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 report on intermediation fees
- 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.
You may view here the latest engagement report of Amundi Group « Engagement report ».
In the area of corporate governance CPR Asset Management has provided itself with a “ Voting Policy ”.
You may view here the latest “ Report on shareholder dialogue and the exercise of voting rights ”.
POLICY FOR MANAGING CLAIMS AND COMPLAINTS
You will find a link to our “ Policy for managing claims and complaints ” document
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.