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.
POLICY ON ENVIRONMENTAL, SOCIAL, AND GOVERNANCE (ESG) CRITERIA
Principles
The consideration of environmental, social, and governance (ESG) criteria is linked to the concept of Socially Responsible Investment (SRI). This approach involves applying sustainable development principles to investment decisions.
The methodology consists of systematically taking into account the three dimensions—environment, social/societal, and governance (ESG)—in addition to traditional financial criteria. The implementation methods can take multiple forms, based on positive selection, exclusion, or both, potentially including engagement with issuers.
ESG criteria encompass three key dimensions:
Article L 533-22-1 of the French Monetary and Financial Code states that:
“Management companies must provide subscribers of each collective investment scheme they manage with information on how social, environmental, and governance quality criteria are taken into account in their investment policies.”
In compliance with applicable regulations, O2 CAPITAL AM has implemented this policy, whose principles below outline the approach it has adopted regarding these criteria.
BEST SELECTION POLICY
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 ensuring customer satisfaction in all circumstances, particularly when a difficulty arises that may affect the quality of the relationship or undermine the trust between the client and O2 CAPITAL AM.
Customer complaints are monitored and may be subject to mediation, a process that O2 CAPITAL AM commits to respecting.
HOW TO FILE A COMPLAINT WITH O2 CAPITAL AM?
If you have a dispute, you can submit a complaint as follows:
O2 CAPITAL AM’s complaint handling policy details the following procedures:
INVESTOR INFORMATION
For further information, please contact:
O2 CAPITAL AM – 20 rue Royale, 75008 Paris
By email at: contact@o2am.com
INFORMATION ON WEBSITE CONTENT
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.
REPRODUCTION RIGHTS FOR INFORMATION
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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.
O2 Capital AM