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ECHIQUIER FUND
Subscriptions can only be received on the basis of this prospectus accompanied by the
relevant key information documents, the latest annual report as well as the latest semi-
annual report, if published after the latest annual report.
These reports form part of the present prospectus. No information other than that contained
in this prospectus, in the periodic financial reports, as well as in any other documents
mentioned in the prospectus and which may be consulted by the public, may be given in
connection with the offer.
23 October 2024
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TABLE OF CONTENTS
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REGISTERED OFFICE 60, avenue J.F. Kennedy
L-1855 Luxembourg
Grand Duchy of Luxembourg
Olivier DE BERRANGER
Director
La Financière de l’Echiquier, Chief Investment
Officer
Elsa SCOURY
Director
La Financière de l’Echiquier, Chief Operating Officer
Vincent CORNET
Deputy CEO
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The Prospectus is divided into two Parts. Part A “General Information” aims at
describing the general features of ECHIQUIER FUND. Part B “The Sub-Funds”
aims at describing precisely each sub-fund’s specifics.
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GLOSSARY
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Directive 2009/65/EC Directive 2009/65/EC of the European Parliament and of the
Council of 13 July 2009 on the coordination of laws,
regulations and administrative provisions relating to
undertakings for collective investment in transferable
securities as modified by the Directive 2014/91/EU.
Distressed securities Bond securities rated below “CCC” and above “D” by Standard
& Poor’s or the equivalent by another agency.
EFTA European Free Trade Association.
EUSD or Savings Council Directive 2003/48/EC of 3 June 2003 on taxation of
Directive savings income in the form of interest payments.
FATF Financial Action Task Force on money laundering.
Feeder Sub-Funds Feeder UCITS of funds which qualifies as master UCITS as
defined in the Investment Fund Law.
FFI Foreign Financial Institution.
GIIN Global Intermediary Identification Number.
Hedged Share Certain Class(es) of Shares hedged against currency risk
Class(es) exposure.
Investment Advisor No investment advisor has been appointed.
Investment Fund Law The Luxembourg law of December 17, 2010 related to
undertakings for collective investments.
Investment Manager No investment manager has been appointed.
KID Key Information Document (pursuant to Regulation (EU)
1286/2014 on key information documents for PRIIPs) or Key
Investor Information Document (pursuant to Commission
Regulation (EU) 583/2010 (only for share classes reserved for
professional investors not opting for a KID)) containing
information on each Class of Shares of a Sub-Fund.
Management Company La Financière de l’Echiquier.
Master Fund The sub-fund of the SICAV in which the Feeder Sub-Fund
invests.
Member State Member State of the European Union.
Mémorial The Luxembourg official gazette of law.
Merger A merger of a Sub-Fund or Class of Shares of the Company.
National Commission The independent authority created by the law of 2 August
for Data Protection 2002 on the protection of individuals with regard to the
processing of personal data.
Net Asset Value The Net Asset Value as determined in section 8.
Nominee A company into whose name securities or other properties are
transferred.
OECD Organisation for Economic Co-operation and Development.
OTC Derivative(s) Over the Counter derivative(s) contract(s).
Prospectus The current prospectus, offering document of the Company.
Performance Fee The yearly period during which the performance fee is
Crystallisation calculated and accrued and at the end of which the accrued
Period/Observation performance fee (if any) is paid.
Period
Performance Fee The 5-year period during which the performance is calculated
Reference Period and compared to the index of reference and at the end of
which the Fund is entitled to reset the past negative
performance (or underperformance) recovery mechanism.
Reference Currency The reference currency of the Sub-Funds.
Registrar and BNP Paribas, Luxembourg Branch.
Transfert Agent
RESA Recueil Electronique des Sociétés et Associations.
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RMB Renminbi, the official currency of the People's Republic of
China.
Savings Law The law of 21 June 2005 transposing into Luxembourg law
the Council Directive 2003/48/CE of 3 June 2003 on taxation
of savings income in the form of interest payments.
Shareholder(s) Holder(s) of shares of the Company.
SFDR Regulation (EU) 2019/2088 2088 of the European Parliament
of the Council of 27 November 2019 on sustainability-related
disclosures in the financial services sector.
Sustainable Investment(s) which meets the three criteria, in accordance
Investment(s) with article 2(17) of SFDR:
- the company's activity makes a positive contribution to an -
environmental or social objective,
- it does not cause significant harm to any of these objectives,
and
- the company applies good governance practices.
SICAV Société d’Investissement à Capital Variable.
Sub-Fund(s) A distinctive entity of the Company constituted of assets and
liabilities.
Taxonomy Regulation The Regulation (EU) 2020/852 of the European Parliament and
of the Council of 18 June 2020 on the establishment of a
framework to facilitate sustainable investment, and amending
SFDR.
Total Return Swaps Derivative contract, as defined in point (7) of Article 2 of
(TRS) regulation 648/2012 of 4 July 2012 on OTC Derivatives,
central counterparties and trade repositories, in which
(according to regulation (EU) 2015/2365 of the European
Parliament and of the Council of 25 November 2015 on
transparency of securities financing transactions and of reuse)
one counterparty transfers the total economic performance,
including income from interest and fees, gains and losses from
price movements, and credit losses, of a reference obligation
to another counterparty.
UCI Undertaking for Collective Investment.
UCITS Undertaking for Collective Investment in Transferable
Securities.
US Person (i) a citizen of the United States of America irrespective of
his place of residence or a resident of the United States
of America irrespective of his citizenship;
(ii) a partnership organised or existing in laws of any state,
territory or possession of the United States of America;
(iii) a corporation organised under the laws of the United
States of America or of any state, territory or
possession thereof; or
any estate or trust which are subject to United States tax
regulations.
Valuation Date Date of the Net Asset Value per share of each Class that will
be calculated on the Calculation Day.
VaR approach Value at risk approach: a global risk exposure calculation
method.
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1. INTRODUCTION
The Company constitutes a single legal entity, but the assets of each Sub-Fund are
segregated from those of the other Sub-Fund(s). This means that the assets of each Sub-
Fund shall be invested for the Shareholders of the corresponding Sub-Fund and that the
assets of a specific Sub-Fund are solely accountable for the liabilities, commitments and
obligations of that Sub-Fund.
The main objective of the Company is to provide a range of Sub-Funds combined with active
professional management to diversify investment risk and satisfy the needs of investors
seeking income, capital conservation and longer term capital growth.
The Board of Directors may decide at any time to create new Sub-Funds. At the opening of
such additional Sub-Funds, the Prospectus shall be adapted accordingly.
As of the date of the Prospectus, the following Sub-Funds have been launched within the
Company:
(i) restrict or prevent the ownership of shares in the Company by any physical person
or legal entity;
(ii) restrict the holding of shares in the Company by any physical or corporate person in
order to avoid breach of laws and regulations of a country and/or official regulations
or to avoid that shareholding induces tax liabilities or other financial disadvantages,
which it would otherwise not have incurred or would not incur.
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Shares shall in particular not be offered or sold by the Company to US Person.
As the above-mentioned definition of “US Person” differs from Regulation S of the US
Securities Act of 1933, the Board of Directors of the Company, notwithstanding the fact that
such person or entity may come within any of the categories referred to above, is
empowered to determine, on a case by case basis, whether ownership of shares or
solicitation for ownership of shares shall or shall not be in breach with any securities law of
the United States of America or any state or other jurisdiction thereof.
For further information on restricted or prohibited share ownership, please consult the
Company.
FATCA provisions generally impose a reporting to the U.S. Internal Revenue Service of U.S.
persons’ direct and indirect ownership of non-U.S. accounts and non-U.S. entities. Failure
to provide the requested information will lead to a 30% withholding tax applying to certain
U.S. source income (including dividends and interest) and gross proceeds from the sale or
other disposal of property that can produce U.S. source interest or dividends.
The basic terms of FATCA currently appear to include the Company as a FFI, such that in
order to comply, the Company may require all Shareholders to provide documentary
evidence of their tax residence and all other information deemed necessary to comply with
the above mentioned legislation.
Despite anything else herein contained and as far as permitted by Luxembourg laws, the
Company shall have the right to:
- Withhold any taxes or similar charges that it is legally required to withhold, whether
by law or otherwise, in respect of any shareholding in the Company;
- Require any Shareholder or beneficial owner of the shares to promptly furnish such
personal data as may be required by the Company in its discretion in order to comply
with any law and/or to promptly determine the amount of withholding to be retained;
- Divulge any such personal information to any tax or regulatory authority, as may be
required by law or such authority;
In addition, the Company hereby confirms that it is a participating FFI as laid down in the
FATCA rules and that it is registered and certify compliance with FATCA and obtained a GIIN,
the Company will furthermore only deals with professional financial intermediaries duly
registered with a GIIN.
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2. THE COMPANY
The Company was incorporated for an unlimited period in the Grand Duchy of Luxembourg
on 8 October 2013 as a société anonyme under the Company Law and is organized as a
variable capital company (société d'investissement à capital variable - SICAV) under Part I
of the Investment Fund Law. As such, the Company is registered on the official list of
collective investment undertakings maintained by the Luxembourg regulator.
The capital of the Company shall at all times be equal to the value of the assets of all the
Sub-Funds of the Company.
The minimum capital of the Company must be at least EUR 1,250,000 (one million two
hundred fifty thousand Euro) and must be reached within a period of six (6) months following
the authorisation of the Company. For the purpose of determining the capital of the
Company, the assets attributable to each Sub-Fund, if not expressed in Euro, will be
converted into Euro at the then prevailing exchange rate in Luxembourg. If the capital of
the Company becomes less than two-thirds of the legal minimum, the Directors must submit
the question of the dissolution of the Company to the Annual General Meeting. The meeting
is held without a quorum and decisions are taken by simple majority. If the capital becomes
less than one quarter of the legal minimum, a decision regarding the dissolution of the
Company may be taken by Shareholders representing one quarter of the shares present.
Each such meeting must be convened not later than forty (40) days from the day on which
it appears that the capital has fallen below two-thirds or one quarter of the minimum capital,
as the case may be.
The Articles were published in the Mémorial under number 2597 on 18 October 2013 and
the Company is registered with the Luxembourg Trade and Companies Register under
number B180751. The Articles and amendments thereto, together with the mandatory legal
notice, have been deposited with the Register of the Tribunal d'Arrondissement of
Luxembourg where they are available for inspection and where copies thereof can be
obtained.
The financial year of the Company starts on 1 October and ends on 30 September of each
year. The first financial year started at the launch of the SICAV and ended on
31 December 2013.
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3. THE MANAGEMENT COMPANY
The Directors are responsible for the overall investment policy, objectives and management
of the Company, and for its Sub-Funds.
The Management Company is registered with number 352 045 454 under the Register of
Commerce and Companies of Paris, France. La Financière de l’Echiquier is regulated in
France by the “Autorité des Marchés Financiers”, the financial supervisory authority, and is
authorised under number GP-91004 as a UCITS management company in compliance with
Directive 2009/65/EC. The Management Company has been appointed under a Collective
Portfolio Management Agreement entered into force on 15 October 2013. This Agreement is
for an indefinite period of time and may be terminated by either party with ninety (90) days’
written notice.
As of the date of the Prospectus, the share capital of the Management Company is
EUR 10,005,300. The list of funds managed by the Management Company is available on
the following website: https://www.lfde.com/les-fonds/.
The Management Company shall ensure compliance of the Company with the investment
instructions and is responsible for the implementation of the Company's strategies and
investment policy. The Management Company shall send reports to the Directors on a
quarterly basis and inform each Director without delay of any non-compliance of the
Company with the investment restrictions.
Subject to the conditions set forth by the Directive 2009/65/EC, the Management Company
is authorized to delegate under its responsibility and control, and with consent and under
supervision of the Company and its Board of Directors, part or all of its functions and duties
to third parties.
The Management Company has adhered to the shareholder engagement policy of the LBP
AM group and has delegated the exercise of its voting rights to LBP AM. The shareholder
engagement policy of LBP AM is available on the following website: www.lbpam.com. The
report on the implementation of the shareholder engagement policy is available at:
www.lfde.com.
Management companies are required to define a remuneration policy that is consistent with
sound and effective risk management. This principle is precisely defined in the AIFM Directive
(2011/61/UE, in particular Annex II), the UCITS V Directive (2014/91/EU), as well as in the
French Monetary and Financial Code (Article L. 533-22-2) and the AMF General Regulation
(Article 319-10).
The AMF has also published professional guidelines for investment services providers with a
view to the practical application of legal and regulatory provisions.
Lastly, the remuneration policy complies with Article 5 of the SFDR - Regulation (EU)
2019/2088.
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The Management Company’s remuneration policy is fully compliant with sound and effective
risk management. It does not encourage risk-taking that might be inconsistent with the risk
profiles, regulation or regulatory documents of the UCIs managed by the Management
Company.
The Management Company’s remuneration policy is aligned with the economic strategy,
objectives, values and interests of the Management Company as well as the UCITS it
manages, and includes measures to prevent potential conflicts of interests. The
remuneration policy has been put in place in order to: actively support the strategy and
objectives of the Management Company; promote the competitiveness of the Management
Company on the market in which it operates; ensure its attractiveness and the development
and retention of motivated and qualified employees.
The general principles of the Management Company’s remuneration policy are as follows:
• The fixed component of remuneration takes into account the real situation of the labour
market.
• The principle of equal pay for men and women, including with respect to career
development.
• Each employee undergoes a skills assessment and evaluation process with the definition
of qualitative and quantitative objectives.
• Non-contractual discretionary variable remuneration that rewards employees’
performance. The variable portion is therefore reviewed each year by team and for each
employee.
• The principles of variable remuneration comply with a principle of fairness that aims to
motivate the greatest number of employees.
• Since 2020, the “contribution to the Management Company’s responsible investment
approach” has been a collective objective, set for all the Management Company’s
employees, and is included in determining their annual variable remuneration.
• The Management Company implements a deferred variable remuneration mechanism for
risk takers awarded a variable remuneration of more than €200K; in application of the
UCITS V and AIFM Directives.
Details regarding the compensation policy are available online on the following website:
www.lfde.com or free on request from the Management Company.
For the investment management of the Sub-Funds, the Management Company may, at its
own costs and under its control and supervision, appoint one or more Investment
Manager(s) for providing day-to-day management of the assets of certain Sub-Funds. The
Management Company may further, under the same conditions, appoint Investment
Advisor(s) to provide investment information, recommendations and research concerning
prospective and existing investments. In this case, the Prospectus will be updated
accordingly.
