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 email@example.com
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.
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.
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.
Broker Selection Policy
Pursuant to Decree 2012-132 of January 30, 2012, Axiom Alternative Investments provides information on the social, environmental and governance criteria used in the context of its investment policy.
Axiom Alternative Investments has adopted the UN Principles for Responsible Investment (UNRI) in 2016. By doing so, Axiom confirms its commitment and willingness to take into account the extra financial criteria (referred to as ESG) into its management process.
It is now clear that ESG investing, or sustainable investing as it is sometimes called, is not only about doing what is right for the environment and the communities we live in; it is also about doing what is right for your portfolio.
We believe ESG should be integrated for all asset classes. However, Axiom is a specialist in financial institutions. We currently invest a very substantial share of our assets under management in financial institutions and currently our ESG approach only applies to them. We will seek to expand our ESG research capacity in the future.
For financial institutions, we use three main mechanisms to integrate ESG criteria:
- Our in-house database and tools dedicated to ESG, as described in our ESG policy below.
- Engagement with management or investor relations teams to get additional information.
- Information published in annual reports or other regulatory filings (such as TCFD or sustainability reports.)
Axiom’s investment committee is ultimately responsible for that ESG integration progress across investment teams, under the supervision of the Axiom executive committee (“Conseil de gérance”).
On top of the ESG analysis described in our ESG policy, Axiom maintains two exclusion lists.
Our Sectorial Policies disclosed in our Transparency and no-harm Handbook below define the components of our General exclusions list applicable to all Axiom funds which is revised on a regular basis by the investment committee, and at least annually.
Our Sustainable standards disclosed in our Transparency and no-harm Handbook below define the additional more stringent exclusions list applied to our Sustainable Financial Institutions funds.
Direct investments in securities issued by firms on that 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 harmful to holders (no fire sale).
The lists are mainly based on the lists established by recognized key players, such as the Norwegian government pension fund. These lists 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. Companies can be excluded for example because they produce controversial weapons, such as the ones covered by the Ottawa and Oslo Conventions (anti-personnel mines, cluster munitions.)
Our exclusion lists are revised on a regular basis by the investment committee, and at least annually.
The exclusions don’t not apply to indices the composition of which cannot be controlled by the company (index or ETF investments). The lists also do not apply to indirect investments: we will not exclude a financial institution because it lends to an excluded company.