Any investment in a UCI or any related product should only be made after reviewing the current regulatory documents.
The prospectuses, KIDs (Key Investor Documents), KIIDs (Key Investor Information Documents) and annual reports of every UCI approved and/or authorised by the Autorité des Marchés Financiers (French financial markets authority or AMF); the Commission de Surveillance du Secteur Financier (Luxembourg financial supervisory authority or CSSF) and the Financial Conduct Authority or FCA are available from the respective websites.
The other regulatory documents are available on request from Carmignac, 24 place Vendôme, 75001 Paris, France.
Investment in financial products involves risk. The value of a share in a SICAV, a unit of an FCP , an ICAV, or a share in an OEIC reflects the value of the securities and assets held in the portfolio and is subject to market fluctuations.
Investors may lose some or all their capital, as the capital in the funds is not guaranteed.
All investment service providers have an obligation to act in the best interests of their clients when executing orders that result from investment decisions for the portfolios.
To this end, in its capacity as a management company, and having regard to the nature of its business, Carmignac is obligated to select intermediaries whose execution policy guarantees the best possible result when executing orders sent on behalf of its clients.
Carmignac nevertheless remains responsible for best execution with respect to the processing of certain transactions carried out directly on the market.
In accordance with the regulations, Carmignac has put in place an order execution policy that allows it to obtain the best possible result with respect to client orders. The order execution policy notably requires that orders be registered and processed in a timely and accurate manner, having regard to market conditions.
This order execution policy is based on:
Carmignac uses a multi-criteria approach to select intermediaries that guarantee the best execution of stock market orders.
The criteria applied are both quantitative and qualitative. They depend on the markets for which the intermediaries provide services, in terms of both geographical area (global, pan-European, or local intermediaries) and financial instruments traded (intermediaries specialised in equity, interest rate, convertible or derivatives markets).
Every analysis criterion is subject to an assessment, which is allocated a weighting coefficient, thereby enabling an overall rating to be attributed, subsequently allowing all intermediaries analysed to be ranked. The methodology for calculating votes (weightings / criteria) is periodically reviewed by the Trading Desk and submitted for approval to the Broker Committee.
Contacts with new service providers, steered by the Trading Desk and monitored by a dedicated "Due Diligence" operational committee, are also the subject of a special review during the Broker Committee.
The final list of intermediaries/ counterparties evaluation is subject to the validation/ review of the Broker Committee which notes the "dormancy" or "closure of relationships".
The analysis criteria notably cover:
The intermediaries’ ratings are updated twice a year. Based on this, the list of selected intermediaries is also reviewed twice a year.
The summary of our selection policy described above is updated whenever the policy changes. The policy can be obtained on request from the management company.
Carmignac makes every effort to identify conflicts of interest that may arise whilst providing investment or related services or fund management services.
Carmignac has a conflict of interest management policy -which is commensurate with the size, structure, nature, importance and complexity of Carmignac’s business. It includes procedures to follow and measures to take to manage conflicts of interest, the aim being to ensure the primacy of clients’ interests and respect for market integrity.
Carmignac also maintains and updates a register that lists situations in which a conflict of interest has arisen or may arise during its activities.
When the organisational or administrative measures taken by Carmignac to manage conflicts of interest are not sufficient to avoid the risk of damaging investors’ interests with a reasonable degree of certainty, Carmignac will inform investors of the general nature and/or source of these conflicts of interest.
A mapping of conflicts of interest has been drawn up- which identifies the circumstances that give rise or may give rise to a conflict of interest. The mapping makes it possible for Carmignac to identify and, if necessary, manage fairly any conflicts of interest that may carrying out its services, between its own interests and those of its clients or between the interests of several clients.
This involves the identification of and monitoring of the following:
This summary has been drawn up in accordance with Regulation (EU) 2019/1156, and is not intended to be an exhaustive list of investor rights. For further details, please refer to the Prospectus, Key Information Document, Articles of Association and/or Management Regulations (hereinafter referred to as the “Fund's legal documentation”) of the relevant fund. (The word “fund” here is defined in the broadest sense as any undertaking for collective investment for which Carmignac Gestion or Carmignac Gestion Luxembourg is the management company)
5.a. Right to information on investments
Investors have the right to receive the following information on the fund:
The fund’s prospectus, KID, KIID and financial reports are available on the website or on request from the Management Company.
The KID, KIID must be made available to the subscriber prior to subscription.
5.b. Right to redeem investments
Redemptions are executed under the conditions and according to the procedures defined in the prospectus. The right of redemption is subject to the condition that all documents required to ensure compliance with anti-money laundering and anti-terrorist financing laws and regulations have been provided.
