The Market in Financial Instruments Directive (MiFID) has been effective since 1 November 2007. The directive’s objective is to ensure the transparency of information that the Company discloses to its clients, Explanations of the Company current practices and policy.
1. General Information
In accordance with regulations, BNP PARIBAS ASSET MANAGEMENT Holding SA and affiliated (« BNPP AM ») provides information about itself, its management companies services and the ancillary investment services it offers.
BNPP AM offices are located at the following adress:
BNP Paribas Asset Management
1 Boulevard Haussmann 75009 Paris
The below text is intended to provide the required level of information on our firm and on the financial services we provide.
 Affiliated companies means any entity controlled, directly or indirectly, by BNP PARIBAS ASSET MANAGEMENT Holding; the control has the meaning ascribed in the article L 233-3 of the French Commercial code.
2. Licenses and competent supervisory authorities
The following BNPP AM Entities are either MiFID investment firms or management companies licensed for Undertakings for Collective Investment in Transferable Securities (“UCITS”) and/or Alternative Investment Funds (“AIF”).
BNP PARIBAS ASSET MANAGEMENT FRANCE is supervised by the French competent supervisory authority, the Autorité des Marchés Financiers (AMF).
17, place de la Bourse
75082 Paris Cedex 02
BNP PARIBAS ASSET MANAGEMENT BELGIUM is supervised by the Belgian competent supervisory authority, the Financial Services and Markets Authority (“FSMA”).www.fsma.be
12-14 Rue du Congrès/Congresstraat
BNP PARIBAS ASSET MANAGEMENT Nederland N.V.is supervised by the Dutch competent supervisory authority, The Dutch Authority for the Financial Markets (AFM).
P.O. box 11723
1001 GS, AMSTERDAM
BNP PARIBAS ASSET MANAGEMENT UK Limited is supervised by the UK competent supervisory authority, The Financial Conduct Authority
12 Endeavour Square
3. Investment services and ancillary services
In Compliance with local, European and applicable extraterritorial regulations, BNPP AM aims at ensuring a high level of investor protection, respecting the applicable rules of conduct and acting in the clients’ best interest.
Please note that BNPP AM focuses its services offering to professional clients. MiFID classification is our starting point when providing ancillary investment services.
Ensuring a high level of investor protection can only be achieved by providing adequate information to our potential and existing clients and by obtaining accurate and up-to-date information from these potential and existing clients with regards to their financial situation, risk tolerance, ability to bear losses, investment objectives and investment horizon.
The information collected allows us to determine which services and financial instruments are deemed suitable for you.
BNPP AM offers the following MiFID investment services:
- Investment Advice
- Portfolio Management
Important for you:
Investment Advice (including, if requested, the reception and transmission of orders in relation to advised financial instruments)
Investment Advice can be defined as the provision of personal recommendations to a client, either upon its request or at the initiative of the investment firm, in respect to one or more transactions relating to financial instruments.
Investment Advice implies that the recommendation presented is suitable for the client, in its capacity as an investor or a potential investor, and that it must be based on a consideration of the circumstances of the client.
Please note a recommendation differs from the provision of information in the sense that a recommendation always requires an element of opinion on the part of the advisor.
Please note that BNPP AM provides investment advice on a non-independent basis.
Portfolio Management can be defined as the managing of portfolios in accordance with mandates given by clients on a discretionary client-by-client basis where such portfolios include one or more financial instruments.
Portfolio Management implies that the client has given the portfolio manager a mandate with respect to the management of its assets. The portfolio manager is thus allowed to take decisions and undertake actions for the appropriate management of the portfolio on behalf of the client and this always in the best interest of the client.
3.1 Conduct of business rules
- MiFID classification: in accordance with current regulations applicable to the investment services BNPP AM provides, BNPP AM classifies its clients as non-professional (“retail”) or as professional.Please note that if your entity is a local public authority, municipality, association or union, your entity will be classified as a retail client
- Product governance: this enhances investor protection by requiring that investment firms take reasonable steps to ensure that financial instruments are marketed to a pre-determined target market of clients that is specific to a given financial instrument. BNPP AM will also review the effectiveness of these arrangements on a regular basis.
