Regulatory information

Remuneration policy


ln accordance with the provisions of the Alternative lnvestment Fund Managers Directive 2011/61/EU (AIFM Directive), Balzac REIM undertakes to establish, implement and maintain a normative system relating to the remuneration of its employees.

The objective of this policy is to promote sound and efficient risk management by not encouraging risk-taking that is incompatible with the risk profiles, prospectuses/regulations or other documents of the funds under management.

Balzac REIM’s remuneration policy is consistent with a coherent economic strategy, objectives, values and interests of the Management Company, funds under managements clients, and includes measures to avoid conflicts of interest. It also takes into account the organizational and operational requirements of Balzac REIM and the nature, scope and complexity of its activities.

Thus, it specifies the methods for determining and paying the overall remuneration package allocated by the Management Company’s Management for a given financial year to the employees concerned, this overall package including fixed and variable remuneration.

The remuneration policy has been put in place in order to : 

Actively support the strategy and objectives of the Management Company support the competitiveness of the Management Company in the market in which it operates ensure the attractiveness, development, and retention of staff, Balzac REIM employees are clearly informed in advance of the qualitative and quantitative criteria used to determine their remuneration as well as the stages and timetable for assessing their performance. 

The purpose of the remuneration policy is to define the criteria used by the Management Company to evaluate the performance of the persons concerned and to determine their fixed and variable remuneration:

The fixed part of the remuneration of the employee concerns rewards for the employee’s ability to meet the criteria defined for his/her position in a satisfactory manner.
The variable part of the remuneration of the employee concerns aims to recognize individual performance, contributions and behaviour.
Remuneration is individual and negotiated at the lime of the employment contract by Balzac REIM’s General Management. lt may be revised according to the development of the employce and the Management Company, within the limits set by the overall remuneration Policy.

The policy is re-evaluated annually and validated by Balzac REIM’s Management.

Best selection policy


Within the framework of its activity, and in compliance with regulations, Balzac REIM may use external service providers under its own responsibility.

ln the interest of its clients, and in line with its policy of transparency, Balzac REIM ensures that service providers are selected on a competitive basis.

Each external service provider is selected by Balzac REIM according to the following criteria:

  • recognized as a player in the field,
  • recommended by other persons – including the investor – who have used their services previously,
  • having obtained commitment from the service provider in relation to Balzac REIM’s specific needs,
  • having received detailed estimate and quotes,
  • having the possibility of checking it any time,
  • checking that there is no conflict of interest with the contractor,
  • being able to intervene with them to ensure that they comply with the applicable regulations,
  • having the possibility of terminating the contract at any time, and in the event of termination at the initiative of the service provider, the means provided to ensure the continuity of the service.

An internal assessment of the quality of services is carried out at least once a year by Balzac REIM’s teams, which are in direct contact with the external service providers.

An ad hoc review may also be carried out each time an event or piece of information justifies it, particular1y with regard to the criteria mentioned above.

For example, this review may be necessary in the event of a change in shareholder, structure, team, internal systems, size or costs, or if there is a deterioration in the quality of execution, reputation or mechanisms for resolving any errors or problems.

Complaints handling policy


ln accordance with the regulations, Balzac REIM has set up a complaints handling system specifying:

  • the obligation for the Management Company to undertake to respond to a client or prospective client complaint within a maximum of two months, except in specific, duly justified circumstances, and, if the response is not immediately provided, to acknowledge receipt within a maximum of ten working days,
  • the establishment of a complaints handling system allowing for equal and harmonized treatment,
  • the allocation of the resources and expertise necessary to ensure this processing,
  • the obligation to follow up on complaints in order to identify and remedy malfunctions.

These provisions apply to:

  • complaints from all unit-holders or shareholders where no investment services are provided to them at the time of subscription
  • complaints from unit-holders or shareholders from non-professional client when a Referral procedures

Referral procedures

Any client or prospect wishing to make a complaint ta Balzac REIM is invited to send a letter to the following address:

  • by post to:              
    BALZAC REIM
    Mr François MENAGÉ, President
    112 Avenue Kléber
    75116 Paris France
  • by telephone:             +33 (0)1 53 93 23 50
    (complaints received by telephone must be confirmed in writing by post or e-mail)