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4. INVESTMENT OBJECTIVES AND POLICY
The investment objective of each Sub-Fund is to provide Shareholders with the opportunity
of achieving long term capital growth and/or capital conservation through investment in
assets within each of the Sub-Funds. The Sub-Funds’ assets will be invested in
conformity with each Sub-Fund’s investment objective and policy as described in
each Sub-Fund’s specifics (section “Investment Objectives and Policy”) in Part B of this
Prospectus. All or part of the Sub-Funds may adopt a feeder investment policy in compliance
with the provisions of the Investment Fund Law, with a view to invest at all times at least
85% of its assets in shares of a Master Fund, as further detailed (where applicable) in the
relevant Sub-Fund's specifics in Part B of this Prospectus.
The investment objective and policy of each Sub-Fund of the Company is determined by the
Directors, after taking into account the political, economic, financial and monetary factors
prevailing in the selected markets.
Whilst using their best endeavours to attain the investment objectives, the Directors cannot
guarantee the extent to which these objectives will be achieved. The value of the shares and
the income from them can fall as well as rise and Shareholders may not realise the value of
their initial investment. Changes in the rates of exchange between currencies may also cause
the value of the shares to diminish or to increase.
I. In the case that the Company comprises more than one Sub-Fund, each Sub-Fund
shall be regarded as a separate UCITS for the purpose of the investment objectives,
policy and restrictions of the Company.
II. 1. The Company, for each Sub-Fund, may invest in only one or more of the following:
a) transferable securities and money market instruments admitted to or dealt in
on a regulated market; for these purposes, a regulated market is any market
for financial instruments within the meaning of Directive 2004/39/EC of the
European Parliament and of the Council of 21 April 2004;
b) transferable securities and money market instruments dealt on another
market in a Member State and in a contracting party to the Agreement on the
European Economic Area that is not a Member State within its limits set forth
and related acts, which is regulated, operates regularly and is recognised and
open to the public;
c) transferable securities and money market instruments admitted to official
listing on a stock exchange in an OECD member country or dealt in on another
market in an OECD member country which is regulated, operates regularly
and is recognised and open to the public, and is established in a country in
Europe, America, Asia, Africa or Oceania;
d) Recently issued transferable securities and money market instruments,
provided that:
- the terms of issue include an undertaking that application will be made for
admission to official listing on a stock exchange or on another regulated
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market which operates regularly and is recognised and open to the public
or markets as defined in the paragraphs a), b), c) above;
- provided that such admission is secured within one year of issue;
e) units of UCITS authorised according to Directive 2009/65/EC and/or other UCI
within the meaning of the first and the second indent of Article 1, paragraph
(2) points a) and b) of the Directive 2009/65/EC, whether or not established
in a Member State, provided that:
- such other UCIs are authorised under laws which provide that they are
subject to supervision considered by the CSSF to be equivalent to that laid
down in EU Community law, and that cooperation between authorities is
sufficiently ensured,
- the level of protection for unitholders in such other UCIs is equivalent to
that provided for unitholders in a UCITS, and in particular that the rules
on assets segregation, borrowing, lending, and uncovered sales of
transferable securities and money market instruments are equivalent to
the requirements of Directive 2009/65/EC,
- the business of such other UCIs is reported in semi-annual and annual
reports to enable an assessment of the assets and liabilities, income and
operations over the reporting period,
- no more than 10% of the assets of the UCITS or of the other UCIs, whose
acquisition is contemplated, can, according to their constitutional
documents, be invested in aggregate in units of other UCITS or other UCIs;
f) deposits with credit institutions which are repayable on demand or have the
right to be withdrawn, and maturing in no more than twelve (12) months,
provided that the credit institution has its registered office in a Member State
or, if the registered office of the credit institution is situated in a third country,
provided that it is subject to prudential rules considered by the CSSF as
equivalent to those laid down in EU Community law;
g) financial derivative instruments, including equivalent cash-settled
instruments, dealt in on a regulated market referred to in subparagraphs a),
b) and c) above, and/or OTC Derivatives, provided that:
- the underlying consists of instruments covered by this paragraph II. of
section 4.2., financial indices, interest rates, foreign exchange rates or
currencies, in which each Sub-Funds may invest according to its
investment objectives;
- the counterparties to OTC derivative transactions are institutions subject
to prudential supervision, and belonging to the categories approved by the
CSSF; and
- the OTC derivatives are subject to reliable and verifiable valuation on a
daily basis and can be sold, liquidated or closed by an offsetting
transaction at any time at their fair value at the Company’s initiative;
h) money market instruments other than those dealt in on a regulated market
and which fall under Article 1 of the Investment Fund Law, if the issue or the
issuer of such instruments are themselves regulated for the purpose of
protecting investors and savings, and provided that such instruments are:
- issued or guaranteed by a central, regional or local authority or by a
central bank of a Member State, the European Central Bank, the European
Union or the European Investment Bank, an OECD member country or, in
case of a Federal State, by one of the members making up the federation,
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or by a public international body to which one or more Member States
belong; or
- issued by an undertaking any securities of which are dealt in on regulated
markets referred to in subparagraphs a), b) or c) above; or
- issued or guaranteed by an establishment subject to prudential
supervision, in accordance with criteria defined by EU Community law, or
by an establishment which is subject to and complies with prudential rules
considered by the CSSF to be at least as stringent as those laid down by
EU Community law; or
- issued by other bodies belonging to the categories approved by the CSSF
provided that investments in such instruments are subject to investor
protection equivalent to that laid down in the first, the second or the third
indent of this sub-paragraph and provided that the issuer is a company
whose capital and reserves amount to at least ten million Euro
(EUR 10,000,000) and which presents and publishes its annual accounts
in accordance with the fourth Directive 78/660/EEC, is an entity which,
within a group of companies including one or several listed companies, is
dedicated to the financing of the group or is an entity which is dedicated
to the financing of securitisation vehicles which benefit from a banking
liquidity line.
2. However:
a) The Company, for each Sub-Fund, shall not invest more than 10% of its assets
in transferable securities or money market instruments other than those
referred to in paragraph 1 above of this paragraph II. of section 4.2.;
b) the Company for each Sub-Fund shall not acquire either precious metals or
certificates representing them.
III. The Company, for each Sub-Fund, may acquire movable and immovable property
which is essential for the direct pursuit of its business.
IV. The Company may hold ancillary liquid assets.
V. a) (i) The Company, for each Sub-Fund, may invest no more than 10% of the
assets of any Sub-Fund in transferable securities or money market
instruments issued by the same body.
(ii) The Company, for each Sub-Fund, may not invest more than 20% of its
assets in deposits made with the same body. The risk exposure to a
counterparty of each Sub-Fund in an OTC derivative transaction may not
exceed 10% of its assets when the counterparty is a credit institution
referred to in paragraph II. f) or 5% of its assets in other cases.
b) The total value of the transferable securities and money market instruments
held by the Company for each Sub-Fund in the issuing bodies in each of which
it invests more than 5% of its assets shall not exceed 40% of the value of its
assets of each Sub-Fund. This limitation does not apply to deposits and OTC
derivative transactions made with financial institutions subject to prudential
supervision.
Notwithstanding the individual limits laid down in paragraph a), the Company,
for each Sub-Fund, shall not combine where this would lead to investing more
than 20% of its assets in a single body, any of the following:
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- deposits made with that body; or
- exposures arising from OTC derivative transactions undertaken with that
body.
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- the index represents an adequate benchmark for the market to which it
refers;
- the index is published in an appropriate manner.
b) The limit laid down in paragraph a) is raised to 35% where that proves to be
justified by exceptional market conditions, in particular on regulated markets
where certain transferable securities or money market instruments are highly
dominant. The investment up to this limit is only permitted for a single issuer.
VII. Notwithstanding the limits set forth under paragraph V., each Sub-
Fund is authorized to invest in accordance with the principle of risk
spreading up to 100% of its assets in different transferable securities
and money market instruments issued or guaranteed by a Member
State, one or more of its local authorities, an OECD member country
or public international bodies of which one or more Member States of
the European Union belong, provided that (i) such securities are part
of at least six different issues and (ii) the securities from a single issue
shall not account for more than 30% of the total assets of the Sub-
Fund.
VIII. a) The Company may not acquire any shares carrying voting rights which would
enable it to exercise significant influence over the management of an issuing
body.
b) Moreover, the Company may acquire no more than:
- 10% of the non-voting shares of the same issuer;
- 10% of the debt securities of the same issuer;
- 25% of the units of the same UCITS and/or other UCI with the meaning
of Article 2 (2) of the Investment Fund Law;
- 10% of the money-market instruments of any single issuer.
These limits laid down under second, third and fourth indents may be
disregarded at the time of acquisition, if at that time the gross amount of the
bonds or of the money market instruments or the net amount of the
instruments in issue cannot be calculated.
c) The provisions of paragraphs (a) and (b) are waived as regards to:
- transferable securities and money market instruments issued or
guaranteed by a Member State or its local authorities;
- transferable securities and money market instruments issued or
guaranteed by an OECD member country;
- transferable securities and money market instruments issued by public
international bodies of which one or more Member States of the European
Union are members;
- shares held by the Company in the capital of a company incorporated in
an OECD member country which invests its assets mainly in the securities
of issuing bodies having their registered office in that State, where under
the legislation of that State, such a holding represents the only way in
which the Company for each Sub-Fund can invest in the securities of
issuing bodies of that State provided that the investment policy of the
company from the OECD member country complies with the limits laid
down in paragraph V., VIII. and IX. Where the limits set in paragraph V
and IX are exceeded, paragraph XI a) and b) shall apply mutatis mutandis;
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- shares held by one or more investment companies in the capital of
subsidiary companies carry on the business of management, advice or
marketing in the country where the subsidiary is established, in regard to
the redemption of units at the request of unitholders exclusively on its or
their behalf.
IX. a) The Company may acquire the units of the UCITS and/or other UCIs referred
to in paragraph II. e), provided that no more than 20% of a Sub-Fund's assets
be invested in the units of a single UCITS or other UCI.
For the purpose of the application of this investment limit, each compartment
of a UCI with multiple compartments is to be considered as a separate issuer
provided that the principle of segregation of the obligations of the various
compartments vis-à-vis third parties is ensured.
b) Investments made in units of UCIs other than UCITS may not in aggregate
exceed 30% of the assets of each Sub-Fund.
When a Sub-Fund has acquired units of UCITS and/or other UCIs, the assets
of the respective UCITS or other UCIs do not have to be combined for the
purposes of the limits laid down in paragraph V.
c) When a Sub-Fund invests in the units of other UCITS and/or other UCIs that
are managed, directly or by delegation, by the same management company or
by any other company with which the management company is linked by
common management or control, or by a substantial direct or indirect holding,
that management company or other company may not charge subscription or
redemption fees on account of the Companies' investment in the units of such
other UCITS and/or UCIs.
The Company for each Sub-Fund that invests a substantial proportion of its
assets in other UCITS and/or other UCIs will disclose in this prospectus the
maximum level of the management fees that may be charged both to the
UCITS itself and to the other UCITS and/or other UCIs in which it intends to
invest.
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The exposure is calculated taking into account the current value of the underlying
assets, the counterparty risk, foreseeable market movements and the time available
to liquidate the positions. This shall also apply to the following subparagraphs.
If the Company invests in financial derivative instruments, the exposure to the
underlying assets may not exceed in aggregate the investment limits laid down in
paragraph V above. When the Company invests in index-based financial derivative
instruments, these investments do not have to be combined to the limits laid down
in paragraph V.
When a transferable security or money market instrument embeds a derivative, the
latter must be taken into account when complying with the requirements of this
paragraph X.
The global exposure may be calculated through the Value-at-Risk approach or the
Commitment approach as described in each Sub-Fund in Part B of this Prospectus.
The purpose of the VaR approach is the quantification of the maximum potential
loss that could arise over a given time interval under normal market conditions and
at a given confidence level. A confidence level of 99% with a time horizon of one
month is foreseen by the Investment Fund Law.
The Commitment Approach performs the conversion of the financial derivatives into
the equivalent positions in the underlying assets of those derivatives. By calculating
global exposure, methodologies for netting and hedging arrangements and the
principles may be respected as well as the use of efficient portfolio management
techniques.
Unless described differently in each Sub-Fund in Part B, each Sub-Fund will ensure
that its global exposure to financial derivative instruments computed on a VaR
approach does not exceed either (i) 200% of the reference portfolio (benchmark) or
(ii) 20% of the total assets or that the global exposure computed based on a
commitment basis does not exceed 100% of its total assets.
To ensure the compliance of the above provisions the Management Company will
apply any relevant circular or regulation issued by the CSSF or any European
authority authorised to issue related regulation or technical standards.
XI. a) The Company for each Sub-Fund does not need to comply with the limits laid
down in section 4.2 when exercising subscription rights attaching to
transferable securities or money market instruments which form part of its
assets. While ensuring observance of the principle of risk spreading, recently
created Sub-Funds may derogate from paragraphs V., VI., VII. and IX. for a
period of six months following the date of their authorisation.
b) If the limits referred to in paragraph XI. a) are exceeded for reasons beyond
the control of the Company or as a result of the exercise of subscription rights,
it must adopt as a priority objective for its sales transactions the remedying
of that situation, taking due account of the interest of its shareholders.
XII. 1. The Management Company on behalf of the Company may not borrow.
However, the Company may acquire foreign currency by means of a back-to-back
loan for each Sub-Fund.
2. By way of derogation from paragraph XII.1., the Company may borrow provided
that such a borrowing is:
a) on a temporary basis and represents no more than 10% of their assets;
b) to enable the acquisition of immovable property essential for the direct pursuit
of its business and represents no more than 10% of its assets.
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The borrowings under points XII. 2. a) and b) shall not exceed 15% of its assets in
total.
XIII. A Sub-Fund may, subject to the conditions provided for in the Articles as well as this
Prospectus, subscribe, acquire and/or hold securities to be issued or issued by one
or more Sub-Funds of the Company under the condition that:
- the target Sub-Fund does not, in turn, invest in the Sub-Fund invested in this
target Sub-Fund;
- no more than 10% of the assets of the target Sub-Fund whose acquisition is
contemplated may, pursuant to the Articles, be invested in aggregate in
shares/units of other target Sub-Funds of the same fund; and
- voting rights, if any, attaching to the relevant securities, are suspended for as
long as they are held by the Sub-Fund concerned and without prejudice to the
appropriate processing in the accounts and the periodic reports; and
- in any event, for as long as these securities are held by the Company, their
value will not be taken into consideration of the calculation of the assets of the
Company for the purposes of verifying the minimum threshold of the assets
imposed by the Investment Fund Law; and
- there is no duplication of subscription or repurchase fees between those at the
level of the Sub-Fund of the Company having invested in the target Sub-Fund,
and this target Sub-Fund.
