Set-up of controls
CPR AM has a three-tier set-up of controls:
First-level permanent controls are handled by operating staff and are integrated into all stages of the management process.
Second-level permanent controls are handled by two CPR AM teams which are independent of the operating teams.
- The Risk Control department, with five persons, reports to CPR AM Senior Management and to Amundi’s Chief Risk Officer. Its purpose is to monitor risks incurred in fund management (including approval and compliance with the methodological framework; production, monitoring and approval of indicators; compliance with constraints; and monitoring of the risk policy set by CPR AM), as well as measuring and controlling proprietary activity risks.
- The Compliance and Internal Controls department focuses on controlling risks of breach in compliance and professional ethics rules, monitoring of the primacy of the client’s interests and compliance with market integrity. It handles three main missions: identifying and preventing risks, conducting the schedule of internal controls, and supervising responses to anomalies and incidents. The department head with regard to the French Financial Markets Authority (AMF) is the Chief Compliance and Internal Controls Officer.
Third-level periodic controls are handled by two entities:
- Amundi Audit is in charge of assessing the quality of the second-level controls set up by Amundi’s various entities. It ensures that the various entities are dealing properly with audited activities, that they are complying with external and internal rules, that information is reliable and complete, and that risk-measuring systems are in place.
- Crédit Agricole S.A. Inspection reports directly to Senior Management of Groupe Crédit Agricole. It is Senior Management’s guarantor of the efficiency of the company’s operations, effective control of risks, the proper conduct of its operations and their compliance.
Policies and regulation
CPR Asset Management is certified by the French Financial Markets Authority (AMF) under number GP 01-056
The European Markets in Financial Instruments Directive (MiFID) entered into force on 1 November 2007.
You will find below the main information on this directive.
- A MiFID information brochure
- Financial instruments and risks
- Policy for preventing and managing conflicts of interest
- Execution policy
- MiFID client classification
ENFORCEMENT OF ESMA GUIDELINES
ESMA’s “Guidelines on ETFs and other UCITS issues” was released on 12 December 2012 entered into force on 18 February 2013.
You will find, attached, the policy applicable to UCITS subject to these Orientations in the field of financial guarantees.
SHAREHOLDERS RIGHTS DIRECTIVE 2
The European Shareholder Rights Directive 2 requires asset managers to disclose publicly their engagement and voting policy. For several years, CPR Asset Management has choose to share these policies on its website with its investors.
Engagement policy, applied to all of the companies in the Amundi group, including CPR Asset Management, is articulated around three main axes: engagement for influence, ongoing engagement and engagement through voting. It is an essential part of Amundi’s fiduciary duty and its role as responsible investor.
The monitoring of the investee companies is organized as follows, depending on the management platform concerned:
- For active management strategy: investment cases are discussed and documented by the equity research analysts. Buy rated stocks are followed based on frequent research updates. The investment case is based on the Research team company report, supported by Valuation & Model updates when required. Feedback of meetings with the Company, as other engagement actions by the Research team, are documented diligently
- For passive management strategy: monitoring is mainly done through the engagement and the voting at general meetings.
- For Private Equity: for investments in companies not listed on a regulated market, the managers in charge of the participation on behalf of the portfolios, actively monitor the investee companies and usually attend general assemblies. These votes are confidential and therefore cannot be publicly reported.
Information relating to the European Shareholder Rights Directive 2 is presented in the documents below and in the dedicated section "Voting policy".
You may view here:
In the area of corporate governance CPR Asset Management has provided itself with a “ Voting Policy ”.
You may view here:
POLICY FOR MANAGING CLAIMS AND COMPLAINTS
You will find a link to our “ Policy for managing claims and complaints ” document
CODE OF CONDUCT
CPR Asset Management prides itself on having complied with GIPS performance presentation standards since 31 December 2002 for a performance track-record dating back to 1 January 1990. Theses checks have been undertaken by an independent firm and cover the entire company and its composites.
As an active member of the French Financial Management Association (AFG) through its participation in various working groups, CPR AM endeavours to comply with various provisions and recommendations of AFG’s code of compliance.
- EMPLOYEE COMPLIANCE
All compliance requirements are given to all employees. They list their obligations in terms of regulatory knowledge, declaration of their securities accounts and personal transactions, the holding of corporate directorships, and the receiving of gifts and benefits, if any.
FINANCIAL SECURITY AND ANTI-MONEY LAUNDERING
CPR AM’s prevention set-up is based on:
- An anti-money laundering correspondent: the Chief Compliance and Internal Controls Officer;
- An anti-money-laundering handbook, including laws and rules on third-party asset management applicable to Amundi group;
- Vetting by the Compliance and Internal Controls department of any contract committing the company;
- Employee training/awareness initiatives.
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