5.c. Processing of client complaints
Carmignac 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 email to complaints@carmignac.com or by post to :
Carmignac 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.
For France, except in duly justified exceptional circumstances, a response will be issued to the client within two months of receipt of the complaint by Carmignac. 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 www.amf-france.org.
For Luxembourg: In the event of a dispute:
UK investors who raise an expression of dissatisfaction or a complaint to Carmignac UK Ltd, will receive a final response within 8 weeks. If a complainant does not accept the final response and they qualify as an eligible complainant, they can direct their complaint within six months by post or telephone to the Financial Ombudsman Service, Exchange Tower, London E14 9SR or 0800 023 4567.
Further details of eligibility for this service will be provided by Carmignac UK Ltd in its Final Response.
5.d. Cross border complaint
You can also use FIN-NET to submit a cross-border complaint if you live in a member country of the European Economic Area, if you have a complaint against a financial service provider in another member country of the European Economic Area, if you have submitted a complaint but are not satisfied with the response, and if you wish to know which alternative dispute resolution body could resolve the dispute.
To send a complaint to a member of the FIN-NET network, you can contact a FIN-NET member directly and ask for advice. Click here to see contact details for all members in each country.
Lastly, you always retain the right to take legal action.
5.e. If you hold units in a mutual fund (FCP)
The co-owners’ rights are represented by units, with each unit corresponding to the same fraction of the fund’s assets. Each unitholder has a co-ownership right in and to the assets of the fund proportional to the number of units they hold.
5.f. If you hold units of a SICAV/ICAV/OEIC
You are entitled to be called to, attend in person or by proxy, and vote at shareholder meetings.
In accordance with the regulatory requirements of AMF position 2004-07, we hereby inform you that to meet the needs of professional investors subject to the requirements arising from the Directive 2009/138/EC referred to as Solvency II, Carmignac may provide a report, within a deadline of no less than 48 hours with effect from the latest publication of the net asset value, on the composition of its Funds’ portfolio. The information provided shall be strictly confidential and used solely to determine prudential requirements. It may not under any circumstances give rise to prohibited practices such as market timing or late trading by the unitholders that receive this information.
In certain countries, custodians delegate the custody of assets:
Carmignac Gestion’s 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 basis by the Remuneration and Appointments Committee 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.
The Remuneration Policy of Carmignac UK Ltd has been approved by its Board of Directors. The provisions of the Remuneration Policy will be reviewed on a regular basis by the Remuneration and Appointments Committee and are adjusted to fit the changing regulatory framework. The Remuneration Policy includes a description of how remuneration and benefits are calculated.
For more information on the Remuneration and Appointments Committee:
Please click here to access the Research Payment Account Disclosure Form.
The up-to-date information on current share classes is available on the Carmignac website www.carmignac.com or at the registered office of the Management Company.
For any market sounding-related requests, please send an email to marketsounding@carmignac.com. The Compliance and Internal Control Department (“Compliance”) will contact you promptly to follow up on the next steps. Please refrain from contacting any employee of Carmignac directly before liaising with Compliance.
SFDR EU 2019/2088 ARTICLE 4 - Consideration of adverse impacts of investment decisions on sustainability factors.
Carmignac Gestion, as a financial market participant, confirms that it considers principal adverse impacts on sustainability factors (PAIs) in the investment decision as part of the conduct of its activity and as part of the management of financial products. We believe that monitoring and prioritising both the impacts of environmental and social issues on investments decisions and the impact of those investments on environmental and social issues is part of our objectives and duty as a responsible investor.
Full statement on Principal Adverse Impacts of investment decisions on sustainability factors is available here.
SFDR EU 2019/2088 ARTICLE 10 - Sustainability-related information Disclosures
For relevant funds, Carmignac issued specific disclosure documents per fund according to the fact that they promote environmental or social characteristics (“article 8” funds) or that that have sustainable investments as their objective (“article 9” funds).
CARMIGNAC GESTION
24, place Vendôme - F - 75001 Paris
Tel: (+33) 01 42 86 53 35
Portfolio management company approved by the AMF
SA au capital de 13 500 000 € - RCS Paris B 349 501 676
CARMIGNAC GESTION LUXEMBOURG
City Link - 7, rue de la Chapelle - L - 1325 Luxembourg
Tel: (+352) 46 70 60 1
Subsidiary of Carmignac Gestion
CSSF-approved investment fund management company
SA au capital de 23 000 000 € - RCS Luxembourg B67549