XIV. A Sub-Fund may invest in Ancillary liquid assets pursuant to article 41 (2) b) of the
Investment Fund Law. In exceptional circumstances and in the best interest of the
Sub-Fund’s Shareholders, the Sub-Funds may however temporarily invest up to
100% of their assets in bank deposits at sight for a period of time strictly necessary
when, because of exceptionally unfavourable market conditions, circumstances so
require and where such breach is justified having regard to the interests of the
investors.
4.3 Securities lending, sale with right of repurchase transactions, repurchase and reverse
repurchase agreement transactions and total return swaps.
The Company will not, within the limits and under the conditions of CSSF Circular 14/592 on
ESMA guidelines on ETFs and other UCITS issues and of Regulation (EU) No 2015/2365 of
25 November 2015 on transparency of securities financing transactions and of reuse
(“Regulation 2015/2365”), enter into securities lending transactions, repurchase and reverse
repurchase agreements transactions, margin lending transactions, buy-sell back and sell-
buy back transactions or total return swaps, except otherwise stated in the Sub-Fund’s
specifics in Part B of the Prospectus.
If case of use of such efficient portfolio management techniques, the Company will ensure
the following:
• That the risks arising from these activities are adequately captured by the risk
management process of the Company.
• That the techniques and instruments relating to transferable securities and money
market instruments should not:
a) result in a change of the declared investment objective of the Company; or
b) add substantial supplementary risks in comparison to the original risk policy as
described in its sales documents.
• That the Prospectus mentions:
a) the policy regarding direct and indirect operational costs/fees arising from efficient
portfolio management techniques that may be deducted from the revenue delivered
to the Company, these fees not including hidden revenue; and
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a) the identity of the entity(ies) to which the direct and indirect costs and fees are paid
and the indication of their relation with the Management Company or the Depositary.
• That all revenues arising from efficient portfolio management techniques, net of direct
and indirect operational costs, should be returned to the Company.
• That it is able at any time to recall any security that has been lent out or terminate any
securities lending agreement into which it has entered.
• That, when it enters into a reverse repurchase agreement, it is able at any time to recall
the full amount of cash or to terminate the reverse repurchase agreement on either an
accrued basis or a mark-to-market basis.
• That, when it enters into a repurchase agreement, it is able at any time to recall any
securities subject to the repurchase agreement or to terminate the repurchase
agreement into which it has entered.
If case of use of total return swaps or other financial derivative instruments with the same
characteristics, the Company will insert in its Prospectus the following:
• information on the underlying strategy and composition of the investment portfolio or
index;
• information on the counterparty(ies) of the transactions;
• a description of the risk of counterparty default and the effect on investor returns;
• the extent to which the counterparty assumes any discretion over the composition or
management of the Company’s investment portfolio or over the underlying of the
financial derivative instruments, and whether the approval of the counterparty is
required in relation to any Company investment portfolio transaction; and
• the identification of the counterparty being considered as an investment manager.
4.4 Management of collateral for OTC financial derivative transactions and efficient
portfolio management techniques
In case of entering into OTC financial derivative transactions and efficient portfolio
management techniques, the Company will ensure that all collateral used to reduce
counterparty risk exposure should comply with the following criteria at all times:
a) Liquidity – any collateral received other than cash should be highly liquid and traded on
a regulated market or multilateral trading facility with transparent pricing in order that it
can be sold quickly at a price that is close to pre-sale valuation. Collateral received should
also comply with the provisions of Article 56 of the Directive 2009/65/EC.
b) Valuation – collateral received should be valued on at least a daily basis and assets that
exhibit high price volatility should not be accepted as collateral unless suitably conservative
haircuts are in place.
f) Risks linked to the management of collateral, such as operational and legal risks, should
be identified, managed and mitigated by the risk management process.
g) Where there is a title transfer, the collateral received should be held by the Depositary.
For other types of collateral arrangement, the collateral can be held by a third-party
custodian which is subject to prudential supervision, and which is unrelated to the provider
of the collateral.
h) Collateral received should be capable of being fully enforced by the Company at any time
without reference to or approval from the counterparty.
In that case, the Company will put in place a clear haircut policy adapted for each class of
assets received as collateral; and when devising the haircut policy, the Company will take
into account the characteristics of the assets such as the credit standing or the price
volatility, as well as the outcome of the stress tests. The Company will ensure that this policy
is documented and justify each decision to apply a specific haircut, or to refrain from
applying any haircut, to a certain class of assets.
All or part of the Sub-Funds of the Company may be feeder UCITS of funds which qualifies
as master UCITS (the “Master Fund”) as defined in the Investment Fund Law (these Sub-
Funds will be referred hereunder as “Feeder Sub-Fund(s)”). In compliance with the
relevant provisions of the Investment Fund Law, a Feeder Sub-Fund will at all times invest
at least 85% of its assets in shares of a Master Fund. Any Feeder Sub-Fund may hold up
to 15% of its assets in Ancillary liquid assets in accordance with the provisions of Article 41
(2) of the Investment Fund Law.
To be eligible, any Master Fund must at all times (i) have at least one feeder UCITS among
its shareholders, (ii) not itself become a feeder UCITS, and (iii) not hold shares or units of
a feeder UCITS in accordance with Directive 2009/65/EC. The Sub-Fund’s specifics in Part
B of the Prospectus will contain information on investment objective and policy of the
relevant Master Fund of the Feeder Sub-Funds of the Company.
Valuation Date for shares of the Feeder Sub-Funds will correspond to dealing days for
shares of the relevant Master Fund. Similarly, the respective dealing cut-off times for the
Feeder Sub-Funds and the relevant Master Fund are set so that valid subscription or
redemption orders for Shares of the Feeder Sub-Fund placed before the cut-off time can then
22
be reflected in the Feeder Sub-Fund's investment into the Master Fund. Accordingly,
valuation points for the Feeder Sub-Funds and the relevant Master Fund must also be
coordinated, as each Feeder Sub-Fund's investments into their respective Master Fund will
be valued at the latest available net asset value per share as published by the Master Fund.
(a) The Management Company shall establish internal conduct of business rules describing,
especially, the appropriate measures to mitigate conflicts of interest that may
arise between the Feeder Sub-Funds and the Master Fund, the basis of investment
and divestment by the Feeder Sub-Funds, standard dealing arrangements, events
affecting dealing arrangements and standard arrangements for the audit report.
These internal rules are available on the website of the Management Company
at http://www.lfde.com/informations-reglementaires/ and include, in particular,
rules regarding the conflicts of interests, principles applying to the transfers made
by the Company, provisions governing the negotiation and provisions related to the
audit report. Additional information regarding these internal rules can be obtained
free of charge upon request made to the Management Company.
(b) The Depositary and the depositary of each of the Master Fund must enter into an
agreement in order to share information regarding the Master Funds. This
agreement describes, especially, the documents and categories of information to
be routinely shared between both depositaries or available upon request, the
manner and timing of transmission, the coordination of involvement of each
depositary in operational matters in view of their duties under their respective
national law, the coordination of accounting year-end procedures, reportable
breaches committed by the Master Funds, the procedure for ad hoc requests for
assistance, and particular contingent events reportable on ad hoc basis.
(c) The Auditor of the Company and the auditors of each of the Master Funds must
enter into an Information Exchange Agreement in order to share information
regarding the Master Fund. This agreement describes, especially, the documents
and categories of information to be routinely shared between auditors or available
upon request, the manner and timing of transmission of information, the
coordination of involvement of each auditor in accounting year-end procedures of
the Feeder Sub-Funds and the Master Funds, reportable irregularities identified in
the Master Funds and standard arrangements for ad hoc requests for assistance.
Each Feeder Sub-Fund is invested in specific shares of the Master Fund. The fees, charges
and expenses of those specific shares of Master Fund associated with such investment
are described in the Master Fund prospectus and details on the actual charges and
expenses incurred at the level of the Master Fund are available on the website of the
Management Company at www.lfde.com.
Please refer to the section on "Fees and Expenses" in Part B of the Prospectus for additional
information on fees and expenses payable by the Feeder Sub-Funds. The Key Information
for Investors Documents issued for each Sub-Fund and Class of shares also contain
additional information on ongoing charges incurred by the Feeder Sub-Funds (aggregated
with the charges incurred at the level of the Master Fund).
If and to the extent that voting rights attached to shares of the Master Fund will be
exercised on behalf of the Feeder Sub-Fund, a summary description of the strategies
followed in the exercise of such rights, as well as the actions taken on the basis of those
23
strategies, will be made available to investors upon their specific request addressed to the
Management Company.
It is intended that the performance of the various Classes of shares offered by the Feeder
Sub-Fund will be similar to that of the corresponding classes of shares of the Master Fund.
However, the performance of both funds will not be equal due, in particular, to costs
and expenses incurred by the Feeder Sub-Fund and if the Reference Currency of the Feeder
Sub-Fund differs from that of the Master Fund.
The objective of SFDR is to harmonise transparency rules with regards the integration of
sustainability risks and the consideration of adverse sustainability impacts in the Sub-Funds’
investment management processes and the provision of sustainability-related information.
Sustainability Risks (e.g. climate change, health and safety, companies with breach issues
such as serious criminal penalties, etc) may represent a risk of its own and / or have an
impact on other Sub-Funds’ risks. Sustainability Risks may significantly contribute to the
increase of the Sub-Fund’s risks, such as market risks, credit risks and liquidity risks while
negatively impacting the value and/or the return of the Sub-Funds.
The Sub-Funds, which comply with ESG criteria, systematically integrate environmental,
social and governance criteria into financial management.
The ESG scoring is done on a scale of up to 10 (being a maximum) and is assigned to each
issuer. It is composed as follows:
• Environment and Social: Social and environmental criteria are brought together in
a responsibility note. The calculation of this takes into account the type of company
concerned:
1. For industrial values: social and environmental criteria are equally weighted in the
responsibility note.
2. For service values: the “Social” scoring contributes 2/3 in the “Responsibility” scoring
while the “Environment” scoring represents 1/3 of the “Responsibility” scoring.
Additionally, the SRI Sub-Funds (i.e. ECHIQUIER AGENOR SRI MID CAP EUROPE FUND,
ECHIQUIER ARTY SRI FUND and ECHIQUIER MAJOR SRI GROWTH EUROPE FUND) must also
comply with a minimum ESG scoring as indicated in their respective investment policy. These
ESG scoring are binding and determined by the Management Company and applied to the
entire direct underlying portfolio, thus excluding derivatives and units/shares held by any of
the sub-funds in other investment vehicles. In the event that a company sees its ESG scoring
24
drop below the minimum required by the Management Company for the relevant sub-funds
/ fund, the position on the issuer will be sold in the best interest of the Shareholders.
The ESG data sources used to assess and monitor the sustainability risks are mainly
companies’ public information, direct engagement with companies, financial press as well as
external ESG data providers (if need be).
The limits to achieving these sustainability risks and ESG criteria objectives include the
potential inconsistencies between the ESG strategies of the securities of global companies
(e.g. different criteria, approaches, constraints, etc) and the accuracy, completeness and
availability of ESG data sources.
As a conclusion, this approach has an impact on the selection of securities in these Sub-
Funds.
Finally, the Management Company takes into account the principal adverse sustainability
impacts indicators in its investment decisions.
Further to the entry into force of EU Regulation 2022/1288 dated 6 April 2022
supplementing SFDR with regard to regulatory technical standards specifying the
details of the content and presentation of the information in relation to the
principle of ‘do no significant harm’, specifying the content, methodologies and
presentation of information in relation to sustainability indicators and adverse
sustainability impacts, and the content and presentation of the information in
relation to the promotion of environmental or social characteristics and
sustainable investment objectives in precontractual documents, on websites and
in periodic reports, Shareholders are informed about the environmental or social
characteristics available in “Part C” of this Prospectus.
For more detailed information on the ESG scoring methodology implemented in the relevant
sub-funds / fund, investors are invited to refer to the La Financière de l'Echiquier
Transparency Code available on the website https://www.lfde.com/en/responsible-
investment/to-find-out-more/.
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5. RISK FACTORS
The Management Company applies a risk management process which enables it to monitor
and measure at any time the risk of the positions and their contribution to the overall risk
profile of the portfolio as described in point X of section 4.2 of Chapter 4 “Investment
Objectives and Policies” and further detailed in each Sub-Fund’s specifics in Part B of this
Prospectus.
The investments of each Sub-Fund are subject to market fluctuations and the risks inherent
to investments in transferable securities and other eligible assets. There is no guarantee
that the investment-return objective will be achieved. The value of investments and the
income they generate may go down as well as up and it is possible that investors will not
recover their initial investment. An investment may also be affected by any changes in
exchange control regulation, tax laws, withholding taxes and economic or monetary policies.
Investors should be aware of the risks inherent to the following instruments or investment
objectives, although this list is in no way exhaustive:
Market risk is the general risk attendant to all investments that the value of a particular
investment will change in a way detrimental to a portfolio's interest.
The market risk may be further affected by sustainability risks. The value of the
relevant Sub-Fund’s investments may therefore be negatively impacted or exacerbated
in case of occurrence of a sustainability risk (e.g. ESG issues, climate change, natural
disaster, pandemics, etc).
The value of all Sub-Funds that invest in equity and equity related securities will be
affected by economic, political, market, sustainability and issuer specific changes. Such
changes may adversely affect securities, regardless of company specific performance.
Additionally, different industries, financial markets, and securities can react differently
to these changes. Such fluctuations of the Sub-Fund’s value are often exacerbated in
the short-term as well. The risk that one or more companies in a Sub-Fund’s portfolio
will fall, or fail to rise, can adversely affect the overall portfolio performance in any
given period.
26
(iii) Interest rate risk
Interest rate risk involves the risk that when interest rates decline, the market value
of fixed-income securities tends to increase. Conversely, when interest rates increase,
the market value of fixed-income securities tends to decline. Long-term fixed-income
securities will normally have more price volatility because of this risk than short-term
fixed-income securities. A rise in interest rates generally can be expected to depress
the value of the Sub-Funds’ investments. The Sub-Fund shall be actively managed to
mitigate market risk, but it is not guaranteed to be able to accomplish its objective at
any given period.
