Regulatory information

Complaints handling policy

Clients may make a complaint by writing directly to MIMCO Asset Management by post at 87 Boulevard Haussmann 75008 Paris or by e-mail at partners@mimco-am.com. They may also make a complaint through an agent or intermediary writing on behalf of the end client. Client complaints are recorded centrally by the Compliance and Internal Control Officer in a dedicated file.

MIMCO Asset Management undertakes to:

• Acknowledge receipt no later than ten working days from the day of receipt of the complaint, unless the response to the customer is provided within this period;
• Provide a response to the customer no later than two months from the date of receipt of the complaint and the date of sending the response unless exceptional circumstances arise and are duly justified.

The management company's handling of the complaint is free of charge and the client does not incur any costs (administrative, research or other) in connection with the processing of the complaint.

If you are dissatisfied with the outcome of your complaint, you may contact the AMF:

AMF contact details:
Médiateur de l'AMF
Autorité des marchés financiers
17, place de la Bourse
75 082 Paris cedex 02

Conflict of interest policy

The prevention and management of conflicts of interest within the MIMCO Asset Management Company is in line with the general principles laid down by the MiFID II Directive and the AIFM Delegated Regulations, which include the following obligations:

• Establish a policy for managing conflicts of interest;
• Detect conflict of interest situations;
• Maintain a register of conflict of interest situations that arise;
• Inform clients when conflicts of interest cannot be resolved.

For additional information please contact: office@mimco-am.com
Specify in the subject line of the email "Conflict of Interest Management Policy".

Remuneration policy

MIMCO Asset Management has a personnel remuneration policy that complies with Article 13 of Directive 2011/61 EU and the ESMA Guidelines 2013/232 published on 3rd July 2013 and transposed in France by the AMF in Position Recommendation 2013-11 "Remuneration policies applicable to managers of alternative investment funds".

This remuneration policy has been reviewed to ensure compliance with Article 13 of EU Directive 2011/61, taking into account the size of the manager and the Funds it manages, its internal organization and the nature, scope and complexity of its activities.

Data management policy

MIMCO Asset Management is committed to conducting its business in compliance with all applicable data protection laws and regulations, and in accordance with the highest ethical standards.

MIMCO Asset Management has a procedure for the collection, use, storage, transfer, disclosure and destruction of any personal data. You can exercise your rights by contacting us by post at: 87 Boulevard Haussmann 75008 Paris or by email at: office@mimco-am.com
Specify in the subject line of the email "Data Management Policy".

Shareholder engagement policy

MIMCO Asset Management's shareholder engagement policy is in line with Directive 2017/828, the so-called "shareholders' rights" directive, which aims to promote long-term shareholder engagement and mentions the following obligations:

• Monitoring of strategy, financial and non-financial performance, risks, capital structure social and environmental impact and corporate governance;
• Dialogue with companies held;
• Cooperation with companies held and other stakeholders;
• Prevention and management of conflicts of interest;
• Reporting on shareholder engagement policy.

The shareholder engagement policy is freely available for consultation at MIMCO Asset Management's head office at 87 Boulevard Haussmann 75008 Paris, as well as on the company's website www.mimco-am.com via this link, and will be provided within 8 days upon request by e-mail or by letter.

For additional information please contact: office@mimco-am.com
Specify in the subject line of the email "Shareholder Engagement Policy".

ESG policy

SFDR Regulation

The European Union has set itself the goal of financing the transition to a low-carbon economy through three pillars:

1) Redirect capital flows towards a more sustainable economy
2) Integrate sustainability into risk management
3) Promote transparency and long-term sustainability in financial and economic activities.

The EU SFDR 2019/2088 (“Disclosure” regulation) introduced new regulatory obligations for the financial sector to increase the transparency of sustainability of financial market participants and financial products.

The SFDR regulation first requires defining the classification of each financial product according to its characteristics. The classification of funds can be summarised as follows:

• Products eligible under Article 8: the product promotes environmental or social objectives (or both), among other objectives;
• Products eligible under Article 9: the product has a sustainable investment objective, i.e. the investment is made in an economic activity that contributes to an environmental and/or social objective, provided that such investments do not cause significant harm to any of these objectives and the companies in which the investments are made apply good governance practices;
• Products eligible under Article 6: (Harmonie): if the fund is neither Article 8 nor Article 9 compliant, it is therefore Article 6 compliant. This status does not imply any particular consideration of environmental or social criteria. However, a duty of transparency on this non-integration in the management of the product remains.

Positioning of MIMCO Asset Management's investment solutions:

Sustainability risks

In accordance with Article 3 of the SFDR, MIMCO Asset Management's ESG integration strategy is intended to ensure that MIMCO Asset Management is fully aware of the key risks and opportunities of potential investments by adding additional levels of scrutiny and due diligence to its financial analysis and decision-making process.

MIMCO Asset Management addresses the following sustainability risks in its investment policy: energy performance, waste management, use of water resources, transport of materials, working conditions (health, safety), anti-competitive practices.

MIMCO Asset Management's ESG risk management policy is applied throughout the investment cycle:

• During the acquisition phase via an evaluation matrix that serves as ESG due diligence. This due diligence results in an initial score;
• During the investment phase: monitoring is carried out throughout the course of the project's development. Improvement plans are put in place to achieve a new rating;
• First and second level controls are then conducted to ensure compliance with MIMCO Asset Management’s ESG analysis methodology and policy.

