Regulatory Information

Regulatory inforamtions for SILEX Investment Managers (France)

Important notices

Any subscription to a fund or product must be made after having read the regulatory documents of the fund. The prospectuses, KIDs (Key Information Document) and annual reports of each fund are available on our website on the page dedicated to the fund. Other documents are available on request from SILEX Investment Managers.
Investing in financial instruments may entail a risk and the value of a SICAV share being the reflection value of the securities and assets held is subject to variations in the stock markets. The investor may therefore lose all or part of the amount of capital invested, the funds not being guaranteed in capital.

Best selection

SILEX Investment Managers acts in the best interests of its clients for the execution of orders resulting from investment decisions relating to portfolios. In this context, SILEX Investment Managers has a particular obligation to select intermediaries whose execution policy will ensure the best possible result when executing orders transmitted on behalf of its clients. SILEX Investment Managers nevertheless remains responsible for the best execution when processing certain transactions placed directly on the market. SILEX Investment Managers has established an order execution policy enabling it to obtain the best possible result for its clients’ orders. The order execution policy provides in particular that orders are recorded and processed quickly and accurately, taking into account market conditions.
This order execution policy is based on: a standardized process for selecting financial intermediaries and counterparties; a process for selecting places of execution; a process of analysis and selection of reports provided by service providers within the framework of best execution. The criteria used to assess the quality of execution are both quantitative and qualitative. They depend on the markets on which the intermediaries offer their services, both in terms of geographical areas (global, pan-European, local intermediaries) and financial instruments traded (intermediaries specialising in equity markets, interest rates, convertibles, derivatives). Each analysis criterion is subject to an assessment with a weighting coefficient to assign an overall score and then to draw up a ranking of all the intermediaries analysed in order to determine the list of intermediaries actually selected. The analysis criteria include in particular financial solvency, speed, quality of processing and execution of orders, intermediation costs and the availability and proactivity of the interlocutors. The intermediary rating scales are updated each year. On this basis, the list of selected intermediaries is also subject to an annual review. The summary of our selection policy described above is updated as soon as the policy is updated. This can be obtained in its entirety upon simple request to the management company.

Conflict of Interest Management Policy

SILEX Investment Managers takes all necessary measures to detect conflict of interest situations arising when providing investment services, related services or managing funds. The company has a conflict of interest management policy for this purpose. This policy is appropriate given the size, organisation, nature, importance and complexity of SILEX Investment Managers' activity. It provides for procedures to be followed and measures to be taken to manage conflict of interest situations with the objective of prioritising the client's interest and respecting market integrity. It can be obtained upon request from SILEX Investment Managers. SILEX Investment Managers also keeps and updates a register listing, as necessary, situations in which a conflict of interest has arisen. When the organizational or administrative arrangements made by the company to manage conflicts of interest are not sufficient to guarantee, with reasonable certainty, that the risk of harming investors' interests will be avoided, the company will clearly inform investors of the general nature and/or source of these conflicts of interest. Furthermore, the identification of conflicts of interest has led to the development of a conflict of interest map. This map lists the situations that give rise to or are likely to give rise to a conflict of interest. It makes it possible to detect and, where appropriate, fairly manage conflicts of interest that may arise, in the context of the performance of one of its services, between its own interests and those of its clients or between the interests of several clients.

Voting policy

SILEX Investment Managers has established a voting policy presenting the conditions under which it intends to exercise the voting rights attached to the securities held by the OPCs that it manages.
Organization of the exercise of voting rights
The exercise of voting rights at general meetings is the responsibility of the managers who analyze the resolutions of the general meetings. The managers can rely on the recommendations emanating from the Association française de la gestion financière (AFG). The managers always vote in the direction of the proper functioning and good governance of the company as well as in the interest of the shareholders.
Cases of exercising voting rights
Voting rights are systematically exercised when the share of the company's capital held by the OPCs is greater than 3%.
Principles of voting policy
The principles of SILEX Investment Managers' voting policy are based on respect for good corporate governance while respecting the interests of shareholders, and taking into account the recommendations issued by the AFG.
Prevention of conflict of interest situations
SILEX Investment Managers’ voting policy is established in complete independence. Voting rights are exercised strictly in the interest of unitholders, without taking into account the own interests of SILEX Investment Managers or the SILEX group.
Method of exercising voting rights
Voting rights are in principle exercised by correspondence, by proxy, by electronic vote. However, managers may occasionally attend general meetings.
Report and communications
An annual report is prepared within four months of the end of SILEX Investment Managers' financial year, reporting on the conditions for exercising voting rights. It specifies the number of companies in which SILEX Investment Managers has exercised its voting rights in relation to the total number of companies in which it has voting rights, as well as the cases in which it considered that it could not comply with the principles set out in this voting policy. Conflict of interest situations encountered when exercising voting rights are also included in this report. It is made available to the Autorité des Marchés Financiers and to all holders of funds or principals who request it. However, in the event that SILEX Investment Managers does not exercise its voting rights, no annual report is published.

Report on intermediation fees

When SILEX Investment Managers uses Investment Decision Support and Order Execution Services and the intermediation fees for the previous financial year amounted to more than EUR 500,000, SILEX Investment Managers draws up a document entitled “Report on intermediation fees”.

Portfolio Inventory Transmission Policy

In accordance with the position "Market timing and late trading practices (DOC-2004-07)" of the Autorité des Marchés Financiers (AMF), SILEX Investment Managers specifies when and how it transmits to the holders the detailed inventories of the funds that it manages. In order to avoid the practice of market timing, SILEX Investment Managers does not communicate in real time the details of the funds portfolio to a prospect, client, distributor, consultant or other external counterparties or intermediaries. The associated principles and procedures, mentioned in this section, do not apply to mandates, the information of which may be communicated at any time to their principals and to the dedicated funds, provided that the information is communicated concomitantly to all holders.
SILEX Investment Managers may communicate to these investors the information necessary for them to be able to fulfil their regulatory obligations, subject to the signing of a confidentiality agreement. SILEX Investment Managers may not transmit this information within a period of less than 48 hours after the publication of the net asset value.

Compensation policy

The remuneration policy of SILEX Investment Managers has been approved by the Management Board of the management company. The principles of the remuneration policy are reviewed on a regular basis by the remuneration committee and adapted to the constantly changing regulatory framework. The remuneration policy includes a description of how remuneration and benefits are calculated. A hard copy is available free of charge upon request.

Special reporting on art.29 of the French Energy and Climate Actt

In accordance with applicable regulations, the Energy and Climate Act report is available upon request.

SILEX Finance (France)

SILEX FINANCE is a Financial Investment Advisor (CIF in French) registered with ORIAS and a member of the la Compagnie CIF. The advice provided by the company is non-independent advice subject to the provisions relating to benefits and remuneration specified in Article 325-16 of the AMF General Regulations

Regulatory informations on SILEX SAM (Monaco)

SILEX SAM is an establishment approved by the Financial Activities Control Commission (CCAF) for the reception and transmission of orders (RTO), advice for RTO and wealth management advice and bearing approval number 2020-03.

Regulatory informations on SILEX Partners Ltd (Royaume Uni)

SILEX PARTNERS Ltd is acting duly on behalf of SAPIA Partners Ltd which is authorised by the Financial Conduct Authority, under reference number 977475, to advise on investments, to arrange (bring about) transactions in investments, to deal in investments as agent.