Credit risk involves the risk that an issuer of a bond (or similar money-market
instruments) held by the Company may default on its obligations to pay interest and
repay principal and the Company will not recover its investment. The credit risk may
be further affected by sustainability risks. The risk of default of a counterpart may
therefore be negatively impacted or exacerbated in case of occurrence of a
sustainability risk (e.g. ESG issues, climate change, natural disaster, pandemics, etc).
The Sub-Funds will be subject to the risk of the inability of any counterparty (including
the Depositary and Clearing Brokers) who to perform with respect to transactions,
whether due to its own insolvency or that of others, bankruptcy, market illiquidity or
disruption or other causes and whether resulting from systemic or other reasons.
Currency risk involves the risk that the value of an investment denominated in
currencies other than the Reference Currency of a Sub-Fund may be affected
favourably or unfavourably by fluctuations in currency rates.
There is a risk that the Company will not be able to pay repurchase proceeds within
the time period stated in the Prospectus, because of unusual market conditions, an
unusually high volume of repurchase requests, or other reasons. The liquidity risk may
be further affected by sustainability risks. The liquidity of the Fund may therefore be
negatively impacted or exacerbated in case of occurrence of a sustainability risk (e.g.
ESG issues, climate change, natural disaster, pandemics, etc).
The Sub-Funds may engage, within the limits established in their respective
investment policy and the legal investment restrictions, in various portfolio strategies
involving the use of derivative instruments for hedging or efficient portfolio
management purposes.
The use of such derivative instruments may or may not achieve its intended objective
and involves additional risks inherent to these instruments and techniques.
In case of a trading purpose of such transactions, the assets held in portfolio will not
necessarily secure the derivative. In essence the Sub-Funds are therefore exposed to
additional market risk in case of option writing or short forward/future positions (i.e.
underlying needs to be provided/ purchased at exercise/maturity of contract).
Furthermore the Sub-Funds incur amplified risks due to the specificities of the structure
of such derivative products (e.g. volatility of underlying, counterparty risk in case of
OTC, market liquidity, etc.).
Investors should note that certain Sub-Funds may invest in less developed or emerging
markets as described in the Sub-Funds’ specifics in Part B of this Prospectus. Investing
in emerging markets may carry a higher risk than investing in developed markets.
The securities markets of less developed or emerging markets are generally smaller,
less developed, less liquid and more volatile than the securities markets of developed
markets. The risk of significant fluctuations in the Net Asset Value (as defined in
section 7 of Part A of this Prospectus) and of the suspension of redemptions in those
Sub-Funds may be higher than for Sub-Funds investing in major markets. In addition,
there may be a higher than usual risk of political, economic, social and religious
instability and adverse changes in government regulations and laws in less developed
or emerging markets, which could affect the investments in those countries. The assets
of Sub-Funds investing in such markets, as well as the income derived from the Sub-
Fund, may also be effected unfavourably by fluctuations in currency rates and
exchange control and tax regulations and consequently the Net Asset Value of shares
of these Sub-Funds may be subject to significant volatility. Some of these markets
may not be subject to accounting, auditing and financial reporting standards and
practices comparable to those of more developed countries and the securities markets
of such markets may be subject to unexpected closure. In addition, there may be less
government supervision, legal regulation and less well defined tax laws and procedures
than in countries with more developed securities markets.
Moreover, settlement systems in emerging markets may be less well organised than
in developed markets. Thus there may be a risk that settlement may be delayed and
that cash or securities of the concerned Sub-Funds may be in jeopardy because of
failures or of defects in the systems. In particular, market practice may require that
payment shall be made prior to receipt of the security which is being purchased or that
delivery of a security must be made before payment is received. In such cases, default
by a broker or bank through whom the relevant transaction is effected might result in
a loss being suffered by the Sub-Funds investing in emerging market securities.
The Company will seek, where possible to use Counterparties whose financial status is
such that this risk is reduced. However, there can be no certainty that the Company
will be successful in eliminating this risk for the Sub-Funds, particularly as
Counterparties operating in emerging markets frequently lack the substance or
financial resources of those in developed countries.
28
schemes may be non-existent or limited or inadequate to meet the Company’s claims
in any of these events.
The Stock Connect is subject to quota limitations on investment, which may restrict the Sub-
Fund’s ability to invest through the Stock Connect on a timely basis, and the Sub-Funds may
not be able to effectively pursue their investment policies.
Suspension risk
Both SEHK and SSE reserve the right to suspend trading if necessary for ensuring an orderly
and fair market and managing risks prudently which would adversely affect the Sub-Fund’s
ability to access the PRC market.
The Stock Connect operates on days when both the PRC and Hong Kong markets are open
for trading and when banks in both markets are open on the corresponding settlement days.
So it is possible that there are occasions when it is a normal trading day for the PRC market
but Hong Kong investors cannot carry out any trading. The Sub-Funds may be subject to a
risk of price fluctuations during the time when the Stock Connect is not trading as a result.
PRC regulations require that before an investor sells any share, there should be sufficient
shares in the account; otherwise SSE will reject the sell order concerned. SEHK will carry
out pre-trade checking on sell orders of its participants (i.e. the stock brokers) to ensure
there is no over-selling.
The Hong Kong Securities Clearing Company Limited, a wholly-owned subsidiary of HKEx
(the “HKSCC”) and ChinaClear establish the clearing links and each is a participant of each
other to facilitate clearing and settlement of cross-boundary trades. As the national central
counterparty of the PRC’s securities market, ChinaClear operates a comprehensive network
of clearing, settlement and stock holding infrastructure. ChinaClear has established a risk
management framework and measures that are approved and supervised by the CSRC. The
chances of ChinaClear default are considered to be remote. Should the remote event of
ChinaClear default occur and ChinaClear be declared as a defaulter, HKSCC will in good faith,
seek recovery of the outstanding stocks and monies from ChinaClear through available legal
channels or through ChinaClear’s liquidation. In that event, the Sub-Fund may suffer delay
in the recovery process or may not be able to fully recover its losses from ChinaClear.
Shares traded through Shenzhen-Hong Kong or Shanghai-Hong Kong Stock Connect are
issued in scripless form, so investors such as the Sub-Funds will not hold any physical shares.
Hong Kong and overseas investors, such as the Sub-Funds, who have acquired SSE
Securities through Northbound trading should maintain the SSE Securities with their brokers’
or depositaries’ stock accounts with the Central Clearing and Settlement System operated
by HKSCC for the clearing securities listed or traded on SEHK. Further information on the
custody set-up relating to the Stock Connect is available upon request at the registered
office of the Management Company.
29
Operational risk
The Stock Connect provides a new channel for investors from Hong Kong and overseas, such
as the Sub-Fund, to access the China stock market directly. The Stock Connect is premised
on the functioning of the operational systems of the relevant market participants. Market
participants are able to participate in this program subject to meeting certain information
technology capability, risk management and other requirements as may be specified by the
relevant exchange and/or clearing house.
It should be appreciated that the securities regimes and legal systems of the two markets
differ significantly and in order for the trial program to operate, market participants may
need to address issues arising from the differences on an on-going basis.
Further, the “connectivity” in the Stock Connect program requires routing of orders across
the border. This requires the development of new information technology systems on the
part of the SEHK and exchange participants (i.e. a new order routing system (“China Stock
Connect System”) to be set up by SEHK to which exchange participants need to connect).
There is no assurance that the systems of the SEHK and market participants will function
properly or will continue to be adapted to changes and developments in both markets. In
the event that the relevant systems failed to function properly, trading in both markets
through the program could be disrupted. The Sub-Fund’s ability to access the A-share
market (and hence to pursue their investment strategy) will be adversely affected.
HKSCC is the “nominee holder” of the SSE securities acquired by overseas investors
(including the Sub-Fund) through the Stock Connect. The CSRC Stock Connect rules
expressly provide that investors enjoy the rights and benefits of the SSE securities acquired
through the Stock Connect in accordance with applicable laws. However, the courts in the
PRC may consider that any nominee or depositary as registered holder of SSE securities
would have full ownership thereof, and that even if the concept of beneficial owner is
recognized under PRC law those SSE securities would form part of the pool of assets of such
entity available for distribution to creditors of such entities and/or that a beneficial owner
may have no rights whatsoever in respect thereof. Consequently, the Sub-Funds and the
Depositary cannot ensure that the Sub-Fund’s ownership of these securities or title thereto
is assured in all circumstances.
Under the rules of the Central Clearing and Settlement System operated by HKSCC for the
clearing of securities listed or traded on SEHK, HKSCC as nominee holder shall have no
obligation to take any legal action or court proceeding to enforce any rights on behalf of the
investors in respect of the SSE securities in the PRC or elsewhere. Therefore, although the
relevant Sub-Fund’s ownership may be ultimately recognised, the Sub-Fund may suffer
difficulties or delays in enforcing their rights.
To the extent that HKSCC is deemed to be performing safekeeping functions with respect to
assets held through it, it should be noted that the Depositary and the Sub-Funds will have
no legal relationship with HKSCC and no direct legal recourse against HKSCC in the event
that the Sub-Fund suffers losses resulting from the performance or insolvency of HKSCC.
Where securities are held in custody on a cross-border basis, there are specific
legal/beneficial ownership risks linked to compulsory requirements of the local central
securities depositaries, HKSCC and ChinaClear. As in other emerging markets, the only
30
legislative framework is only beginning to develop the concept of legal/formal ownership and
of beneficial ownership and of beneficial ownership or interest in securities.
To the extent that HKSCC is deemed to be performing safekeeping functions with respect to
assets held through it, it should be noted that the Depositary and the Sub-Funds will have
no legal relationship with HKSCC and no legal direct recourse against HKSCC in the event
that the Sub-Funds suffer losses resulting from the performance or insolvency of HKSCC.
In the event ChinaClear defaults, HKSCC’s liabilities under its market contracts with clearing
participants will be limited to assisting clearing participants with claims. HKSCC will act in
good faith to seek recovery of the outstanding stocks and monies from ChinaClear through
available legal channels of the liquidation of ChinaClear. In this event, the Sub-Funds may
not fully recover their losses or their China Hong-Kong Stock Connect Programmes securities
and the process of recovery could also be delayed.
Investor compensation
Investments of the Sub-Funds through Northbound trading under the Stock Connect will not
be covered by Hong Kong’s Investor Compensation Fund. Hong Kong’s Investor
Compensation Fund is established to pay compensation to investors of any nationality who
suffer pecuniary losses as a result of default of a licensed intermediary or authorised financial
institution in relation to exchange-traded products in Hong Kong.
Since default matters in Northbound trading via the Stock Connect do not involve products
listed or traded in SEHK or Hong Kong Futures Exchange Limited, they will not be covered
by the Investor Compensation Fund. On the other hand, since the Sub-Fund is carrying out
Northbound trading through securities brokers in Hong Kong but not PRC brokers, therefore
they are not protected by the China Securities Investor Protection Fund in the PRC.
Trading costs
In addition to paying trading fees and stamp duties, the Sub-Funds may be subject to new
portfolio fees, dividend tax and tax concerned with income arising from stock transfers,
which are yet to be determined by the relevant authorities.
Regulatory risk
The CSRC Stock Connect rules are departmental regulations having legal effect in the PRC.
However, the application of such rules is untested, and there is no assurance that PRC courts
will recognize such rules, e.g. in liquidation proceedings of PRC companies. The Stock
Connect is novel in nature, and is subject to regulations promulgated by regulatory
authorities and implementation rules made by the stock exchanges in the PRC and Hong
Kong. Further, new regulations may be promulgated from time to time by the regulators in
connection with operations and cross-border legal enforcement in connection with cross-
border trades under the Stock Connect. The regulations are untested so far and there is no
certainty as to how they will be applied. Moreover, the current regulations are subject to
change. There can be no assurance that the Stock Connect will not be abolished. The Sub-
Funds, which may invest in the PRC markets through the Stock Connect may be adversely
affected as a result of such changes.
Since 1994, the conversion of onshore Renminbi CNY into other currencies has been based
on rates set by the People’s Bank of China, which are set daily based on the previous day’s
PRC interbank foreign exchange market rate. On July 21, 2005, the PRC government
introduced a managed floating exchange rate system to allow the value of CNY to fluctuate
31
within a regulated band based on market supply and demand and by reference to a basket
of currencies. There can be no assurance that the CNY exchange rate will not fluctuate widely
against any foreign currency in the future.
While both onshore Renminbi (“CNY”) and offshore Renminbi (“CNH”) are the same
currency, they are traded in different and separated markets. CNY and CNH are traded at
different rates and their movement may not be in the same direction. Although there has
been a growing amount of Renminbi held offshore (i.e. outside the PRC), CNH cannot be
freely remitted into the PRC and is subject to certain restrictions, and vice versa. Investors
should note that subscriptions and redemptions will be in USD and will be converted to/from
CNH and the investors will bear the forex expenses associated with such conversion and the
risk of a potential difference between the CNY and CNH rates. The liquidity and trading price
of the Sub-Fund may also be adversely affected by the rate and liquidity of the Renminbi
outside the PRC.
The Sub-Funds may invest in securities in respect of which the PRC imposes limitations or
restrictions on foreign ownership or holdings. Such legal and regulatory restrictions or
limitations may have adverse effects on the liquidity and performance of the Sub-Funds’
holdings as compared to the performance of the Reference Index. This may increase the risk
of tracking error and, at the worst, the Sub-Funds may not be able to fully achieve its
investment objective and/or the Sub-Fund may face increased liquidity risks.
Suspension risk
Shares may only be bought from, or sold to, the Sub-Funds from time to time where the
relevant security may be sold or purchased on the Shanghai Stock Exchange or the
Shenzhen Stock Exchange, as appropriate. Given that these markets are considered volatile
and unstable (with the risk of suspension of a particular stock or government intervention),
the subscription and redemption of Shares may also be disrupted.
Settlement procedures in the PRC are less developed and may differ from those in countries
that have more developed financial markets. The Sub-Funds may be subject to a risk of
substantial loss if an appointed agent (such as a broker or a settlement agent) defaults in
the performance of its responsibilities. The Sub-Funds may incur substantial losses if its
counterparty fails to pay for securities the Sub-Funds has delivered, or for any reason fails
to complete its contractual obligations owed to the Sub-Fund. On the other hand, significant
delays in settlement may occur in certain markets in registering the transfer of securities.
