All investment service providers should act in the best interest of their clients when executing orders resulting from investment decisions related to portfolio management.
To this end, in its capacity as an investment manager, Eleva Capital is required to take all reasonable measures to select the intermediaries to which orders are transmitted for execution (brokers and financial counterparties) and whose execution policies guarantee the best possible result when executing orders sent on behalf of the Funds it manages.
In accordance with regulation, Eleva Capital has put in place an Execution Policy. We aim to consistently deliver Best Execution, by executing transactions at the most favourable terms for our clients, after evaluating various execution factors.
Subject to any specific instructions that may be given by clients, when executing orders, we take all reasonable steps to obtain the best possible result taking into account the Execution Factors listed below. We determine the relative importance of these Execution Factors by using our commercial judgment and experience in light of market information available and taking into account our Execution Criteria.
- Price (generally the most significant factor);
- Size and nature of the order;
- Potential market impact;
- Cost of execution commissions;
- Speed at which we can trade
- Liquidity of the market on which we are trading;
- Likelihood of execution and settlement;
- Financial status and responsibility of the counterparty.
Eleva Capital selects counterparties who can deliver Best Execution on the trading venues to which we require access. We constantly monitor the performance of these counterparties, and formally evaluate them every six months. This formal review is based on performance in four key areas:
- Understanding our execution objectives and helping us to reach them.
- Providing timely market information which adds value to our execution performance.
- Sourcing or providing liquidity.
- Adding long-term value to our execution process beyond day-to-day trading (for example advising us regarding regulatory or technological developments).
We also evaluate our counterparties for post-trade efficiency, from the confirmation of trades to settlement. Poor performance in these areas could lead us to suspend trading with them until renewed satisfactory performance can be guaranteed.
The list of key trading counterparties with whom we transact is maintained by the Head of Trading at Eleva Capital and is available to our clients on request. Any new brokers must be approved by Eleva’s Chief Compliance Officer (“CCO”) and added to the list of approved brokers before we can place a trade with them.
Both the Best Selection and Execution Policy are available upon request by Email to: email@example.com
Conflicts of Interests Policy
In accordance with regulation, Eleva Capital has established a conflicts of interest policy to ensure that the Firm takes all reasonable measures necessary to prevent, detect and resolve conflicts of interest arising during the course of providing its business activities.
As a result of its size and the nature of its activities, a mapping of conflicts of interest has been drawn up. This mapping identifies the circumstances that give rise or may give rise to a conflict of interest.
This makes it possible for Eleva Capital to identify and, if necessary, fairly manage any conflicts of interest that may arise in the course of carrying out its services, between its own interests and those of its clients or between the interests of a number of clients.
In cases where Eleva Capital would consider that the deployed measures are not sufficient to guaranty, with a reasonable certainty that the risk of prejudice for its clients can be avoided, the company would inform in writing the affected customers about the nature or the source of the conflict of interests in order for these clients to be able to take their decision knowingly.
Additional information on our Conflicts of Interest Policy can be obtained upon request by Email to: firstname.lastname@example.org
In accordance with regulation, Eleva Capital has established a conflicts of interest policy to ensurethat the Firm takes all reasonable measures necessary to prevent, detect and resolve conflicts ofinterest arising during the course of providing its business activities.As a result of its size and the nature of its activities, a mapping of conflicts of interest has beendrawn up. This mapping identifies the circumstances that give rise or may give rise to a conflict ofinterest.This makes it possible for Eleva Capital to identify and, if necessary, fairly manage any conflicts ofinterest that may arise in the course of carrying out its services, between its own interests and thoseof its clients or between the interests of a number of clients.In cases where Eleva Capital would consider that the deployed measures are not sufficient toguaranty, with a reasonable certainty that the risk of prejudice for its clients can be avoided, thecompany would inform in writing the affected customers about the nature or the source of theconflict of interests in order for these clients to be able to take their decision knowingly.Additional information on our Conflicts of Interest Policy can be obtained upon request by Email to:email@example.comExercise of Voting rights policyIn accordance with regulation, Eleva Capital has established and maintains an active process in
Exercise of Voting rights policy
In accordance with regulation, Eleva Capital has established and maintains an active process in governing its voting policy.
Eleva Capital is committed to evaluating and voting on issues in the best interests of its clients. Should the Firm decide to vote proxy proposals, amendments, consents or resolutions relating to client securities, including interests in private investment funds, if any, (collectively, "proxies"), it will do so in accordance with the following guidelines:
- We will generally support a current management initiative if our view of the Issuer’s management is favourable, and as long as it is in shareholders’ interests;
- We will generally vote to change the management structure of an Issuer if it would increase shareholder value;
- We will generally vote against management if there is a clear conflict between the Issuer’s management and shareholder interest;
- In some cases, even if we support an Issuer’s management, there may be some corporate governance issues that we believes should be subject to shareholder approval; and
- We may abstain from voting proxies when it is determined that the cost of voting the proxy exceeds the expected benefit to our clients or where voting would entail locking up securities for a long period, thereby restricting our freedom to act.
Generally, all proxies are evaluated and voted on a case-by-case basis, considering each of the relevant factors set forth above. Eleva Capital, in all cases, will vote for any proposals that are believed to be most advantageous to our clients.
Conflicts of interest prevention
Internal compliance code and Conflict of interests’ policy define, for all employees, the cases where a conflict of interest situation may arise.
A report is published once a year, within 4 months of the end of each financial year (in accordance with article 314-101 of the RG AMF). This report along with the full version of the policy is also available upon request by Email to: firstname.lastname@example.org
Customer complaints management
Eleva Capital, in accordance with the regulation, has implemented and maintains an operational procedure to quickly and efficiently process complaints made by its clients. Any complaint may be referred to email@example.com or by regular mail at the following address:
Eleva Capital SAS
15 avenue Matignon
Eleva Capital will acknowledge receipt of the complaint within a maximum of ten working days from the date it was received, unless a response has been issued to the client in the intervening period. Except in duly justified exceptional circumstances, a response will be issued to the client within two months of receipt of the complaint.
In the event of an ongoing dispute, the client may contact the AMF Ombudsman at the following address:
Autorité des marchés financiers
Médiateur de l'AMF
17 Place de la Bourse
75082 PARIS CEDEX 02
The AMF mediation request form and the Mediation Charter are available on the AMF website:
- Mediation Charter
- AMF mediation request form
Integration of ESG criteria
In accordance with article L.533-22-1 of the French “Code Monétaire et Financier”, Eleva Capital shall inform investors of the integration of Social, Environmental and Corporate Governance criteria within the investment policy of the company.
As a signatory of the UN Principles for Responsible Investment, the Firm commits to integrating ESG criteria in the investment process. Although the Firm does not manage any dedicated E.S.G Funds the investment team use ESG provider Sustainalytics to monitor quarterly controversy reports and for detailed analysis on corporate governance as part of the investment process. The team may pay pay a special attention to manager’s ethics, financial transparency, information and independency of audit structures on particular investment opportunities.
In accordance with the UCITS Directive, Eleva Capital has implemented a Remuneration Policy compatible with sound and effective risk management applicable to categories of personnel whose professional activities have a material impact on the Risk profile of the UCITS it manages. This policy can be made available upon request by Email to firstname.lastname@example.org