1. Conflicts of interest policy
Edmond de Rothschild Asset Management (France)’s duty has never wavered: always put the client’s interests above all other considerations. This is why we strive to detect and prevent any conflict of interest that might occur when offering you investment services and any related services.
It is with this in mind that Edmond de Rothschild Asset Management (France) has established an organisation, dedicated procedures and measures that enable it to identify and manage such conflicts, should they arise, as well as possible.
Edmond de Rothschild Asset Management (France) naturally undertakes to inform the Client of the general nature or source of these conflict(s) of interest, should such a situation(s) be identified.
The Client may, if desired, obtain on request to his/her Client Advisor, further information on the Conflicts of Interest Policy.
2. Best Execution Policy - Best Selection Policy
The Markets in Financial Instruments Directive (MiFID 2004/39/EC) requires as of November 1, 2007 that, during the execution of an order concerning a financial instrument on behalf of a client, the investment services provider shall take all reasonable steps to obtain for its client the best execution of the order, in particular by establishing a Best Order Execution Policy and a Best Selection Policy regarding the choice of intermediaries (collectively called The Policy). The Policy is reviewed by Edmond de Rothschild Asset Management (France) as and when necessary and at least once per year.
Details of our Best Selection and Best Execution policies
3. Top five broker report for discretionary management mandates
Current regulation requires that the top five execution platforms (in terms of trading volume) on which orders have been executed be classified and published once a year for each category of financial instruments. Information must be provided for retail (non-professional) and professional clients.
Top five broker report for discretionary management mandates
4. Risks Mapping
As required by the regulation, Edmond de Rothschild Asset Management (France) has established a general description of the nature and risks of financial instruments. This explains the particular characteristics of the type of financial instrument concerned and the risks associated with it, in order to facilitate investment decision-making in full possession of the facts.
Risk chart by type of financial instrument
5. Report on intermediation fees
According to the regulation, Edmond de Rothschild Asset Management (France) has established the document called
Report on intermediation fees - Edmond de Rothschild Asset Management (France)
6. Policy for selecting and assessing the entities that provide investment decision aid services
Edmond de Rothschild Asset Management (France) implemented a policy for selecting and assessing the entities that provide Investment Decision Aid Services and Order Execution Services.
7. Remuneration policy
Edmond de Rothschild Asset Management (France) has implemented a remuneration policy in compliance with the provisions of European Directives 2011/61/UE (“AIFM Directive”) and 2014/91/UE ("UCITS V Directive").
Remuneration policy - Edmond de Rothschild Asset Management (France)
8. Withholding tax claim procedure
In the past, French funds have received foreign equities’ dividends on which the issuer’s local country may have levied a withholding tax. Sometimes, the withholding tax rate applied to dividends received by French funds may be different from the one applied to dividends paid to funds for which the country is the same as the one of the security issuer.
On May 10th, 2012, the Cour de justice de l’Union Européenne (CJUE) gave a final judgement by condemning withholding tax of such a discriminated nature. This decision allows funds to introduce actions for restitution of a part of the amounts of past withholding tax towards relevant tax authorities.
Edmond de Rothschild Asset Management (France) established a preliminary analysis so as to identify claims with best chance of success, based on objective criteria (materiality threshold). Based on such criteria, the portfolio management company decided, on behalf of portfolios, in the interest of the shareholders, to apply for claims between 2009 and 2014, towards related tax authorities (of which Germany, Denmark, Spain, Finland, Italy, the Netherlands, Poland, Sweden).
Please note that this claim policy may have some uncertainties in terms of effective and final amounts as well as delay that may last several years. Moreover, regarding amounts at stake at related countries’ level, some countries may not apply with diligence the CJUE final judgement or may try to introduce additional terms and conditions. External costs may be borne without benefiting from expected reimbursements.
Should you wish further information, please contact us.
In the event of a problem or disagreement regarding any investment service provided by Edmond de Rothschild Asset Management, you can contact by every possible means either your internal contact or mail to Client Service of Edmond de Rothschild Asset Management (France), 47 rue du faubourg Saint-Honoré - 75401 PARIS Cedex 08.
You will receive, after the reception of your complaint by our services:
- an acknowledgment of receipt within ten working days maximum after the complaint reception, unless a response to your complaint is provided before this deadline;
- a response within two months maximum.
However, if the response does not satisfy you, or if your problem persists, you may also contact the ombudsman of the Autorité des marchés financiers by mailing to the following address: Autorité des marchés financiers - Médiateur de l'AMF - 17 place de la Bourse - 75082 PARIS Cedex 02. For more information:
10. Personal data processing
The personal information collected as part of an investment service shall be processed automatically by Edmond de Rothschild Asset Management (France), data controller, whose contact details are Client Services 47 rue du Faubourg Saint-Honoré - 75008 Paris (‘firstname.lastname@example.org’) and whose Data Protection Officer can be reached at DPO Edmond de Rothschild Asset Management (France), 47, rue du Faubourg Saint-Honoré - 75008 Paris (DPO@edr.com).
This processing is necessary for the performance of the investment service and compliance with the legal and regulatory obligations of Edmond de Rothschild Asset Management (France).
The collected information is mandatory for the performance of the investment service. If this information is not provided, the entire investment service shall be terminated.
The recipient of this data is Edmond de Rothschild Asset Management (France). Data collected may be transferred to other entities in the Edmond de Rothschild group or to third-party data processors or to partners located in France, in European Union member states, or in Switzerland (noting that the European Commission recognised via decision no. 2000/518/EC of 26 July 2000 that this third country offers adequate protection) for the purposes of performing the investment service as well as the execution of the Edmond de Rothschild Asset Management (France) policy on preventing and managing conflicts of interest or to satisfy its legal and regulatory obligations, provided that such disclosure is restricted to a need-to-know basis.
Data will be kept in accordance with the various applicable retention periods, i.e. for five years after the business relationship ends should no shorter or longer period be specifically stipulated.
The Data Subject shall have the right to ask the controller for access to and correction or erasure of personal data, a limitation of the processing of such personal data, as well as the right to object to processing and the right to portability of said data.
Exercising the right to object to the processing of said data shall mean that the investment service shall be terminated.
The Data Subject shall also have the right to define the instructions for what happens to the data after their death.
If the Customer is dissatisfied with the processing of their personal data, the Customer shall have the possibility to submit a complaint to the French data protection registrar, the Commission Nationale de l’Informatique et des Libertés (CNIL), at the following address: 3 Place de Fontenoy, TSA 80715 - 75334 Paris Cedex 07 – 01 53 73 22 22.
Charter of personal data protection