Such delays could result in substantial losses for the Sub-Fund if investment opportunities
are missed or if the Sub-Funds is unable to acquire or dispose of a security as a result. As
a consequence, the broker model involving Delivery Versus Payment settlement must be
chosen in order to limit counterparty risk.
The PRC Government has implemented a number of tax reform policies in recent years. The
current tax laws and regulations may be revised or amended in the future. Any revision or
amendment in tax laws and regulations may affect the after-taxation profit of PRC companies
and foreign investors in such companies. Any changes in tax policies may reduce the after-
taxation profits of the investments to which the performance of the Sub-Funds is linked.
32
Government intervention and restriction risk
Governments and regulators may intervene in the financial markets, such as by the
imposition of trading restrictions for certain stocks. This may affect the operation and market
making activities of the Sub-Funds, and may have an unpredictable impact on the Sub-
Funds.
Furthermore, such market interventions may have a negative impact on the market
sentiment, which may in turn affect the performance of the Sub-Funds.
In the context of the management of the investment portfolio, each Sub-Fund may
use instruments with a view to hedging against exchange-rate fluctuations. These
instruments include sales of forward foreign-exchange contracts, sales of currency
futures, purchases of put options on currencies as well as sales of call options on
currencies. Such transactions are limited to contracts and options which are traded on
a regulated market, which is in continuous operation and which is recognised and open
to the public. Furthermore, the Company may for each Sub-Fund enter into currency
swaps in the context of over-the-counter transactions dealing with leading institutions
specialised in this type of transaction.
Each Sub-Fund may engage in currency hedging transactions with regards to a certain
Class of shares. Hedged Share Classes are designed (i) to minimize exchange rate
fluctuations between the currency of the Hedged Share Class and the base currency of
the Sub-Fund or (ii) to reduce exchange rate fluctuations between the currency of the
Hedged Share Class and other material currencies within the Sub-Fund’s portfolio.
33
The hedging will be undertaken to reduce exchange rate fluctuations in case the base
currency of the Sub-Fund or other material currencies within the Sub-Fund (the
"reference currency(ies)") is(are) declining or increasing in value relative to the hedged
currency. The hedging strategy employed will seek to reduce as far as possible the
exposure of the Hedged Share Classes and no assurance can be given that the hedging
objective will be achieved. In the case of a net flow to or from a Hedged Share Class
the hedging may not be adjusted and reflected in the net asset value of the Hedged
Share Class until the following or a subsequent business day following the Valuation
Date on which the instruction was accepted. This risk for holders of any Hedged Share
Class may be mitigated by using any of the efficient portfolio management techniques
and instruments (including currency options and forward currency exchange contracts,
currency futures, written call options and purchased put options on currencies and
currency swaps), within the conditions and limits imposed by the Luxembourg financial
supervisory authority. Investors should be aware that the hedging strategy may
substantially limit Shareholders of the relevant Hedged Share Class from benefiting
from any potential increase in value of the Class of shares expressed in the reference
currency(ies), if the Hedged Share Class currency falls against the reference
currency(ies). Additionally, Shareholders of the Hedged Share Class may be exposed
to fluctuations in the net asset value per Share reflecting the gains/losses on and the
costs of the relevant financial instruments. The gains/losses on and the costs of the
relevant financial instruments will accrue solely to the relevant Hedged Share Class.
Any financial instruments used to implement such hedging strategies with respect to
one or more Classes of a Sub-Fund shall be assets and/or liabilities of such Sub-Fund
as a whole, but will be attributable to the relevant Class(es) and the gains/losses on
and the costs of the relevant financial instruments will accrue solely to the relevant
Class. However, due to the lack of segregated liabilities between Classes of the same
Sub-Fund, costs which are principally attributed to a specific Class may be ultimately
charged to the Sub-Fund as a whole. Any currency exposure of a Class may not be
combined with or offset against that of any other Class of a Sub-Fund. The currency
exposure of the assets attributable to a Class may not be allocated to other Classes.
No intentional leveraging should result from currency hedging transactions of a Class
although hedging may exceed 100% for short periods between redemption instructions
and execution of the hedge trade.
Share classes which are Hedged Share Classes will be indicated so in each Sub-Fund’s
specifics in Part B of this Prospectus.
Since the Company values the portfolio holdings of each of its Sub-Funds in Euro or
other currency as stated in the relevant Sub-Fund’s specifics in Part B of this
Prospectus, changes in currency exchange rates adverse to those currencies may affect
the value of such holdings and each respective Sub-Fund's yield thereon. Since the
securities held by a Sub-Fund may be denominated in currencies different from its
base currency, the Sub-Fund may be affected favourably or unfavourably by exchange
control regulations or changes in the exchange rates between such reference currency
and other currencies. Changes in currency exchange rates may influence the value of
a Sub-Fund’s Shares, and also may affect the value of dividends and interests earned
by the Sub-Fund and gains and losses realised by said Sub-Fund. If the currency in
which a security is denominated appreciates against the base currency, the price of
the security could increase. Conversely, a decline in the exchange rate of the currency
would adversely affect the price of the security. To the extent that a Sub-Fund or any
Class of shares seeks to use any strategies or instruments to hedge or to protect
against currency exchange risk, there is no guarantee that hedging or protection will
be achieved. Unless otherwise stated in any Sub-Fund’s investment policy, there is no
34
requirement that any Sub-Fund seeks to hedge or to protect against currency
exchange risk in connection with any transaction. Sub-Funds which use currency
management strategies, including the use of cross currency forwards and currency
futures contracts, may substantially change the Sub-Fund's exposure to currency
exchange rates and could result in losses to the Sub-Fund if the currencies do not
perform as the Investment Manager expects.
Substantial withdrawals by shareholders within a short period of time could require the
liquidation of positions more rapidly than would otherwise be desirable, which could
adversely affect the value of the assets of the Company. The resulting reduction in the
assets of the Company could make it more difficult to generate a positive rate of return
or to recoup losses due to a reduced equity base.
The value of the Company's assets may be affected by uncertainties such as political
developments, changes in government policies, taxation, currency repatriation
restrictions and restrictions on foreign investment in some of the countries in which
the Company may invest.
The lack of ESG criteria standards can make comparability between different portfolios
using these criteria difficult
The security selection can involve a significant element of subjectivity when applying
Environmental, Social and Governance filters. Indeed, due to the lack of ESG criteria
and sub-criteria standards, ESG factors incorporated in the investment processes may
vary depending on the investment themes, asset classes, investment philosophy and
subjective use of different Environmental, Social and Governance criteria and sub-
criteria governing the portfolio construction.
The ESG investment approaches available in the market can be subject to different
interpretations
As the ongoing implied risk is the risk of portfolio “greenwashing”, some investment
firms will exploit the ESG area for marketing, rather than employing a sincere ESG
investment strategy.
The use of Environmental, Social and Governance criteria may affect the Sub-Funds’
investment performance and, as such, Sub-Funds may perform differently compared
to similar Sub-Funds that do not use such criteria. Indeed, the investment selection
processes are different due to ESG criteria.
35
Evolving ESG risks calculations makes ESG risk measurements difficult
Since the assessment of Environmental, Social and Governance risks is still very much
evolving, it is usually difficult to measure Environmental, Social and Governance risks
directly as traditional risks. The Management Company must therefore manage the
Fund's risks based on indirect measures of risk, like the (relative) scores of companies
on the large number of Environmental, Social and Governance factors which are
available on the market through data providers.
Sustainability risk
Any Feeder Sub-Fund will also be subject to specific risks associated with its
investment into the Master Fund as well as specific risks incurred at the level of the
Master Fund and its investments. If the Master Fund invests in a particular asset
category, investment strategy or financial or economic market, the Feeder Sub-
Fund will then become more susceptible to fluctuations in value resulting from
adverse economic conditions affecting the performance of that particular asset
category, investment strategy or financial or economic market.
In addition to the above risk factors, prospective investors in Shares of a Feeder Sub-
Fund should consider the following risks associated with the Feeder Sub-Fund's
investment in the Master Fund.
When a Sub Fund is a Feeder Sub-Fund, it is intended that the Feeder Sub-Fund will
invest substantially all of its assets in the Master Fund save for a residual cash amount
which may be required from time to time for dealing liquidity purposes and payment
of costs and expenses of the Feeder Sub-Fund.
The Net Asset Value of the Feeder Sub-Fund will mainly depend on the net asset value
of the Master Fund.
Consequently, the Net Asset Value per Share may be determined only after the net
asset value of the Master Fund has been determined, and the number of Shares to be
issued to, exchanged or redeemed from, an investor in the Feeder Sub-Fund may
not be determined until the net asset value per share of the Master Fund is
36
determined. The determination of the Net Asset Value per Share may be suspended
upon a suspension of the calculation of the net asset value per share of the Master
Fund or any other suspension or deferral of the issue, redemption and/or exchange
of shares in the Master Fund, in accordance with the provisions under the section
"Net Asset Value” below.
The rules applied to calculate the Net Asset Value per Share, as described under
the section "Net Asset Value” below, presume the Feeder Sub-Fund's ability to value
its investment in the Master Fund. In valuing such investment holdings, the Feeder
Sub-Fund may rely on financial information provided by the Management Company
and the administrator of the Master Fund. Independent valuation sources such as
exchange listing may not be available for the Master Fund.
The main operational and legal risks associated with any Feeder Sub-Fund's
investment in the Master Fund include, without being limited to, the Feeder Sub-
Fund's access to information on the Master Fund, coordination of dealing
arrangements between the Feeder Sub-Fund and the Master Fund, the occurrence
of events affecting such dealing arrangements, the communication of documents from
and to the Master Fund to and from the Feeder Sub-Fund, the coordination of the
involvement of the respective depositary and auditor of the Feeder Sub-Fund and
the Master Fund and the identification and reporting of investment breaches and
irregularities by the Master Fund.
Such operational and legal risks will be mitigated and managed by the Management
Company, the Depositary and the Independent Auditor, as applicable, in
coordination with the depositary, the administrator and the auditor of the Master
Fund. A number of documents and/or agreements are in place to that effect,
including (1) internal conduct of business rules established by the Management
Company, (2) an information sharing agreement between the Depositary and the
depositary of the Master Fund, and (3) an information exchange agreement
between the Independent Auditor and the auditor(s) of the Master Fund.
Currency Risk
The Reference Currency of the Feeder Sub-Fund and the Master Fund may differ and
the underlying investments of the Master Fund are denominated in a variety of
currencies. Generally, the Management Company will not seek to hedge out
currency exposure at Feeder Sub-Fund’s level (unless specified otherwise in the Sub
Fund’s specifics in Part B of this Prospectus). Equally, the Management Company will
not seek to hedge out any currency exposure at the Master Fund’s level.
Consequently, the performance of the Feeder Sub-Fund may be strongly influenced
by movements in foreign exchange rates because the Reference Currency of the
Feeder Sub-Fund will not correspond to that of the Master Fund and may not
correspond to the currency of the securities positions held in the Master Fund.
Given the feeder nature of the Feeder Sub-Fund it will naturally be concentrated
in the Master Fund. Therefore, concentration risks and market risks will mainly
occur at the level of the Master Fund. In this respect, Shareholders should carefully
read the risks associated with an investment in the Master Fund, as described in
the prospectus of the Master Fund.
37
Investment Management Risk
Warrants are complex and volatile instruments, due to the “leverage effect”, as
the value of the underlying asset can have a disproportionate effect on the value
of the warrant. Therefore the risk of a total loss of the invested capital is great.
Finally, there is no guarantee that, in the event of an illiquid market, it will be
possible to sell the warrant on a secondary market.
38
6. SUB-FUNDS AND SHARES OF THE COMPANY
Under the Articles of the Company, the Directors have the power to create and issue several
different Sub-Funds, whose characteristics may differ from those Sub-Funds then existing.
The Directors shall maintain for each Sub-Fund a separate pool of assets. As between
shareholders, each pool of assets shall be invested for the exclusive benefit of the relevant
Sub-Fund. With regard to third parties, in particular towards the Company's creditors, each
Sub-Fund shall be exclusively responsible for all liabilities attributable to it.
Under the Articles of the Company, the Directors have the power to create and issue within
each Sub-Fund several different classes of shares within each Sub-Fund, whose
characteristics may differ from those Classes existing.
The differences between the Classes may relate inter alia to the initial subscription price per
share, the reference currency of the Class, the types of investors who are eligible to invest,
the subscription and repurchase frequency, the charging structure applicable to each of
them, the distribution policy or such other features as the Board of Directors may, in their
discretion, determine.
Shares will in principle be freely transferable to investors complying with the eligibility
criteria of the relevant Class and provided that shares are neither acquired nor held by or
on behalf of any person in breach of the law or requirements of any country or governmental
or regulatory authority, or which might have adverse taxation or other pecuniary
consequences for the Company, including a requirement to register under any securities or
investment or similar laws or requirements of any country or authority. The Board of
Directors may in this connection require a shareholder to provide such information as they
may consider necessary to establish whether he is the beneficial owner of the shares which
he holds.
Within each Class, the Board of Directors is authorised, without limitation and at any time,
to issue additional shares at the respective Net Asset Value per share determined in
accordance with the provisions of the Company's Articles, without reserving to existing
Shareholders preferential or pre-emptive rights to subscribe for the shares to be issued.
On issue, all shares have to be fully paid up. The shares do not have any par value. Each
share carries one vote, regardless of its Net Asset Value and of the Sub-Fund to which it
relates.
Shares are only available in registered form. No share certificates will be issued in respect
of registered shares; registered share ownership will be evidenced by confirmation of
ownership and registration on the share register of the Company.
Fractions of shares may be issued up to one thousandth of a share. The resultant fractional
shares shall have no right to vote but shall have the right to participate pro-rata in
distributions and allocation of the proceeds of liquidation in the event of the winding-up of
the Company or in the event of the termination of the Company.
The Sub-Funds’ specifics in Part B of this Prospectus detail the Classes available in each Sub-
Fund.
Upon creation of a new Sub-Fund and Class, the Prospectus will be updated accordingly.
40
7. INCOME POLICY
Within each Class of shares, the Board of Directors may decide to issue accumulating and/or
distributing shares. The dividend policy applicable for each Class of shares or Sub-Fund is
further described in each Sub-Fund’s specifics in Part B of this Prospectus.
Dividend payments are restricted by law in that they may not reduce the assets of the
Company below the required minimum capital.
