaries takes into account on the one hand their specialties according to the types of financial instruments and the coverage of research in the defined geographical area, and on the other hand qualitative criteria. The choice of a new intermediary must be the subject of written justification and must be approved by the Head of Compliance and Internal Control (RCCI).
The selection and evaluation policy for intermediaries is available on request from CLARESCO's premises.
GESTION UNDER MANDAT – BEST SELECTION REPORT CALLED “RTS 28” FOR THE 2021 FINANCIAL YEAR
The regulations in force require the establishment and publication once a year, for each category of financial instruments, of the ranking of the top five execution platforms (in terms of trading volume) on which orders have been executed. The information must be provided for retail (non-professional) clients and professional clients.
CONFLICT OF INTEREST MANAGEMENT POLICY
In accordance with Article L533-10 of the Monetary and Financial Code, CLARESCO must take all reasonable measures with the aim of preventing any situation of "conflicts of interest" from harming the interests of its customers. CLARESCO has implemented a procedure aimed at identifying any potential conflicts of interest via a map listing them, updated as necessary, detailing the measures taken to prevent such situations where applicable. If these measures were not sufficient to guarantee with reasonable certainty that the risk of harming the interests of customers would be avoided, CLARESCO should inform them in detail, before acting on their behalf, of the general nature or source of these conflicts of interest.
The conflict of interest prevention and management policy is available on request from CLARESCO's premises.
ESG EXCLUSION POLICY
CUSTOMER COMPLAINTS
INFORMATION ON SOCIAL, ENVIRONMENTAL AND GOVERNANCE (ESG) CRITERIA - "SFDR" REGULATION
According to Article L.533-22-1 of the Monetary and Financial Code, the management company must henceforth inform investors of the way in which social, environmental and governance (ESG) criteria are taken into account in the management process. implemented by CLARESCO FINANCE.
At this stage, the company does not formalize the simultaneous and explicit consideration (via a rating) of ESG criteria in the management process. However, the investment process on which the management of the funds is based gives a large place to the study and the will to respect these criteria. The management style is based on a rigorous selection of companies through in-depth financial analysis. Fundamental criteria such as the degree of transparency of managers and governance, the financial structure, social policy and human resources as well as the attitude towards environmental constraints are an integral part of the various elements studied. Although these criteria are not legally obligatory, the violation of these principles could be a factor prohibiting or limiting the investment or likely to lead to a divestment of the company.
Regulation (EU) 2019/2088 on sustainability reporting in the financial services sector (known as the "Disclosure Regulation" / "SFDR")
We inform you of the changes, as of March 10, 2021 (date of entry into force of the SFDR Regulation):
REMUNERATION POLICY
The compensation policy for Claresco Finance employees provides for a fixed level of compensation in line with their level of seniority, expertise and professional experience in the activity, to allow variable compensation not to be granted, if necessary. The fixed remuneration is defined by the Management at the time of hiring. The variable part of the remuneration is intended to supplement the fixed part, it is determined according to the objectives set at the beginning of the year and in particular the performance achieved by the employee. These objectives relate to global quantitative elements, such as the results, the financial situation of the Company, to quantitative elements specific to each profession and to each position and to qualitative elements, such as the personal commitment of the employee, particularly in the interest of the client, of Claresco Finance, compliance with professional ethics rules and internal risk management and monitoring procedures in place within the Company.
You can obtain additional information upon simple written request to Claresco Finance.
Integration of sustainability risk (art. 5 “SFDR” Regulation)
The European Union published sustainability disclosure legislation in the financial services sector in December 2019 which comes into force on March 10, 2021. This legislation requires financial market participants and financial advisers to include in their remuneration policy information on how these policies are compatible with the integration of “sustainability risks”. At this stage, Claresco Finance's remuneration policy does not include sustainability risks. On the other hand, a reflection is in progress on the nature of the criteria to be taken into account to integrate these risks. The defined sustainability criteria will be incorporated into the employee compensation policy for the next annual target setting campaign.