Which measures has Amundi PEF taken to identify conflicts of interest?
Preventively, Amundi PEF is implementing specific procedures, notably a regular review of activities and specific transactions.
To this end, in accordance with the regulations in force, Amundi PEF has developed a mapping of the different situations of potential conflict of interest in its activities, which might affect the interests of clients because one of the players concerned:
- 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 behalf of the client that is different from the client’s interest in the outcome;
- is prompted 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;
- carries out the same professional activity as that of the client;
- receives or will receive from a person other than the client an advantage in relation to the service provided to the client, in any form whatsoever, other than the commission or fees normally charged for this service.
This risk mapping is updated periodically, at least once per year, to integrate the developments and changes in Amundi PEF’s activities. This allows Amundi PEF to ensure that organisational or procedural provisions are implemented to prevent or manage potential conflicts of interest, that checks are carried out and that their results are satisfactory.
This mapping notably covers:
a) conflicts of interest between Amundi PEF and other entities of the Crédit Agricole group concerning:
- l’activité de capital investissement (prise de participation, co-investissement, gestion de portefeuilles) versus les autres activités bancaires ou de capital investissement d'autres entités du groupe crédit agricole,
b) conflicts of interest between the various activities carried out by Amundi PEF concerning direct fund management :
- the management of funds of funds in development or secondary market projects likely to concern the same interests and that may have a different impact on several funds: “Wall of China” principle (separation of duties, compensation and staff code of conduct)
c) conflicts of interest between Amundi PEF, its service providers, its clients–subscribers, its shareholders or co-investors concerning:
- independence from third-party shareholders or clients in the conduct of activities (selection of providers, intermediaries, investment choices, participation in the boards of companies)
- a choice of service providers (delegatees, lawyers, etc.) without holding a tender procedure or under unusual market conditions
- direct fund management, the management of funds of funds exercised in the interest of investors (rule for allocating interests taken in the various portfolios, rules in the case of divestiture of interests)
- the choice of counterparties for the placing of orders on listed companies without taking account of the best execution objective
- direct and indirect remunerations received by Amundi PEF (transparency of information and remuneration)
e) conflict of interest between Amundi PEF and its employees concerning:
- personal transactions generating a financial gain on investments (investment in managed portfolios, carried interest)
- the exercise of several activities or external mandates with direct financial interests in companies in which Amundi PEF invests, which, moreover, may be in competition
- the use of confidential information obtained in the context of the investment activity
- the benefits received from companies in which Amundi PEF invests, from co-investors, clients or service providers that could lead to them being treated preferentially
Amundi PEF also implements procedures for employees to report any potential or proven conflict of interest situation.