In the event that a dividend is declared and remains unclaimed after a period of five (5)
years from the date of declaration, such dividend will be forfeited and will revert to the Class
or Sub-Fund in relation to which it was declared.
41
8. NET ASSET VALUE
The Net Asset Value per share of each Class will be determined for each Valuation Date as
indicated in the Sub-Funds’ specifics in Part B of this Prospectus and expressed in the
reference currency of the respective Class, by the central administrator of the Company by
dividing the value of the assets of the Sub-Fund properly able to be allocated to such Class
less the liabilities of the Sub-Fund properly able to be allocated to such Class by the number
of shares then outstanding in the class on the relevant Valuation Date. The Net Asset Value
per share of each Class may be rounded up or down to the nearest two decimals of the
reference currency of such Class of shares. The Sub-Funds’ specifics in Part B of this
Prospectus detail the Valuation Date for each Sub-Fund.
When a Valuation Date should not be considered as a full Bank Business Day, the Company
may decide that a Net Asset Value will not be calculated for such Valuation Date.
The value of the assets of each Sub-Fund is determined on the Calculation Day as follows:
2. non-listed securities are valued on the basis of their probable sales price as
determined in good faith by the Board of Directors or its delegate;
3. Shares or units of UCITS (including any Master Fund) or other UCIs are valued at the
latest available net asset value per share;
4. liquid assets are valued at their nominal value plus accrued interest;
6. the Board of Directors may adjust the value of any investment if having regard to its
currency, marketability, applicable interest rates, anticipated rates of dividend,
maturity, liquidity or any other relevant considerations, it considers that such
adjustment is required to reflect the fair value thereof;
Whenever a foreign exchange rate is needed in order to determine the Net Asset Value of a
Class, the applicable foreign exchange rate on the respective Valuation Date will be used.
In addition, appropriate provisions will be made to account for the charges and fees charged
to the Sub-Funds and Classes as well as accrued income on investments.
In the event it is impossible or incorrect to carry out a valuation in accordance with the
above rules owing to particular circumstances, such as hidden credit risk, the Board of
Directors is entitled to use other generally recognised valuation principles, which can be
examined by an auditor, in order to reach a proper valuation of each Sub-Fund's total assets.
42
The Net Asset Value per share in each Sub-Fund is available at the registered office of the
Company and at the Management Company's offices.
The calculation of the Net Asset Value of the shares of any Class and the issue, redemption
and conversion of the shares of any Sub-Fund may be suspended by the Board of Directors
in the following circumstances:
- following a suspension of the calculation of the net asset value per share of the Master
Fund or any other suspension or deferral of the issue, redemption and/or exchange
of shares in the Master Fund; or
- during any period (other than ordinary holidays or customary weekend closings)
when any market or stock exchange is closed, which is the main market or stock
exchange for a significant part of the Sub-Fund's investments, for in which trading
therein is restricted or suspended; or
- when for any reason (i) the prices of any investment owned by the Sub-Fund cannot
be reasonable, promptly or accurately ascertained or (ii) the calculation of the net
asset value of any relevant Master Fund is suspended; or
- during the period when remittance of monies which will or may be involved in the
purchase or sale of any of the Sub-Fund's investments cannot, in the opinion of the
Board of Directors, be carried out at normal rates of exchange; or
- in the case of a merger, if the Board of Directors deems this to be justified for the
protection of the shareholders; or
- in all other cases in which the Board of Directors considers a suspension to be in the
best interest of the Shareholders.
The issue and redemptions of Shares shall be prohibited (a) during the period in which the
Company does not have a depositary and (b) where the Depositary is put into liquidation
or declared bankrupt or seeks an arrangement with creditors, a suspension of payment or
a controlled management or is the subject of similar proceedings.
The suspension of the calculation of the Net Asset Value and of the issue, redemption and
conversion of the shares shall be notified to shareholders having made an application for
subscription, redemption or conversion of shares for which the calculation of the Net Asset
Value and of the issue, redemption and conversion of the shares has been suspended.
43
9. ISSUE OF SHARES
Applications may be made in writing by fax, SWIFT, Neolink or STP addressed to the Transfer
Agent, the Distributor, the Depositary, the Nominee of the Company or any intermediary
situated in a country where the Company is marketed specifying the number of shares or
amount subscribed for, the name of the Sub-Fund and Class, the manner of payment and
the personal details of the subscriber. Orders sent directly to the Transfer Agent can also be
sent by swift.
A subscription fee calculated on the Net Asset Value of the shares as specified in each Sub-
Fund’s specifics and to which the application relates as well as the percentage amount of
which is indicated for each Class in the table in Part B of this Prospectus (see section
“Expenses” in each Sub-Fund’s specifics), may be charged to the investors by the Nominee,
the Distributor, any appointed sub-distributor or by the Registrar and Transfer Agent upon
a subscription for shares in a Class.
The initial subscription period (which may last one day) and price of each newly created or
activated Sub-Fund or Class will be determined by the Directors and disclosed in the relevant
Sub-Fund’s specifics in Part B of this Prospectus.
Payments for subscriptions made during the initial subscription period must have been
received in the Reference Currency of the relevant Sub-Fund / Class of shares by the
Company within the time period indicated in the relevant Sub-Fund’s specifics in Part B of
this Prospectus.
The Board of Directors may at any time decide the activation of a Class.
Upon activation of a new Class in a Sub-Fund, the price per share in the new Class will, at
its inception, correspond to the price per share during the initial subscription period in the
relevant Sub-Fund or to the current Net Asset Value per share in an existing Class of the
relevant Sub-Fund, upon decision of the Board of Directors.
Following any initial subscription period, the issue price per share will be the Net Asset
Value per share on the applicable Valuation Date.
Subscriptions received by the Registrar and Transfer Agent before the applicable cut-off time
on a Valuation Date as specified in the Sub-Funds’ specifics in Part B of this Prospectus will
be dealt with on the basis of the relevant Net Asset Value of that Valuation Date.
Subscriptions received by the Registrar and Transfer Agent after such cut-off time on a
Valuation Date or on any day which is not a Valuation Date will be dealt with on the basis of
the Net Asset Value of the next Valuation Date. The investor will bear any taxes or other
expenses attaching to the application.
Subscription proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within the time frame mentioned at Sub-Fund level.
All shares will be allotted immediately upon subscription and payment must be received by
the Company within the time period as described in each Sub-Fund in Part B of this
prospectus. If payment is not received, the relevant allotment of shares may be cancelled
44
at the risk and cost of the shareholder. Payments should preferably be made by bank
transfer and shall be made in the reference currency of the relevant Class; if payment is
made in another currency than the reference currency of the relevant Class, the Company
will enter into an exchange transaction at market conditions and this exchange transaction
could lead to a postponement of the allotment of shares.
The Board of Directors reserves the right to accept or refuse any subscriptions in whole or
in part for any reason.
In case a subscription is rejected after the applicable Valuation Date, the assets will be
returned to the investor at the lower of the Net Asset Value at the date of rejection or the
subscription price without payment of any interest.
The issue of shares of any Sub-Fund shall be suspended on any occasion when the
calculation of the Net Asset Value thereof is suspended.
Classes dedicated to specific investors, may have a minimum subscription and / or holding
amount as indicated in the Sub-Funds’ specifics in Part B of the Prospectus. The Company
may in its discretion waive this minimum subscription and / or holding amount. In
particular, this applies for Shareholders staggering investments over time, reaching above-
mentioned thresholds over time.
If, as a result of redemption, the value of a Shareholder’s holding in a Class would become
less than the relevant minimum holding amount as indicated above, then the Board of
Director of the Company may elect to redeem the entire holding of such Shareholder in the
relevant Class. It is expected that such redemptions will not be implemented if the value of
the Shareholder’s shares falls below the minimum investment limits solely as a result of
market conditions. Thirty (30) calendar days prior written notice will be given to
Shareholders whose shares are being redeemed to allow them to purchase sufficient
additional shares so as to avoid such compulsory redemption.
In order to inter alia protect existing Shareholders, the Board of Directors may, at any
time, decide to close a Sub‐Fund or a share class and not to accept any further
subscriptions or conversions into the relevant Sub‐Fund or share class i) from new investors
who have not yet already invested into the said Sub‐Fund or into the said share class (“Soft
Closure”) or (ii) from all investors (“Hard Closure”).
In relation thereto, a notice to shareholders will be sent to all investors in the relevant sub-
fund and a notification will be displayed on the website www.lfde.com and will be updated
according to the status of the said shares or Sub‐Funds. Indeed, the closed Sub‐Fund or
share class may be re‐opened when the Board of Directors deems the reasons to have the
latter closed no longer applying.
45
Background for a closure may be, without being restricted thereof, that the size of a given
Sub‐Fund is close to or has reached such a level that the market it is invested into has also
reached its capacity level and thus the Sub‐Fund cannot be managed according to the
defined objectives and investment policy.
Shares of different Sub-Funds and their Classes may at the discretion of the Directors of the
Company be listed on Stock Exchanges, in particular the Luxembourg Stock Exchange.
46
10. REDEMPTION OF SHARES
A Shareholder has the right to request that the Company redeems its shares at any time by
specifying the number of shares or amount to be redeemed. Shares will be redeemed at the
respective Net Asset Value of shares of each Class. Orders sent directly to the Transfer Agent
can also be sent by swift.
In any case, no redemption will be accepted and executed before having successfully
performed all anti-money laundering checks. In the case where the acceptance of any
redemption order would be delayed for any anti-money laundering purpose at the discretion
of the Board of Directors, such a redemption order will be executed on the basis of the Net
Asset Value of shares immediately applicable on the day of such acceptance without payment
of any interest.
A redemption fee calculated on the Net Asset Value of the shares to which the application
relates, the percentage amount of which is indicated for each Class in the tables in Part B of
this Prospectus (see section “Expenses” in each Sub-Fund’s specifics), may be charged to
the investors by the Nominee, the Distributor, any appointed sub-distributor or by the
Registrar and Transfer Agent upon a redemption for shares in a Class.
Shareholders wishing to have all or any of their shares redeemed at the redemption price
on a Valuation Date, should deliver to the Registrar and Transfer Agent before the cut-off
time on a Valuation Date as specified in the Sub-Fund’s specifics in Part B of this Prospectus,
an irrevocable written request for redemption in the prescribed form. Redemption requests
received by the Registrar and Transfer Agent after such determined cut-off time on a
Valuation Date or on any day, which is not a Valuation Date will be dealt with on the basis
of the Net Asset Value of the next Valuation Date.
All requests will be dealt with in strict order in which they are received, and each redemption
shall be effected at the Net Asset Value of the said shares.
Redemption proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within the time frame mentioned at Sub-Fund level.
Shareholders should note that any redemption of shares by the Company will take
place at a price that may be more or less than the Shareholder's original acquisition
cost, depending upon the value of the assets of the Sub-Fund at the time of
redemption.
The payment of the redemption price may be made in consideration in kind at the Board of
Directors’ discretion, subject however to the prior approval of the concerned Shareholders.
The allotment of Fund’s assets in respect of redemption for consideration in kind shall be
fair and not detrimental to the interests of the other Shareholders of the Company. Any
redemption for consideration in kind shall be subject to the confirmation by an auditor’s
special report of the valuation of the Company and of the Company’s assets to be allocated,
the costs of which shall be borne by the Company.
The redemption of shares of any Sub-Fund shall be suspended on any occasion when the
calculation of the Net Asset Value thereof is suspended.
If requests for redemption on any Valuation Date exceed 10% of the Net Asset Value of a
Sub-Fund’s shares, the Company, at the discretion of the Board of Directors reserves the
right to postpone redemption of all or part of such shares to the following Valuation Date.
On the following Valuation Date such requests will be dealt with in priority to any subsequent
requests for redemption.
47
Compulsory redemptions
a) The Shares are held by Shareholders not authorized to buy or own Shares in the
Company, e.g. a Shareholder (or an affiliate of the same) that becomes a US person
as referred to in this Prospectus;
c) the value of a Shareholder’s holding in a Class is less than the relevant minimum
holding amount;
d) In all other circumstances as the Board of Directors may deem appropriate and in the
interests of the Company.
Except in the cases b), c) and d) above, the Board of Directors may impose such penalty
as it deems fair and appropriate.
48
11. CONVERSION BETWEEN SUB-FUNDS/CLASSES OF SHARES
Shares of any Class may be converted into shares of any other Class of the same or of
another Sub-Fund, upon written instructions addressed to the registered office of the
Company or the Distributor. No conversion fee will be charged. Shareholders may be
requested to bear the difference in subscription fee between the Sub-Fund they leave and
the Sub-Fund of which they become shareholders, should the subscription fee of the Sub-
Fund into which the Shareholders are converting their shares be higher than the fee of the
Sub-Fund they leave.
Conversion orders received by the Registrar and Transfer Agent on a Valuation Date before
the cut-off time as specified in the Sub-Funds’ specifics in Part B of this Prospectus will be
dealt with on the basis of the relevant Net Asset Value established on that Valuation Date.
Conversion requests received by the Registrar and Transfer Agent after such cut-off time on
a Valuation Date or on any day, which is not a Valuation Date will be dealt with on the basis
of the Net Asset Value of the next Valuation Date. Conversion of shares will only be made
on a Valuation Date if the Net Asset Value of both share Classes is calculated on that day.
The Board of Directors will determine the number of shares into which an investor wishes to
convert his existing shares in accordance with the following formula:
(B x C)
A = --------------- * EX
E
C= The Net Asset Value per share in the original Class of shares
E= The Net Asset Value per share of the new Class of shares
EX: being the exchange rate on the conversion day in question between the currency of the
Class of shares to be converted and the currency of the Class of shares to be assigned. In
the case no exchange rate is needed the formula will be multiplied by one (1).
If requests for conversion on any Valuation Date exceed 10% of the Net Asset Value of a
Sub-Fund’s shares, the Company reserves the right to postpone the conversion of all or part
of such shares to the following Valuation Date. On the following Valuation Date such requests
will be dealt with in priority to any subsequent requests for conversion.
The conversion of shares of any Sub-Fund shall be suspended on any occasion when the
calculation of the Net Asset Value thereof is suspended.
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12. LATE TRADING/MARKET TIMING POLICY
The Company takes appropriate measures to assure that subscription, redemption and
conversion requests will not be accepted after the time limit set for such requests in this
Prospectus.
The Company does not knowingly allow investments which are associated with market timing
or similar practices as such practices may adversely affect the interests of all Shareholders.
