In accordance with the regulations in force, Focus AM has established a conflicts of interest management policy and has taken all reasonable measures to identify conflicts of interest that may arise in the course of providing its investment services to its customers or in the management of UCITS : either on its behalf, people directly or indirectly related to Focus AM by a control relationship, and its customers; or between two clients. Focus AM identifies in advance the conflicts of interest whose existence may affect the interests of a client. Focus AM maintains a register that records the services that have been or may be subject to conflicts of interest which are a prejudice to one or more clients.
All providers of financial investment services are subject to an obligation to act in the best interests of their clients for the execution of orders as the result of investment decisions in the managed portfolios. Within this framework, in its capacity as a management company, and given the characteristics of its business, Focus AM is required to pursue a selection of financial intermediaries which will ensure the best possible result in the execution of orders transmitted on behalf of its UCITS.
Focus AM's voting policy is defined in the document below available for download. Its effects are permanent. The voting policy details the general principles applicable for voting purposes. The management team is the body responsible for deciding how votes are to be cast. The Middle Office is the body responsible for the processing and monitoring of the resolutions submitted. Focus AM's voting policy aims to exclusively focus on the interests of its shareholders. Information concerning the exercise of voting right is available to any UCITS shareholder upon request.