Regulatory information

Summary

1. Best selection & best execution policy
2. Conflicts of interests policy
3. 2023 report on intermediary fees
4. Customer complaints management
5. Sustainability
6. Compensation policy
7. Privacy notice

BEST selection & best execution policy

All investment services providers should comply with the obligation to act in the best interest of their clients when executing orders resulting from investment decisions related to portfolio management.

To this end, in its capacity as a fund management company, SYQUANT Capital is required to take all reasonable measures to select the intermediaries to which orders are transmitted for execution (brokers and financial counterparties) and whose execution policies guarantee the best possible result when executing orders sent on behalf of the funds it manages.

In accordance with the regulations, SYQUANT Capital has put in place an Execution Policy. This Execution Policy notably requires that the orders should be registered and treated in a timely and accurate manner, with regard to market conditions.

This Execution Policy is based on:
- a standardized process for the selection of brokers and financial counterparties;
- an analysis of the reporting provided by the brokers and financial counterparties.

SYQUANT Capital uses a multi-criteria approach to select intermediaries. The criteria applied are both quantitative and qualitative and depend on the markets for which the intermediaries provide services, in terms of geographical coverage (global, pan-European or local intermediaries) and financial instruments traded (intermediaries specialized in the equity, debt instruments, convertible or derivatives markets).

Every criterion is subject to an assessment, which is allocated a weighting coefficient, thereby enabling an overall rating to be attributed. The analysis criteria notably cover the financial stability of the counterparty, quality and cost of execution, financing costs and global quality of the operational setup.

The intermediaries’ ratings are updated every year. Based on this, the list of selected intermediaries is also reviewed annually.

The Selection and Rating policy for intermediaries is available upon request at: RCCI@syquant.com

Conflicts of interests policy

In accordance with the regulations, SYQUANT Capital has established a conflicts of interest policy and takes all reasonable measures to identify conflicts of interest that may arise in the course of providing its business activities.

As a result of its size and the nature of its activities, a mapping of conflicts of interest has been drawn up. This mapping identifies the circumstances that give rise or may give rise to a conflict of interest.

It makes it possible for SYQUANT Capital to identify and, if necessary, fairly manage any conflicts of interest that may arise in the course of carrying out its services, between its own interests and those of its clients or between the interests of a number of clients.

In cases where SYQUANT Capital would consider that the deployed measures are not sufficient to guaranty, with a reasonable certainty that the risk of prejudice for its clients can be avoided, the company would inform in writing the affected customers about the nature or the source of the conflict of interests in order for these clients to be able to take their decision knowingly.

Additional information on our Conflicts of Interest Policy can be obtained from the management company upon request by Email to: RCCI@syquant.com

2023 report on intermediary fees

In accordance with articles 321-122 and 319-18 of the RG AMF, where the management company has recourse to order execution and investment decision support services and the intermediary fees for the prior financial year exceeded EUR 500,000, it draws up a document entitled « Report on intermediary fees ».

Use of order execution and investment decision support services in 2023

In the context of transactions on listed shares, listed derivatives (futures & options) and corporate bonds done during the 2023 financial year and for the whole set of funds under management, SYQUANT Capital has used in certain cases external research services in order to compare its own analysis on certain opportunities. These services include but not exhaustively: financial analysis, economic research, specific analysis on certain segments and linking with other specialists. None of these services was engaged under any split commission agreement.

Breakdown of intermediary

Breakdown on intermediary fees paid on transactions listed above during year 2023 is as follows:
• Intermediary fees for investment decision support services represented 19.54% of the total.
• Orders’ execution fees represented 80.46% of the total of intermediary fees.

Percentage of fees paid back to third parties in 2023 under split commission agreements

In accordance with its investment policy and with the Best Selection policy, no split commission agreements is in place as at the end of the 2023 financial year. As such, from the total of intermediary fees paid during year 2023, the percentage of these fees paid back to third parties under the terms of such agreements, as mentioned in articles 321-121 and 319-18 of RG AMF is null.

Prevention and handling of conflicts of interests
The selection of service providers and their assessment is duly governed by the intermediary selection policy and the conflict-of-interest policy. These policies are available upon request by Email at RCCI@syquant.com.

CUSTOMER COMPLAINTS MANAGEMENT

SYQUANT Capital, in accordance with the regulation, has implemented and maintains an operational procedure to quickly and efficiently process complaints made by its clients.

Any complaint may be sent by :

• email RCCI@syquant.com ;
• regular mail at the following address:

SYQUANT Capital
Attn. RCCI
25 Avenue Kléber
75116 Paris

Syquant Capital will acknowledge receipt of the complaint within a maximum of ten working days from the date it was received, unless a response has been issued to the client in the intervening period. Except in duly justified exceptional circumstances, a response will be issued to the client within two months of sending the complaint.

In the event of an ongoing dispute, the client may contact the AMF at the following address:

Autorité des marchés financiers
Médiateur de l'AMF
17 Place de la Bourse
75082 PARIS CEDEX 02

The AMF mediation request form and the Mediation Charter are available on the AMF website:

- Mediation Charter : https://www.amf-france.org/en/amf-ombudsman/how-mediation-works/mediation-charter

- AMF mediation request form

Sustainability

The information regarding sustainbility at Syquant Capital are available on the sustainability page. 

COMPENSATION POLICY

In accordance with the UCITS Directive 2014/91/ EU of 23 July 2014, SYQUANT Capital has implemented a Remuneration Policy compatible with the sound and effective risk management applicable to categories of personnel whose professional activities have a material impact on the Risk profile of the UCITS it manages. Alongside several other criteria, the company’s decisions regarding compensation consider the integration of sustainability risks.

A summary of SYQUANT Capital’s Compensation Policy is available here. Upon request, a hard copy can be made available free of charge.

Privacy notice