The Company reserves the right to reject subscription, redemption and conversion orders
from an investor who the Company suspects of using such practices and to take, if
appropriate, other necessary measures to protect the other investors of the Company.
As set out in the CSSF Circular 04/146, market timing is to be understood as an arbitrage
method through which an investor systematically subscribes and redeems or converts units
or shares of the same fund within a short time period, by taking advantage of time
differences and/or imperfections or deficiencies in the method of determination of the net
asset values.
Professional investors subject to prudential requirements (Solvency II) may ask the
Management Company for funds’ assets portfolios. Communication of such information shall
be managed in accordance with regulators provisions.
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13. TAXATION IN LUXEMBOURG
Under Luxembourg law, there are currently no Luxembourg taxes on income, withholding or
capital gains by the Company. The Company is, however, subject to a taxe d’abonnement
of 0.05% per annum, calculated and payable quarterly, on the aggregate Net Asset Value
of the outstanding shares of the Company at the end of each quarter. This annual tax is
however reduced to 0.01% on the aggregate Net Asset Value of the shares dedicated to
institutional investors.
Shareholders are, at present, not subject to any Luxembourg capital gains, income,
withholding, gift, estate, inheritance or other tax with respect to shares owned by them
(except, where applicable, Shareholders who are domiciled or reside or have permanent
establishment or have been domiciled or have resided in Luxembourg).
Prospective investors should inform themselves as to the taxes applicable to the acquisition,
holding and disposition of shares of the Company and to disposition of shares of the
Company and to distributions in respect thereof under the laws of the countries of their
citizenship, residence or domicile.
The Savings Law implemented into Luxembourg Law Savings Directive or EUSD. On 10
November 2015, the Council of the European Union decided to repeal the Savings Directive
with effect as at 1 January 2016. As from that date, CRS applies in EU countries, including
Luxembourg. Therefore, as from 1 January 2016, Luxembourg did not apply anymore EUSD
regime but CRS regime. Additional information on the CRS regime is available in the related
sub-section below.
CRS
The OECD received a mandate by the G8/G20 countries to develop a CRS to achieve a
comprehensive and multilateral automatic exchange of information in the future on a global
basis. The CRS has been incorporated in the DAC, adopted on 9 December 2014, which the
EU Member States had to incorporate into their national laws by 31 December 2015. In this
respect, AEOI Law was published in the Mémorial A – N° 244 on 24 December 2015.
The CRS requires Luxembourg Financial Institutions to identify their account holders
(including in the case of an Investment Entity equity and debt holders) and establish where
they are fiscally resident. In this respect, a Luxembourg Financial Institution should obtain
a self-certification to establish the CRS status and/or tax residence of its investors at account
opening.
Luxembourg Financial Institutions will need to perform their first reporting of financial
account information for the year 2016 about investors and (in certain cases) their Controlling
Persons that are tax resident in a Reportable Jurisdiction (identified in a Grand Ducal Decree)
to the Luxembourg tax authorities (“Administration des contributions directes”) by 30 June
2017. The Luxembourg tax authorities will automatically exchange this information with the
competent foreign tax authorities by the end of September 2017.
Data protection
According to the AEOI Law and Luxembourg data protection rules, each individual concerned
shall be informed on the processing of his/her personal data before the Reporting
Luxembourg Financial Institution processes the data. If the individual qualifies as Reportable
Person in the aforementioned context, the Company will inform the individual in accordance
with the Luxembourg data protection law.
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• In this respect, the Company as Reporting Luxembourg Financial Institution will
be responsible for the personal data processing and will act as data controller for
the purpose of the AEOI Law.
• The personal data is intended to be processed for the purpose of the AEOI Law
and the CRS/DAC 2.
• The data may be reported to the Luxembourg tax authorities (“Administration des
contributions directes”), which may in turn continue these data to the competent
authorities of one or more Reportable Jurisdictions.
• For each information request for the purpose of the AEOI Law sent to the
individual concerned, the answer from the individual will be mandatory. Failure
to respond within the prescribed timeframe may result in (incorrect or double)
reporting of the account to the Luxembourg tax authorities.
• Each individual concerned has a right to access any data reported to the
Luxembourg tax authorities for the purpose of the AEOI Law and, as the case may
be, to have these data rectified in case of error.
All personal data of Shareholders contained in any document provided by such Shareholders
and any further personal data collected in the course of the relationship with the Company
may be collected, recorded, stored, adapted, transferred or otherwise processed and used
(hereinafter “processed”) by the Company or the Management Company. Such data shall be
processed for the purposes of account administration, anti-money laundering identification
and the development of the business relationship. To this end, data may be transferred to
companies appointed by the Company or the Management Company, to support the
Company’s activities.
Each Shareholder, by signing the subscription agreement, gives its agreement to such
processing of his personal data, as provided by the applicable regulatory framework on the
protection of the persons with regard to the processing of personal data.
Further details on the terms and conditions on the processing of data are available upon
request and free of charge at the registered office of the Company.
The Company, acting as data controller, collects, stores and processes by electronic or other
means the data supplied by the Shareholders at the time of their subscription for the purpose
of fulfilling the services required by the Shareholders and complying with its legal
obligations.
Any data collected by the Company are to be processed in accordance with the data
protection law applicable to the Grand Duchy of Luxembourg and the Data Protection Law.
The data processed includes the name, address and invested amount of each Shareholder
as well as any data requested by the Company in order to ensure the Company’s compliance
with applicable anti-money laundering/know your customer, counter terrorist financing,
FATCA and CRS rules (the “Personal Data”).
The investor may, at his discretion, refuse to communicate the Personal Data to the
Company. In this case, however, the Company may reject his request for subscription of
Shares in the Company.
In particular, the data supplied by Shareholders is processed for the purpose of (i)
maintaining the register of Shareholders, (ii) processing subscriptions, redemptions and
52
conversions of Shares and payments of dividends to Shareholders, (iii) performing controls
on late trading and market timing practices, (iv) complying with applicable anti-money
laundering/know your customer, counter terrorist financing, FATCA and CRS rules.
The Company can delegate to another entity located in the European Union (the
Management Company, the Distributor, the Administrative Agent, the Investment Manager
(if any), or the Registrar Agent) the processing of the Personal Data. The Company may also
transfer Personal Data to third parties such as governmental or regulatory agencies including
tax authorities, in or outside the European Union, in accordance with applicable laws and
regulations.
The Shareholder also has the right to object to the use of his/her Personal Data for marketing
purposes.
The Shareholder may exercise the above rights by writing to the Company at its registered
office.
The Shareholder also acknowledges the existence of his/her right to lodge a complaint with
the National Commission for Data Protection.
Personal Data shall not be retained for longer than the time required for the purpose of its
processing, subject to the legal limitation periods.
Tax implication of the investment into the Master Fund for the Company
The investment into the Master Fund has no specific Luxembourg tax impact.
53
14. CENTRAL ADMINISTRATION, DEPOSITARY, TRANSFER, REGISTRAR & PAYING
AGENT
The Management Company and the Company have entered into an Administration
Agreement with BNP Paribas, Luxembourg Branch on 15 October 2013 for an indefinite
period of time.
This Agreement may be terminated by either party with 90 calendar days prior written
notice.
Under the above-mentioned Agreement, BNP Paribas, Luxembourg Branch will provide the
Company under supervision and responsibility of the Management Company with services
as Central Administration Registrar and Transfer Agent and domiciliation agent. It will carry
out the necessary administrative work required by law and the rules of the Company and
establish and keep books and records including the register of shareholders of the Company.
It will also execute all subscription, redemption and conversion applications and determine
the Net Asset Value of the Company.
BNP Paribas, Luxembourg Branch has been appointed Depositary of the Company under the
terms of a written agreement dated 8 December 2016 between BNP Paribas, Luxembourg
Branch, the Management Company and the Company.
BNP Paribas, Luxembourg Branch is a branch of BNP Paribas. BNP Paribas is a licensed bank
incorporated in France as a Société Anonyme (public limited company) registered with the
Registre du commerce et des sociétés Paris (Trade and Companies’ Register) under number
No. 662 042 449, authorised by the Autorité de Contrôle Prudentiel et de Résolution (ACPR)
and supervised by the Autorité des Marchés Financiers (AMF), with its registered address at
16 Boulevard des Italiens, 75009 Paris, France, acting through its Luxembourg Branch,
whose office is at 60, avenue J.F. Kennedy, L-1855 Luxembourg, Grand-Duchy of
Luxembourg, and is supervised by the CSSF.
The Depositary performs three types of functions, namely (i) the oversight duties (as defined
in Art 34.1 of the Investment Fund Law), (ii) the monitoring of the cash flows of the Company
(as set out in Art 34.2 of the Investment Fund Law) and (iii) the safekeeping of the
Company’s assets (as set out in Art 34.3 of the Investment Fund Law).
(1) ensure that the sale, issue, repurchase, redemption and cancellation of Shares
effected on behalf of the Company are carried out in accordance with the Investment Fund
Law or with the Company’s Articles;
(2) ensure that the value of Shares is calculated in accordance with the Investment
Fund Law and the Company’s Articles;
(3) carry out the instructions of the Company or the Management Company acting on
54
behalf of the Company, unless they conflict with the Investment Fund Law or the Company’s
Articles;
(4) ensure that in transactions involving the Company’s assets, the consideration is
remitted to the Company within the usual time limits;
(5) ensure that the Company’s revenues are allocated in accordance with the
Investment Fund Law and its Articles.
The overriding objective of the Depositary is to protect the interests of the Shareholders of
the Company, which always prevail over any commercial interests.
Conflicts of interest may arise if and when the Management Company or the Company
maintains other business relationships with BNP Paribas, Luxembourg Branch in parallel with
an appointment of BNP Paribas, Luxembourg Branch acting as Depositary.
The Depositary is required to ensure that any transaction relating to such business
relationships between the Depositary and an entity within the same group as the Depositary
is conducted at arm’s length and is in the best interests of Shareholders.
In order to address any situations of conflicts of interest, the Depositary has implemented
and maintains a management of conflicts of interest policy, aiming namely at:
In the event that such conflicts of interest do arise, the Depositary will undertake to use its
reasonable endeavours to resolve any such conflicts of interest fairly (having regard to its
55
respective obligations and duties) and to ensure that the Company and the Shareholders
are fairly treated.
The Depositary may delegate to third parties the safe-keeping of the Company’s assets
subject to the conditions laid down in the applicable laws and regulations and the provisions
of the Depositary Agreement. The process of appointing such delegates and their continuing
oversight follows the highest quality standards, including the management of any potential
conflict of interest that should arise from such an appointment. Such delegates must be
subject to effective prudential regulation (including minimum capital requirements,
supervision in the jurisdiction concerned and external periodic audit) for the custody of
financial instruments. The Depositary’s liability shall not be affected by any such delegation.
A potential risk of conflicts of interest may occur in situations where the delegates may enter
into or have a separate commercial and/or business relationships with the Depositary in
parallel to the custody delegation relationship.
In order to prevent such potential conflicts of interest from crystallizing, the Depositary has
implemented and maintains an internal organisation whereby such separate commercial and
/ or business relationships have no bearings on the choice of the delegate or the monitoring
of the delegates’ performance under the delegation agreement.
A list of these delegates and sub-delegates (hereafter the “Sub-Custodians”) for its
safekeeping duties is available on the website:
https://securities.cib.bnpparibas/app/uploads/sites/3/2021/11/ucitsv-list-of-delegates-
sub-delegates-en.pdf
Such list may be updated from time to time. Updated information on the Depositary’s
custody duties, a list of delegations and sub-delegations and conflicts of interest that may
arise, may be obtained, free of charge and upon request, from the Depositary.
BNP Paribas, Luxembourg Branch, being part of a group providing clients with a worldwide
network covering different time zones, may entrust parts of its operational processes to
other BNP Paribas Group entities and/or third parties, whilst keeping ultimate accountability
and responsibility in Luxembourg. The entities involved in the support of internal
organisation, banking services, central administration and transfer agency service are listed
in the website: https://securities.cib.bnpparibas/luxembourg/. Further information on BNP
Paribas, Luxembourg Branch international operating model linked to the Company may be
provided upon request by the Company and/or the Management Company.
The Management Company acting on behalf of the Company may release the Depositary
from its duties with ninety (90) days written notice to the Depositary. Likewise, the
Depositary may resign from its duties with ninety (90) days written notice to the Company.
In that case, a new depositary must be designated to carry out the duties and assume the
responsibilities of the Depositary, as defined in the agreement signed to this effect. The
replacement of the Depositary shall happen within two months.
BNP Paribas, Luxembourg Branch shall also act as paying agent for the Company in
connection with the receipt of payments in respect of the issue of shares, the payment of
monies in respect of the repurchase of shares and if applicable the payment of dividends.
In consideration of its services as Depositary, BNP Paribas, Luxembourg Branch will receive
a depositary fee out of the assets of the Company as specified in the Sub-Funds’ specifics in
Part B of the Prospectus.
56
15. MONEY LAUNDERING PREVENTION
Any Shareholder will have to establish its identity to the Company, the Central
Administration or to the intermediary which collects the subscriptions, provided that the
intermediary is regulated and located in a country that imposes an identification obligation
equivalent to that required under Luxembourg law (including the law of November 12, 2004
as amended and the circulars issued by the CSSF).
In order to appropriately identify the beneficial owners of the funds invested in the Company
and to contribute to the fight against money laundering and financing of terrorism,
subscription requests to the Company by Shareholders must include:
- in the case of natural persons: a certified and valid copy of the investor ’s identity
card or passport (certification by one of the following authorities: embassy,
consulate, notary, high commission of the country of issue, police commissioner,
bank domiciled in a country that imposes an identification obligation equivalent to
that required under Luxembourg law or any other competent authority) and utility
bill;
- for corporate entities: an original or a certified and valid copy of the Articles, an
extract of the register of commerce, the list of Shareholders of the company and the
identification documents of those holding more than 25% of the assets of the
company (certification by one of the following authorities: embassy, consulate,
notary, high commission of the country of issue, police commissioner, bank domiciled
in a country that imposes an identification obligation equivalent to that required
under Luxembourg law or any other competent authority);
It is generally accepted that professionals of the financial sector resident in a country which
has ratified the recommendations of the FATF are deemed to be intermediaries having an
identification obligation equivalent to that required under the applicable law. The complete
updated list of countries having ratified the recommendations of the FATF is available on
www.fatf-gafi.org.
