GOAL ABSOLUTE PERFORMANCE

FUNDS WITH DIFFERENTIATED RISK PROFILES

GOAL ABSOLUTE PERFORMANCE

GOAL ABSOLUTE PERFORMANCE

Regulatory information

Summary

  1. Best selection & best execution policy
  2. Conflicts of interests policy
  3. Exercice of voting rights police
  4. 2020 report on intermediary fees
  5. Customer complaints management
  6. ESG Policy
  7. Compensation policy
  8. 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

 

Exercice of Voting rights policy

In accordance with the regulation, SYQUANT Capital has established and maintains active a process to govern its voting policy.

Principles

SYQUANT Capital’s voting policy is in line with its objectives of portfolio value preservation and enhancement and mitigation of risks through the incorporation of sustainability factors amongst other factors. Our voting policy aims to take an active ownership approach. Our policy is to participate in most of the shareholder meetings in which our funds are eligible, irrespective of the size of our shareholdings. This comes from SYQUANT Capital’s firm belief that even if the shareholding is not significant, voting allows SYQUANT Capital to express its point of view and to show companies its commitment to impeccable corporate governance and, where applicable, to better practices on environmental, social and stakeholder issues. The only exception to this rule would be cases where our custodians/proxy voting firms cannot vote, excessive costs or administrative procedures or other reasons that would need to be justified by SYQUANT Capital.

Being a signatory of the UN PRI charter, our voting policy aims to satisfy the principles of this Charter. Therefore, it is the objective of SYQUANT Capital to generally support shareholder proposals advocating ESG disclosure or universal norms/codes of conduct.

SYQUANT Capital has decided to mandate the proxy voting firm ISS Governance to proxy vote on the Investment Manager’s behalf based on “ISS Sustainability Policy”. As mentioned in the section above, SYQUANT Capital’s management team maintains its discretion to amend the proxy vote in the best interests of investors in the fund it manages. There may be situations in which we may be unable to vote a resolution or may choose not to vote a resolution, such as the costs of voting outweigh the benefit of voting. The management team will pay particular attention to meetings and resolutions regarding the following:
- Change of majority shareholder
- Situations of merger/acquisitions
- Restructuring (capital increases, debt issuance requests, share repurchase plans, creation or cancellation of preferred stock…)

The ISS Sustainability Policy will take as its frame of reference internationally recognized sustainability-related initiatives such as the United Nations Environment Programme Finance Initiative (UNEP FI), United Nations Principles for Responsible Investment (UN PRI), United Nations Global Compact, Global Reporting Initiative (GRI), Carbon Principles, International Labour Organization Conventions (ILO), CERES Roadmap for Sustainability, Global Sullivan Principles, MacBride Principles, and environmental and social European Union Directives. Each of these efforts promote a fair, unified and productive reporting and compliance environment which advances positive corporate ESG actions that promote practices that present new opportunities or that mitigate related financial and reputational risks.

On matters of corporate governance, executive compensation, and corporate structure, the ISS Sustainability Policy guidelines are based on a commitment to create and preserve economic value and to advance principles of good corporate governance.

Operating process
The management team is in charge of the vote’s decision. It analyses and instructs all resolutions’s votes. General meeting attendance monitoring is also performed by the management team. Exercise of the voting rights is mainly processed by regular mail.

Conflicts of interest
Internal compliance code and Conflict of interests management policy define, for all employees, the cases where a conflict of interests situation may arise.

Information and advertising
A report is published once a year, within 4 months of the end of each financial year (in accordance with article 314-101 of the RG AMF) and available here. This report along with the full version of the procedure defining the Voting Policy is also available at the management company’s office or upon request at: RCCI@syquant.com

 

2020 report on intermediary fees

In accordance with article 321-122 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 2020

In the context of transactions on listed shares, listed derivatives (futures & options) and corporate bonds done during the 2020 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 2020 is as follows:

  • Intermediary fees for investment decision support services represented 15.9% of the total.
  • Orders’ execution fees represented 84.1% of the total of intermediary fees.

Percentage of fees paid back to third parties in 2020 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 2020 financial year. As such, from the total of intermediary fees paid during year 2020, the percentage of these fees paid back to third parties under the terms of such agreements, as mentioned in article 321-121 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 referred to RCCI@syquant.com or by 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 receipt of the complaint.

In the event of an ongoing dispute, the client may contact the AMF Ombudsman 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

AMF mediation request form

 

ESG Policy

The purpose of this ESG Policy is to formalize SYQUANT Capital’s philosophy on sustainability and define our approach to integrating the consideration of E, S & G factors into our investment process, and in the broader operation of SYQUANT business.

SYQUANT Capital has established an ESG framework which encompasses:
- its investment approach, to inform investors about how social, environmental and governance (ESG) criteria are implemented in the investment process.
- its corporate practices, to ensure the firm is managed in a responsible manner and adopts ‘best practice’

We recognize that industry guidelines and best practices for ESG management continue to evolve over time. This policy reflects our current approach, and we expect that this policy will mature over time to reflect changes in industry practices, business structures, regulation, and the law. Accordingly, we monitor this policy on an ongoing basis and will typically review our approach annually.

Our ESG policy is available here.

 

COMPENSATION POLICY

In accordance with the UCITS Directive 2014/91/ EU of 23 July 2014, SYQUANT Capital has implemented a Remuneration Policy compatible with 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. This policy is available here. A hard copy can be made available free of charge upon request.

 

Privacy notice

Syquant Capital has issued a privacy notice in the context of the GDPR.

In the context of the Funds’ activities, we process or outsource the processing of personal data of various categories of data subjects. Insofar as we determine the purposes and means of this processing, we qualify and act as joint controllers. As a result, we become subject to a series of specific obligations vis-à-vis the data subjects concerned.

One of our obligations is to provide information to the data subjects concerned about the processing of their personal data. This Privacy Notice purports to fulfil our obligation of information. It is addressed to whoever it may concern, but in particular to all natural persons in relation to whom we process or outsource the processing of personal data as joint controllers.

The privacy notice is available here.