For additional information: Consult the ESG risk management policy here

Addressing negative effects on sustainability

In accordance with article 4 of the SFDR, MIMCO Asset Management publishes a statement on its due diligence policy regarding the negative impacts of its investment decisions on sustainability factors.

MIMCO Asset Management considers that investments in the following sectors have negative sustainability impacts:

• The use, storage, production and movement of anti-personnel mines;
• Thermal coal is the most carbon-intensive and least efficient form of fossil fuel power generation. It also generates a high level of other polluting emissions. As part of the transition to a low-carbon economy, we exclude companies that derive more than 10% of their revenues from coal mining and/or coal-fired power generation;
• We do not invest in countries where there are serious violations of political stability or where the governance structure is deemed non-viable. Furthermore, MIMCO Asset Management complies with applicable UN, EU and OFAC sanctions to which it is subject, and any mandatory restrictions arising therefrom;
• For products and services managed directly by MIMCO Asset Management, without the intervention of a third party, we also exclude companies that violate the UN Global Compact principles on human rights, labour rights, environment and corruption;
• Direct involvement of companies in controversial weapons (development, testing, maintenance and sales), which cause disproportionate and indiscriminate harm (anti-personnel landmines, cluster bombs, depleted uranium weapons, chemical, biological and white phosphorous weapons). This principle applies to all holdings, regardless of the level of sales/turnover derived from them, except for the 5% sales/turnover threshold for white phosphorus weapons to recognise the fact that phosphorus is a dual-use substance;
• Oil sands are a non-renewable source of energy with a significant impact on the environment (high greenhouse gas emissions sector), biodiversity and health. The development of this unconventional energy is not consistent with the transition to a low-carbon economy and good climate risk management, which is why we exclude all companies involved in oil sands extraction.

Consequently, we focus our investment decisions on companies that promote positive environmental, social and governance practices. The sectors in which MIMCO Asset Management focuses its investments are:

• Environmentally friendly structuring projects;
• Real estate projects that use less fossil fuel;
• New or highly energy-efficient certified building projects;
• Projects with proven energy performance;
• Projects that improve the existing performance of buildings.

The policy for identifying and prioritising negative impacts can be summarised as follows:

1) Project sourcing
2) Responsible investment
3) Committed asset management
4) Employee commitment

Finally, MIMCO Asset Management is a signatory of the PRI (Principles for Responsible Investment) supported by the UN, formalising its transparency in favour of responsible investment.

Integration of sustainability risks in the remuneration policy

In accordance with Article 5 of the SFDR, MIMCO Asset Management has incorporated sustainability risk criteria into its remuneration policy.

MIMCO Asset Management's remuneration policy aims to align the interests of employees with the long-term vision of the Portfolio Management Company, whilst promoting a robust risk management culture to protect the value of portfolio investments.

Voting rights policy

MIMCO Asset Management has defined a voting policy that sets out the principles to which MIMCO Asset Management intends to refer when exercising voting rights and the way MIMCO Asset Management will exercise its voting rights. MIMCO Asset Management's voting policy is an integral part of its shareholder engagement policy.

MIMCO Asset Management reports on its use of voting rights in the annual reports of the funds under management.

For additional information please contact: office@mimco-am.com
Specify in the subject line of the email "Voting Rights Policy".

Code of ethics

Regulatory references

Article L. 533-10 of the Monetary and Financial Code
Articles 316-3 to 316-9 et seq. of the AMF General Regulation about authorization and programme of operations of asset management companies.
Article 63 of the Delegated Regulation 231/2013 dated 19^th December 2012

The ASPIM and AFG OPCI Code of Ethics, approved by the AMF, which each employee must acknowledge receipt of.

This MIMCO AM Code of Ethics will be amended as and when the AMF and ESMA publish the rules of ethics applicable to the personnel of asset management companies.

Good practice guidelines

It should be noted that, in accordance with the provisions of Articles L. 533-10 et seq. of the French Monetary and Financial Code, the Management Company is required, in its capacity as an investment services provider, to comply with the good practice guidelines intended to guarantee the protection of investors and the regularity of transactions. These rules oblige the Management Company to:

(1) Act fairly and equitably in the best interests of its clients and the integrity of the market;
(2) Conduct its business with due skill, care and diligence in the best interests of its clients and the integrity of the market;
(3) Have the resources and procedures necessary to carry out its activities, and implement those resources and procedures in an efficient manner;
(4) Inquire into the financial situation of its clients, their investment experience and their objectives with respect to the services requested; also inquire into the good character of its clients;
(5) Communicate, in an appropriate manner, relevant information in negotiations with its clients;
(6) Strive to avoid conflicts of interest and, where conflicts cannot be avoided, ensure that clients are treated fairly;
(7) Comply with all regulations applicable to the conduct of its business so as to promote the best interests of its clients and the integrity of the market;
(8) Exercise the rights attached to the securities held by the collective investment schemes it manages, in accordance with the voting policy implemented by the Management Company.

The full MIMCO AM Code of Ethics is available upon request from partners@mimco-am.com

Due to its portfolio management activity on behalf of third parties, the Management Company is required to comply with the provisions of the part of the AMF General Regulations relating to the rules of good conduct applicable to portfolio management services on behalf of third parties.

The Code of Ethics drawn up by the ASPIM is also communicated to all the Management Company's personnel, who are required to respect its provisions.

Review of regulatory information

This information was last reviewed on 20/04/2022.