- « Inducements »: in accordance with current regulations applicable to the investment services BNPP AM provides, BNPP AM does not receive any fees; commissions or other monetary or non-monetary benefits disbursed or provided by third parties, except for minor non-monetary benefits improving the quality of the service offered to clients.
- Suitability report for investment advice provided to non-professional clients: BNPP AM will send beforeany transaction is made, a suitability report explaining on which basis the investment advice is considered suitable for their specific situation.
- Reporting obligation in relation to portfolio management: in the case of a 10% decrease of the value of a client’s portfolio within one reporting period, BNPP AM’s clients will be notified.
- Ex ante costs and charges: in order to ensure transparency and in the best interest of the client, costs and charges relating to the investment and/or ancillary services and the related financial instruments are disclosed on an aggregate basis and in a timely manner to clients prior to any provision of service or investment decision.
- Ex post costs and charges: in order to ensure transparency and in the best interest of the client, costs and charges relating to the investment and/or ancillary services and the related financial instruments (if relevant) are disclosed on an annual basis to clients.
- Telephone and electronic communication recording and record-keeping:
BNPP AM records telephone conversations and electronic communications with its clients that result or may result in a transaction or certain other regulated activities. A copy of these communications must be available on request for a period of five years after the communication was recorded.
- Information about the procedures for safeguarding the Clients Financial Instrument and Cash:
The Company does not hold cash or financial instruments of clients.Any cash and financial instruments under management, as well as the cash and financial instruments deriving from time to time from the management activity performed by the Company on behalf of the Client, are deposited with the depositary appointed by the Client.
- Legal Entity Identifier (“LEI”) code:
In order to comply with current regulatory obligations where BNPP AM provides investment services to clients, a valid LEI code is required.This LEI code is a unique 20 character ISO1 identifier for a legal entity that participates in a financial transaction. Once a legal entity obtains an LEI code, the code remains unchanged.Please consult the following website for information on how to obtain a LEI code: www.leiroc.org.
- Complaints Policy:
BNPP AM has a proven track record of providing its clients with high-quality and reliable investment services. Client satisfaction is our primary objective. If however any client feels dissatisfied with our services, BNPP AM has adopted a Complaints Policy in order to first remediate the issue at hand and second, take into account this issue and evaluate how BNPP AM can improve its service offering to avoid similar issues in the future. Clients filing a complaint will receive an acknowledgement notice within five business days.Information regarding the Complaints Policy can be found attached on this same page of the Website.
- Conflicts of Interest Policy:
BNPP AM has adopted investor protection rules regarding the prevention and management of any incurred or potential conflicts of interest by implementing a Conflicts of Interest Policy and an associated Conflicts of Interest Inventory. This policy and inventory is regularly updated in order to ensure its accuracy and exhaustiveness.Detailed information regarding the Conflicts of Interest Policy can be found attached on this same page of the Website.
- Best execution–Best selection Policy:
BNPP AM has adopted a Best execution-Best selection Policy aimed at enhancing investor protection with regards to the execution of client orders. This policy is regularly updated in order to ensure its accuracy and exhaustiveness.Furthermore new requirements have been implemented with regards to the regular monitoring and review of our Best execution-Best selection Policy and the arrangements put in place to ensure that all sufficient steps are taken to obtain the best possible result for our clients when executing their orders.Every year, BNPP AM will publicly disclose the top five execution venues used, in terms of trading volumes, to clarify how we achieve best execution for you. BNPP AM will also regularly publish reports on information regarding the quality of execution for transactions that we executed against our own books.Detailed information regarding the Best execution-Best selection Policy can be found attached on this same page of the Website.
 Affiliated companies means any entity controlled, directly or indirectly, by BNP Paribas Asset Management Holding; the control has the meaning ascribed in the article L 233-3 of the French Commercial code