Recourse to the Mediator

Balzac REIM does not itself have an internal mediation service,

However, if Balzac REIM rejects the complaint or refuses to accept it in whole or in part, the reply sent to the client informs him/her of the possibility of referring the matter to the independent mediator of the AMF:

Autorité des Marchés Financiers (AMF)
Ms Marielle Cohen-Branche
AMF Mediator
17 place de la Bourse
75082 Paris Cedex 02

Télécopie : +33 (0)1 53 45 59 60

http://www.amf-france.org/

The AMF mediation request form and the mediation charter are available on the website:
http://www.amf-france.org/Le-mediateur-de-l-AMF/Presentation.html

Conflict of interest management policy


ln accordance with the applicable regulatory requirements, BALZAC REIM establishes and maintains an effective conflict of interest management policy, set out in writing and appropriate to its size, organization, nature, importance, and complexity of its activities.

This policy must ensure the prevention, identification and treatment of conflicts of interest, in order to prevent harming the interests of clients and unit-holders, and thus avoiding any reputational risk.

Definition

Conflict of interest is defined as a situation that involves a choice:

  • between the interest of the Management Company and the interest of the client/unitholder,
  • between the interest of a client/carrier and the interest of another client/carrier,
  • between the interest of the Management Company and the personal interest of the employee,
  • between the interest or the client/carrier and the personal interest of an employee,
  • between the interest of the shareholders of the Management Company and that of its clients/holders.

Article 321-47 (UCITS) 318-13 (FIA) of the AMF General Regulation defines potential conflicts of interest as situations where the Management Company (or a person related to it – in particular a related agent):

  • is likely to make a financial gain or avoid a financial loss at the expense of the client,
  • has an interest in the outcome of a service provided to the client or a transaction carried out on the client’s behalf that is different from the client’s interest in the outcome,
  • has an incentive, for financial or other reasons, to favour the interests of another client or group of clients over the interests of the client to whom the service is provided,
  • is engaged in the same business as the client,
  • receives or will receive from someone other than the client any benefit in connection with the service provided to the client in any form other than the commission or fee normally charged for that service.

This conflict is likely to influence the Management Company’s choices and the manner, in which it carries out its duties, and thus may call into question its neutrality in the performance of its mission.

ln accordance with the applicable regulatory requirements, BALZAC REIM establishes and maintains an effective conflict of interest management policy, set out in writing, and appropriate to its size, organization, nature, importance and complexity of its activities.

This policy should ensure that conflicts of interest are prevented, identified and dealt with so that they do not adversely affect the interests of clients and unit-holders, and thus avoid any reputational risk.

Scope: activities and persons concerned

The conflict-of-interest management policy covers all potential or actual conflicts of interest resulting from the professional activities of any natural or legal person directly or indirectly linked to Balzac REIM in compliance with approval issued by the AMF.

Within the framework of its activities, Balzac REIM takes care to identify situations leading, or likely to lead, to a conflict of interest, in order to find a solution that guarantees the primacy and preservation of the interests of its clients/investors.

The persons concerned by the risks of conflicts of interest are the directors and shareholders of Balzac REIM, financial managers, employees of Balzac REIM, trainees and apprentices, external service providers to whom essential functions are delegated, financial intermediaries, and persons made available and placed under the authority of the Management Company.

Conflict of interest prevention and management system

Balzac REIM is required to take ail reasonable measures to prevent conflicts of interest from harming the interests of its clients/holders to this end, the Management Company has identified potential conflicts of interest of a general nature and those specific to the organization in place and the activities carried out. by listing them in a dedicated map.

If a potential conflict of interest situation is detected, the supposed conflict of interest situation is compared with the different typologies described in the conflict of interest map.

When the conflict of interest is already foreseen in the mapping of potential conflicts of interest, Balzac REIM adopts a solution in accordance with the latter.

Where the conflict has not yet been addressed, Balzac REIM will adopt a solution using the following procedures and measures,

– the elimination of any direct link between the remuneration of relevant persons primarily engaged in a particular activity and the remuneration of other relevant persons primarily engaged in another activity, or the income generated by such other persons, where a conflict
of interest is likely to arise in relation to those activities,

– measures to prohibit or control the simultaneous or consecutive participation of a relevant person in several activities when such participation is likely to interfere with the proper management of conflicts of interest.

Balzac REIM will, if necessary, take the organisational or specific measures required on a case­ by-case basis to deal with the risk of conflicts of interest.