O2 Capital AM
In accordance with Article 31 of Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012, O2 CAPITAL AM takes all reasonable measures to detect situations of conflicts of interest that may arise in the provision of investment services, ancillary services, or the management of AIFs.
Principles
When providing investment services, managing AIFs, or carrying out ancillary services, a conflict of interest situation generally arises when a decision or behavior by the manager, its employees, affiliated companies, or any other service provider or client with whom it has a professional relationship may harm the interests of unitholders.
Such a situation may be structural in nature due to the economic, financial, capital, or contractual relationships maintained by the manager or its employees with third parties, whether individuals or legal entities, with whom they have either a regular (e.g., affiliated companies) or occasional relationship.
In compliance with regulations, O2 CAPITAL AM has implemented a policy for the prevention and management of conflicts of interest.
Conflict of Interest Prevention Framework
O2 CAPITAL AM has developed a mapping system that identifies situations likely to give rise to conflicts of interest, along with the corresponding procedures.
A conflict of interest refers to a situation where it can reasonably be assumed that a person, either potentially or actually, loses the necessary impartiality required for decision-making or benefits from the situation at the expense of another party.
The conflict of interest prevention and management framework aims to identify such situations. These issues are also subject to specific internal procedures that must be strictly followed. Any failure to comply with a rule or internal procedure constitutes a non-compliance issue that must be rectified.
The main measures implemented by O2 CAPITAL AM to prevent conflicts of interest include:
Compliance with ethical charters (such as the ASPIM Code of Ethics, O2 CAPITAL AM’s internal regulations, etc.),
Job segregation and function separation designed to reduce conflict of interest risks,
A remuneration structure that prevents behaviors that could conflict with clients’ interests.
Practical Arrangements
O2 CAPITAL AM maintains and regularly updates a risk mapping system identifying potential threats to clients’ interests.
Additionally, the Compliance and Internal Control Department keeps an up-to-date register of conflicts of interest and the corresponding resolution methods.
When the risk of harming the client’s interests cannot be avoided despite existing procedures and preventive measures, O2 CAPITAL AM informs the client and works with them to determine the necessary actions.
Our Remuneration Policy is available to anyone upon request.
Principles
The integration of environmental, social, and governance criteria allows for the application of sustainable development principles to investment decisions.
The approach consists of systematically considering the three dimensions—environmental, social/societal, and governance (ESG)—in addition to standard financial criteria. Implementation methods may take multiple forms, including positive screening, exclusion, or a combination of both, and may, where appropriate, include dialogue with issuers.
ESG criteria include three dimensions:
According to Article L 533-22-1 of the French Monetary and Financial Code:
“Management companies shall provide subscribers of each collective investment scheme they manage with information on how social, environmental, and governance-related criteria are taken into account in their investment policy.”
O2 Capital AM, in compliance with applicable regulations, has implemented this policy, and the principles below outline the approach it has adopted regarding these criteria.
In accordance with the applicable regulations following the transposition of the MiFID Directive, and in the best interests of its clients and the investment vehicles it manages, O2 CAPITAL AM has established a policy for selecting financial intermediaries and counterparties with whom financial instrument orders are placed for execution.
DERIVATIVE FINANCIAL INSTRUMENTS
To hedge exclusively against interest rate risk, certain AIFs under management may hold derivative financial instruments. O2 CAPITAL AM ensures that the best possible conditions are obtained for its shareholders and unitholders.
POLICY MONITORING AND ANNUAL REVIEW
O2 CAPITAL AM will review its policy for selecting intermediaries annually and whenever a significant change occurs that may affect its ability to continue achieving the best possible outcome for the investment vehicles under management.
O2 CAPITAL AM is committed to satisfying its clients at all times, particularly in situations that could affect the quality of the relationship or undermine trust between the client and O2 CAPITAL AM.
If you are dissatisfied with our services, we invite you to follow the procedure described below.
This procedure is free of charge; no fees will be incurred for the processing of your complaint.
HOW TO SUBMIT A COMPLAINT TO O2 CAPITAL AM?
If you have a dispute, you can submit a complaint as follows:
Timeframe for handling complaints
Upon receipt of your complaint, we undertake to process it within the following timeframes:
If specific circumstances prevent us from meeting these deadlines, we will inform you accordingly.
Contact details of the mediator
If the response provided does not satisfy you, you may refer the matter free of charge to the AMF Mediator:
Please note that choosing to contact the AMF Mediator for disputes within its competence is final.
O2 CAPITAL AM’s complaint handling policy details the following procedures:
For further information, please contact:
O2 CAPITAL AM – 20 rue Royale, 75008 Paris
By email at: contact@o2am.com
The information provided on the O2 CAPITAL AM website is partial. Despite our best efforts, technical failures may occur. These may be due to limited access, incorrect data retrieval, or interventions by third parties.
O2 CAPITAL AM disclaims any liability for any damages that may result from such failures and commits to implementing corrective procedures as soon as the issue is identified.
The O2 CAPITAL AM website is a protected work under intellectual property law. This also applies to the data featured on the website, including trademarks, logos, graphics, photographs, etc.
The information on this website is intended strictly for personal use by visitors and may not be reproduced or shared with third parties, whether for commercial or non-commercial purposes.
Any unauthorized reproduction or, more generally, any unauthorized use of the website and its disclosed information will engage the user’s liability and may lead to legal action, particularly for infringement.
Communication pursuant to EU Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector, also known as the “Disclosure Regulation” or “SFDR”:
The SFDR regulation requires financial market participants to publish information regarding their policies on the integration of sustainability risks in their investment decision-making processes.
“Sustainability risk” is defined as the risk of an environmental, social, or governance event or condition which, if it occurs, could have a significant actual or potential negative impact on the value of the investment.
O2 Capital AM rigorously selects the assets in its funds based on both financial and non-financial criteria. For this reason, O2 Capital AM has developed an investment selection and management methodology integrating Environmental, Social, and Governance (ESG) criteria. This methodology will soon incorporate sustainability risks as well as the adverse impacts of our investments on sustainability factors.
O2 Capital AM has also begun evaluating criteria that would allow the integration of sustainability risks into its remuneration policy; these are not yet taken into account.
This communication will be updated as our approach to integrating ESG criteria into our investment, management, and remuneration policies evolves.
O2 Capital AM