Any investment in a fund or any product linked to the fund should only be made after a careful review of the applicable offering documents. Such offering documents generally include – depending on the type of fund, its jurisdiction, regulatory regime (e.g. AIFM or UCITS) and place of distribution – a prospectus, a KIID (Key Investor Information Documents), and the latest annual report (together the “Offering Documents”).
The Offering Documents are available from the website of the management company or fund manager (as applicable) of the fund and upon written request to the address of the management company or fund manager (as applicable).
The purpose of Metori’s website is to provide information on Metori Capital Management, its corporate structure and its investment philosophy. It does not contain information on funds and does not intend to solicit investors on funds. Thus, it does not provide access to the Offering Documents.
As of the current date, Metori is a sub-investment manager of a series of funds managed by Lyxor Asset Management. Potential investors are invited to visit Lyxor’s websites (www.lyxorfunds.com and www.lyxor.com) if they wish to obtain information on such funds, as well as the relevant Offering Documents.
Investment in financial products involves risks. The value of a share or unit in a fund reflects the value of the assets held in the fund’s portfolio and is subject to market fluctuations. Such fluctuations may be amplified if the fund uses leverage. The capital invested in the funds is not guaranteed. Investors may lose the entire invested amounts.
2. REFERENCE INDICATORS
This website may contain certain information (such as, but not limited to, market reports, newsletters, comments and whitepapers) using reference indicators and market indices (together the “Indicators”). Indicators are provided by third-party providers, or calculated by Metori but based on data provided by third-party providers. Such third-party providers are the exclusive owners of their data and calculation rules. Unless stated otherwise, any published value is the closing level of the Indicator.
3. BEST SELECTION AND EXECUTION POLICY
Metori has an obligation to act in the best interests of its clients and of the funds it manages or sub-manages. To this end, the company is subject to an obligation of best selection and best execution, and applies a dedicated procedure.
Financial intermediaries / brokers are selected based on the following criteria, under the supervision of Metori’s investment committee:
– Intermediation / brokerage costs
– Quality and reliability of execution
– Capacity to deal with large orders
– Quality of confirmation flows and back office processes
The fund managers are required to monitor that actual execution flows are in line with the above. Quality is assessed globally and not deal by deal. Intermediaries are rated by the fund managers. Failure to execute, confirm and settle orders within Metori’s quality standards is reported to Metori’s management and the investment committee.
When selecting a new broker, Metori requires that such broker provides its own best execution policy.
When allocating orders, fund managers favour the most competitive brokers (within the list of selected brokers) given the type of order / market they want to trade. But for a given type of order / market, the most competitive broker may not get all trades, since Metori needs to maintain multiple brokerage relationships to (i) create competition on all markets and maintain aggressive pricings and (ii) compare qualities of execution and post-trade service.
4. MANAGEMENT OF CONFLICTS OF INTERESTS
Metori has established an internal policy to manage conflicts of interests. It aims to identify, prevent and manage situations that could potentially go against the interests of our clients, or be a threat to market integrity. If a situation gives rise to a potential conflict of interests, such conflict shall be managed in the best interest of our clients, meaning in a fair manner and by delivering relevant and comprehensive information.
If a situation gives rise to a potential conflict of interest, and depending on the nature of such situation, Metori shall consider the three following actions:
– do the transaction / perform the activity if a proper resolution of potential conflicts is possible;
– if certain conflicts remain, inform clients on the origin and nature of such conflicts;
– whenever conflicts cannot be managed in the best interest of clients, abandon the operation or the activity that gave rise to such conflicts.
To this end, Metori implements procedures to prevent situations giving rise to conflicts of interests, through:
– mapping situations that may give / have given rise to conflicts of interests;
– making its staff aware of best practices;
– implementing internal controls regularly;
– separating functions that may be in conflict;
– keeping transaction records;
– tracking personal transactions and prohibiting non-compliant personal transactions;
– implementing a gift policy with clear limits and obligations to declare.
The following information is made available to clients upon request:
– procedure to manage and prevent conflicts of interests,
– potential situations that may give rise to conflicts of interests,
– record of identified conflicts of interests.
5. VOTING POLICY
For the time being, Metori does not trade equity securities. Thus, it has not established any policy to exercise voting rights.
6. PROCESSING CLIENT COMPLAINTS
Metori implements operational procedures to efficiently process complaints made by its clients, in a timely manner. Any complaint may be sent to the management of Metori by email to firstname.lastname@example.org or by post to METORI CAPITAL MANAGEMENT, 9 rue de la Paix, 75002 Paris, France. Metori will acknowledge receipt within ten working days. Except in duly justified exceptional circumstances, a response will be issued within two months of receipt.
In France, clients are informed that, in addition to the above, they may call upon the AMF Ombudsman’s Office (Ombudsman of the AMF, Autorité des Marchés Financiers, 17 place de la Bourse, 75082 PARIS CEDEX 02, telephone: 01 53 45 60 00). The request form is available on the AMF’s website: http://www.amf-france.org.
7. REMUNERATION POLICY
Metori has established a remuneration policy in compliance with AIFM and UCITS directives. This remuneration policy aims at retaining talents, incentivising staff to contribute to the long-term performance of the company, ensuring that all employees participate to the management of risks and comply with regulations and internal rules. The remuneration policy, as well as fixed and variable compensations, are set by the management board of Metori.
Variable compensations will be determined at the discretion of the management board of Metori, based on both quantitative and qualitative criteria, but not based on any formula. Such criteria will include, for each team and each employee:
– The performance of the funds and mandates managed or advised by Metori, in absolute terms but also relatively to relevant peer groups or benchmarks;
– The overall profitability of the team, net of operational costs attributable to such business line;
– The overall profitability of the company;
– The achievement of objectives assigned to the team / employee;
– The proper management of risks;
– The compliance with internal rules and procedures, codes of good conduct and regulatory obligations.
Part of variable compensations may be differed up to 3 years. Differed compensations will be payable subject to the employee’s being present, to compliance with good practices and risk management policies and to the company’s financial situation.
8. ESG AND SRI POLICIES
General considerations concerning ESG:
Although Metori Capital Management takes environmental, social and governance (ESG) considerations seriously, it does not include ESG criteria in the investment process of the funds it sub-manages. Metori Capital Management reserves the right to modify such investment process in the future, to include ESG criteria.
Communication (media, content and frequency):
This section of the website (“ESG and SRI Policies”) will be used to keep investors and prospective investors informed on how Metori Capital Management intends to include ESG criteria in its investment policy.
Funds concerned by ESG considerations:
As of 21 March 2018, none of the funds sub-managed by Metori Capital Management takes ESG criteria into account in its investment policy.
In November 2017 Metori Capital Management became a signatory to the United Nations Principles of Responsible Investment (more information on www.unpri.org).
9. METORI CAPITAL MANAGEMENT
Metori is a portfolio management company registered in France to manage UCITS, AIF, Managed Accounts (professional investors), to market UCITS/AIFs managed by another manager and to provide investment advisory services.
AMF agreement n° GP-17000002 of 06/02/2017
Société par Actions Simplifiée (SAS) with share capital of € 750,000 – RCS Paris 823 656 541
Registered office: 9, rue de la Paix, 75002 Paris
Chairman (Président): Nicolas Gaussel
General Manager (Directeur Général): Laurent Le Saint
Publication Director: Laurent Le Saint
Tel : +33 (0)1 83 75 00 60
Email : email@example.com