Regulatory information


  1. Best selection & best execution policy
  2. Conflicts of interests policy
  3. Exercice of voting rights police
  4. 2018 report on intermediary fees
  5. Customer complaints management
  6. Integration of ESG criteria
  7. Compensation policy


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.

SYQUANT Capital’s voting policy aims to focus on the exclusive interests of the clients investing in all the UCITS funds under management.

As a general principle, SYQUANT Capital does exercise the voting rights it is entitled to only under the circumstances where it considers that one resolution of the general meeting contributes to the interest and the protection of its clients.

As per the nature itself of the strategies implemented in the range of its funds, the management company only concentrates on general meeting’s resolutions which imply capital modification and merger proposals.

As a general rule, SYQUANT Capital votes in favor of any resolution aiming to validate any merger proposal or capital operation. In practice the Management Company has set a voting rights threshold of 3%, at which point it considers that it has an active role to play in this type of decision. Under this threshold SGP authorizes itself to exercise its voting rights whenever it considers that its vote may be decisive.

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


2018 report on intermediary fees

In accordance with article 314-82 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 2018
In the context of transactions on listed shares, listed derivatives (futures & options) and corporate bonds done during the 2018 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 analytic research 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 2018 is as follows:
- Intermediary fees for investment decision support services represented 15.1% of the total.
- Orders’ execution fees represented 84.9% of the total of intermediary fees.

Percentage of fees paid back to third parties in 2018 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 2018 financial year. As such, from the total of intermediary fees paid during year 2018, the percentage of these fees paid back to third parties under the terms of such agreements, as mentioned in article 314-81 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



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:

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



In accordance with article L.533-22-1 of the french “Code Monétaire et Financier”, SYQUANT Capital shall inform investors as regards to the integration of Social, Environmental and Corporate Governance criteria within the investment policy of the company.

Investment policy within all funds managed by SYQUANT Capital does not formally and systematically integrate criteria linked to Environmental, Social and Corporate Governance (E.S.G.) although the management team will in some particular investment opportunities pay a special attention to manager’s ethic, financial transparency, information and independency of their audit structures.

The management company does not currently belong to any association specialized in sustainable development and does not delegate to any third party the extra-financial notation of companies. SYQUANT Capital does not manage any E.S.G funds.



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.