Regulatory information

Complaints

Pursuant to Article 313-8 of the AMF general regulation, information on the complaint handling procedure is made available free of charge by Axiom Alternative Investments.

Axiom has implemented and maintains an operational procedure to quickly and efficiently process complaints made by its clients. Any complaint may be sent to the Compliance department by post to Axiom Alternative Investments, 39 avenue Pierre 1er de Serbie 75008 Paris, France. The management company will acknowledge receipt of the complaint within ten working days of the date on which 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.

For France: In the event of an ongoing dispute, the client may contact a mediator, such as the AMF Ombudsman. The address of the AMF Ombudsman is: Autorité des marchés financiers, The AMF Ombudsman, 17 place de la Bourse, 75082 PARIS CEDEX 02, FRANCE. The AMF mediation request form and the Mediation Charter are available online at http://www.amf-france.org.

For Luxembourg: In the event of a dispute or in the absence of an acknowledgment of receipt or response within one month of the complaint being made, the client may contact the competent authority, either by post to Commission de Surveillance du Secteur Financier, L-2991 Luxembourg or by email to direction@cssf.lu

The CSSF dispute resolution request form and relevant texts on the matter are available at http://www.cssf.lu.

Conflicts of interest policy

Pursuant to section 3 of Article L. 533-10 of the French Monetary and Financial Code, Axiom Alternative Investments shall duly inform shareholders of the risk of potential conflicts of interest before acting on their behalf.

Privacy policy

Axiom Alternative Investments requires that you provide current and accurate financial and personal information. Axiom will protect the information you have provided in a manner that is safe, secure and professional. Axiom and its employees are committed to protecting your privacy and to safeguarding that information.

Privacy policy

Voting policy

Pursuant to Article 314-100 of the AMF general regulation, Axiom Alternative Investments has established a voting policy setting the conditions for the exercise of voting rights attached to the securities held by UCITS under its management.

Our engagement and voting policy apply to all of our assets under management. That being said, our range of funds invested in equities is limited to a single fund managing 20 million euros i.e. 0.52% of our total assets as at mid-January 2020, the majority of which are bonds, with a moderate use of derivatives and CDS.

We are cognizant that voting is an important part of the investment process and an opportunity to influence the company so voting rights are exercised above defined thresholds, expressed as a percentage of the number of outstanding shares of an issuer held by the mutual fund concerned. Axiom Alternative Investment may be required to vote when its shareholding falls below the thresholds only in exceptional situations where the defense of shareholders’ interests is necessary.

Our policy is available here below (in French) and available in English on request.

Voting Policy Axiom AI

Broker Selection Policy

In accordance with Article 314-75-1 of the General Rules of the Autorité des Marchés Financiers, Axiom Alternative Management has established a policy for selecting and evaluating the entities that provide it with assistance in investment decision-making and order-execution.

SFDR and AMF Compliance

On march 10, 2021 the European Sustainable Finance Disclosure Regulation (SFDR) 2019/2088 and the position-recommandation DOC-2020-03 of the AMF entered into force with the aim to strengthen protection for end investors of financial products that integrate sustainability considerations into their investment process. Both have for objective to improve the comparability of financial products disclosures by stablishing minimum standards.

This document explains Axiom AI’s compliance with both regulations.

THEMATIC AND SECTORAL POLICIES

One of the tools used to implement our Responsible Investment policy is our thematic and sectoral policies handbook which defines the total or partial exclusion principles to be followed by our portfolio managers. The policies are used to maintain two exclusion lists:

1 – General list, which is based on the general thematic and sectoral policies applied by all our long funds except for index-based funds.
2 – Sustainable Finance funds range list, which is defined by additional and more stringent sectoral policies, including policies for the exclusion of financial institutions’ issuers.

These lists and related policies were introduced in order to formalize our desire not to invest in any company engaged in activities that do not correspond to our values ​​and our requirements in terms of sustainable development. Direct investments in securities issued by firms on those exclusion lists are prohibited. If a name is added to the exclusion list and the securities are already in the portfolios, the portfolio manager must divest the securities, in a way that is not damaging to our clients’ capital. The portfolio manager has a maximum of one month to sell the securities.

Our exclusion lists are revised on a regular basis by the ESG committee, and at least annually.

 

RESPONSIBLE INVESTMENT POLICY

As an asset manager specialized in the financial sector, Axiom seeks to promote the transition to a socially just and low-carbon economy while seeking superior risk-adjusted returns. We are cognizant that the European banking sector plays a key role for the achievement of such a transition as it finances more than 70% of the EU economy. In addition, we acknowledge that empirical research has established a link between firm performance and ESG performance. All this coupled with our focus on subordinated financial debt has led to the development of a Responsible Investment (RI) approach tailor-made for financial institutions which seeks to minimize both the ESG risks than can affect issuers’ financial performance as well as the negative impact that these may have in the economy, the society and the environment.

Our RI approach is comprised of the following tools:
1 – Financial institutions ESG controversies database.
2 – Sectoral and Thematic policies which addresses both financial institutions and corporates (<7% of our AuM), as well as sovereign debt investments.
3 – The Axiom’s Climate Readiness Score (ACRS), our proprietary climate tool for financial institutions climate analysis.
4 – StewardshipThe management of all our long funds except for the ETF integrates at least one of these tools. The ESG committee oversees the implementation of our RI approach, while the management committee defines the RI strategy and ensures it is consistently and effectively rolled out.

Remuneration policy

Axiom Alternative Investments’ Remuneration Policy has been approved by the Board of Directors of the management company. The provisions of the Remuneration Policy are reviewed on a regular and are adjusted to fit the changing regulatory framework. The remuneration policy includes a description of how remuneration and benefits are calculated. A copy of the policy is available free of charge upon request.
See the Remuneration policy
PRI