The Central Administration of the Company may require at any time additional
documentation relating to an application for shares.
57
16. NOMINEES
In such case, the Nominee shall, in its name but as nominee for the investor, purchase,
request the conversion or request the redemption of shares for the investor and request
registration of such operations in the Company's books. However, the investor:
a) may invest directly in the Company without using the Nominee service;
c) may terminate the mandate at any time with prior written notice.
The provisions under a), b) and c) are not applicable to Shareholders solicited in countries
where the use of the service of a nominee is necessary or compulsory for legal, regulatory
or compelling practical reasons.
The Company will ensure that the Nominee presents sufficient guarantees for the proper
execution of its obligations toward the Shareholders who utilise its services. In particular,
the Company will ensure that the Nominee is a professional duly authorised to render
nominee services and domiciled in a country in which it is legally obliged to use an
identification procedure equivalent to the one required by Luxembourg law in the fight
against money laundering and terrorist financing.
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17. EXPENSES
The Company may bear the following expenses, at the Board of Directors discretion:
- all fees to be paid to the Management Company, the Central Administration, the
Investment Manager(s) (if any), the Investment Advisor(s) (if any), the Depositary
and any other agents that may be employed from time to time;
- all taxes which may be payable on the assets, income and expenses chargeable to
the Company;
- all expenses involved in registering and maintaining the Company registered with all
governmental agencies and stock exchanges;
- the remuneration of the Directors, the insurance of Directors if any, and their
reasonable out-of-pocket expenses;
- all other fees and expenses incurred in connection with its operation, administration,
management and distribution.
The attention of Shareholders is drawn to the fact that some of the above listed expenses
may be payable to the Management Company on top of the Management Fee.
All recurring expenses will be charged first against current income, then should this not be
sufficient, against realised capital gains, and, if need be, against assets.
Each Sub-Fund shall amortise its own expenses of establishment over a period of five (5)
years as of the date of its creation. The expenses of first establishment will be exclusively
charged to the Sub-Funds opened at the incorporation of the Company and shall be
amortised over a period not exceeding five (5) years.
Any costs, which are not attributable to a specific Sub-Fund, incurred by the Company will
be charged to all Sub-Funds in proportion to their average Net Asset Value. Each Sub-Fund
will be charged with all costs or expenses directly attributable to it.
The different Sub-Funds of the Company may have one or several investment advisors
and/or investment managers. The Board of Directors of the Company determine their
investment policy and its application to the different Sub-Funds in question. Under
Luxembourg law, the Company including all its Sub-Funds is regarded as a single legal
entity. However, pursuant to article 181 of the Investment Fund Law, as amended, each
Sub-Fund shall be liable for its own debts and obligations. In addition, each Sub-Fund will
59
be deemed to be a separate entity having its own contributions, capital gains, losses,
charges and expenses.
The Company is required to indemnify, out of its assets only, officers, employees and agents
of the Company, if any, and the Board of Directors for any claims, damages and liabilities to
which they may become subject because of their status as managers, officers, employees,
agents of the Company or Board of Directors, or by reason of any actions taken or omitted
to be taken by them in connection with the Company, except to the extent caused by their
gross negligence, fraud or willful misconduct or their material breach of the provisions of the
Prospectus.
Finally, the Company will, in addition, bear the following costs, charges and expenses which
shall be deducted from the assets comprising the Company:
- the costs charged by the Management Company and third-party service providers/data
vendors in relation to SFDR regulatory matters, management, risk and the compliance
monitoring services as well as for the provision of the black-lists for ethical checks and for
the indications relating to Socially Responsible Principles investments;
- the cost of preparing and/or filing and printing of the Articles and all other documents
concerning the Fund, including the Prospectus, Key (Investor) Information Documents,
SFDR regulatory documents and explanatory memoranda and any amendments or
supplements thereto;
- all costs related to any new regulations the Company or the Management Company should
comply with.
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18. NOTICES AND PUBLICATION
Notices to Shareholders are available at the Company's registered office and on the
Management Company’s website - www.lfde.com. In addition, if required by law, they will
also be published in the RESA and in the “d’Wort” in Luxembourg and in other newspapers
circulating in jurisdictions in which the Company is registered as the Directors may
determine.
The Net Asset Value of each Sub-Fund and the issue and redemption prices thereof will be
available at all times at the Company's registered office.
Audited annual reports will be made available at the registered office of the Company no
later than four (4) months after the end of the financial year and unaudited semi-annual
reports will be made available two (2) months after the end of such period.
All reports will be available at the Company's registered office. The first financial reports
were an audited annual financial report dated 31 December 2013 and an unaudited financial
report dated 30 June 2014.
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19. LIQUIDATION OF THE COMPANY, TERMINATION OF THE SUB-FUNDS AND
CLASSES OF SHARES, CONTRIBUTION OF SUB-FUNDS AND CLASSES OF SHARES
In the event of the liquidation of the Company, liquidation shall be carried out by one (1) or
several liquidators (approved by the CSSF) appointed by the meeting of the Shareholders
deciding such dissolution and which shall determine their powers and their compensation.
The liquidators shall realise the Company's assets in the best interest of the Shareholders
and shall distribute the net liquidation proceeds (after deduction of liquidation charges and
expenses) to the Shareholders in proportion to their shares in the Company in cash or in
kind. Any amounts not claimed promptly by the Shareholders will be deposited at the close
of liquidation in escrow with the Caisse de Consignation. Amounts not claimed from escrow
within the statute of limitations will be forfeited according to the provisions of Luxembourg
law.
In accordance with the provisions of the Investment Fund Law, only the liquidation of the
last remaining Sub-Fund of the Company will result in the liquidation of the Company as
referred to in Article 145 of the Investment Fund Law. In this case, and as from the event
given rise to the liquidation of the Company, and under penalty of nullity, the issue of shares
shall be prohibited except for the purpose of liquidation.
Any amounts not claimed by any Shareholder shall be deposited at the close of liquidation
with the Depositary during a period of six (6) months; at the expiry of the six (6) months'
period, any outstanding amount will be the deposited in escrow with the Caisse de
Consignation.
Unless otherwise decided in the interest of, or in order to ensure equal treatment between
Shareholders, the shareholders of the relevant Sub-Fund or Class may continue to request
the redemption of their shares or the conversion of their shares, free of any redemption
and conversion charges (except disinvestment costs) prior the effective date of the
liquidation. Such redemption or conversion will then be executed by taking into account the
liquidation costs and expenses related thereto.
In accordance with articles 79 (4) and 79 (5) of the Investment Fund Law, the Company
shall be dissolved and liquidated if the Master Fund is liquidated, divided into two or more
UCITS or merger with another UCITS, unless the CSSF approves either (a) the investment
of at least 85% of the assets of the Company into units of another master UCITS or (b)
62
the Company’s conversion into a UCITS which is not a feeder UCITS within the meaning of
the Investment Fund Law.
19.4 Merger of Sub-Funds or Class of shares to another Sub-Fund or Class of shares within
the Company
Notice of the Merger will be given in writing to registered Shareholders and/or will be
published in newspapers circulating in jurisdictions in which the Company is registered as
the Directors may determine. Each shareholder of the relevant Sub-Funds or Classes shall
be given the possibility, within a period of at least thirty days in advance, to request the
redemption or conversion of its shares.
The Company may, either as a merging UCITS or as a receiving UCITS, be subject to cross-
border and domestic mergers in accordance with the definitions and conditions set out in
the Investment Fund Law. The Board of Directors of the Company will be competent to
decide on the effective date of such a Merger. Insofar as a Merger requires the approval of
the shareholders concerned by the Merger and pursuant to the provisions of the Investment
Fund Law, the meeting of Shareholders deciding by simple majority of the votes cast by
Shareholders present or represented at the meeting is competent to approve the effective
date of such a Merger. No quorum requirement will be applicable.
Notice of the Merger will be given in writing to registered Shareholders and/or will be
published in the RESA and the “d’Wort” in Luxembourg and in other newspapers circulating
in jurisdictions in which the Company is registered as the Directors may determine. Each
shareholder of the relevant Sub-Funds or Classes shall be given the possibility, within a
period of at least thirty days in advance, to request the redemption or conversion of its
shares.
63
20. REGULATORY INFORMATION
For the purpose of identifying the types of conflicts of interest that arise in the course of
providing services and activities and whose existence may damage the interest of the
Company, the Management Company will take into account, by way of minimum criteria,
the question of whether the Management Company or a relevant person, or a person directly
or indirectly linked by way of control to the Management Company, is in any of the following
situations, whether as a result of providing collective portfolio management activities or
otherwise: (a) the Management Company or that person is likely to make a financial gain,
or avoid a financial loss, at the expense of the Company; (b) the Management Company or
that person has an interest in the outcome of a service or an activity provided to the
Company or another client or of a transaction carried out on behalf of the Company or
another client or, which is distinct from the Company interest in that outcome; (c) the
Management Company or that person has a financial or other incentive to favour the interest
of another client or group of clients over the interests of the Company; (d) the Management
Company or that person carries on the same activities for the Company and for another
client or clients which are not UCITS; and (e) the Management Company or that person
receives or will receive from a person other than the Company an inducement in relation to
collective portfolio management activities provided to the Company, in the form of monies,
goods or services, other than the standard commission or fee for that service.
When identifying any potential types of conflict of interests, the Management Company will
take into account (a) the interests of the Management Company, including those deriving
from its belonging to a group or from the performance of services and activities, the interests
of the clients and the duty of the Management Company towards the Company as well as
(b) the interests of two or more managed UCITS.
The summary description of the strategies referred to in that paragraph will be made
available to the Shareholders on www.lfde.com.
Shareholders of each Sub-Fund of the Company may file complaints free of charge with the
Distributor or the Management Company in an official language of their home country.
Shareholders can access the complaints handling procedure on www.lfde.com.
Unless there is a loss of investor protection, the Company will not exercise voting rights in
respect of instrument held by the Company in each Sub-Fund. The decision to exercise
voting rights is only to be made within the Company’s general meeting.
The Company draws the Shareholders’ attention to the fact that any investor will only be
able to fully exercise his investor rights directly against the Company, if the investor is
registered himself and in its own name in the Shareholders’ register of the UCITS. In cases
where an investor invests in the UCITS through an intermediary investing into the UCITS in
his own name but on behalf of the Shareholder, it may not always be possible for the investor
to exercise certain shareholder rights directly against the UCITS. Shareholders are advised
to take advice on their rights.
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20.4 Best Execution
The Management Company will act in the best interests of the managed Company when
executing decision to deal on behalf of the managed Company in the context of the
management of their portfolios. For that purpose the Management Company will take all
reasonable steps to obtain the best possible results for the Company, taking into account
price, costs, speed, likelihood of execution and settlement, order size and nature, or any
other consideration relevant to the execution of the order (best execution).
The relative importance of such factors will be determined by reference to the following
criteria: (a) the objectives, investment policy and risks specific to the Company, (b) the
characteristics of the order, (c) the characteristics of the financial instruments that are the
subject of that order and (d) the characteristics of the execution venues to which that order
can be directed.
In compliance with the Benchmark Regulation, the Management Company has established
and maintains robust written plans setting out the actions to take in the event that a
benchmark materially changes or ceases to be provided. The Management Company will
make available those plans, on request and free of charges at its registered office.
65
21. DOCUMENTS
Upon request, the following documents may be consulted and obtained free of charge at the
Company's registered office, the Management Company and the Depositary:
d) if the Sub-Fund is a Feeder Sub-Fund, the related Master Fund’s prospectus, statutes,
annual and semi-annual financial reports and key information documents;
e) the Collective Portfolio Management Agreement between the Company and the
Management Company;
f) the Administration Agreement between the Company, the Management Company and
the Central Administration;
The Feeder and the Master Funds are managed by the same Management Company.
Shareholders may obtained information free of charge about the internal rules defined in
order to insure the exchange of information between the Feeder and the Master Funds.
66
PART B: THE SUB-FUNDS
67
ECHIQUIER AGENOR SRI MID CAP EUROPE FUND
SUB-FUND SPECIFICS
The Sub-Fund “Echiquier Agenor SRI Mid Cap Europe Fund” is a dynamically managed
Sub-Fund whose investment objective is long-term performance through exposure to
European equity markets, investing in growth-style companies.
In addition to the ESG investment policy described, the Sub-Fund might further exclude
some sectors of activity and financial instruments with ESG scoring below 5,5.
The MSCI Europe Mid Cap Index Net Return EUR is a representative indicator of the
management objective of the Sub-Fund. It is not consistent with environmental and social
characteristics promoted by this Sub-Fund. This index, which is used solely for information
purposes, shows the development of all shares in small and mid-cap European companies.
It is calculated in EUR and dividends are reinvested.
The Sub-Fund systematically integrates ESG criteria into financial management. The
manager endeavours to select the issuers with the best non-financial scorings in their
investment universe to result in a selectivity rate (reduction of the Mid Cap European equity
market investment universe) of at least 25%. These scorings are determined by the
Management Company and applied to the entire portfolio.
The Sub-Fund invests at least 40% of its assets into Sustainable Investments.
The Sub-Fund has an exposure of at least 50% to European equities and no more than 25%
to non-European equities. It is exposed mostly to European small and mid-caps, i.e. stocks
with a market capitalisation up to EUR 10 billion at investment.
The Sub-Fund reserves the option to invest a maximum of 25% in fixed-income products.
The bonds in question are securities deemed “Investment grade”, i.e. rated at least BBB-
by Standard & Poor’s or equivalent.
68
- Hedging the portfolio against currency risk, and also, to a lesser extent, against equity
risk when the manager anticipates a sharp drop in market performance;
- Exposing the portfolio from time to time to equity risk during periods of heavy
subscription. Under no circumstances whatsoever does the Sub-Fund adopts a strategy
overexposing the portfolio to equity risk.
On an ancillary basis, the Sub-Fund may invest in units/shares of UCITS and/or other UCIs
up to 10% of its net assets.
The Sub-Fund may invest in securities with embedded derivatives (warrants, subscription
certificates, etc.) traded on eurozone and/or international regulated markets or over the
counter. The use of embedded derivatives, as opposed to the other derivative instruments
listed above, will mainly be as a result of the Sub-Fund seeking to optimise the hedging
strategy, or, if appropriate, to improve the performance of the portfolio by reducing the
costs related to the use of these financial instruments in order to achieve the investment
objective. In any event, the amounts invested in securities with embedded derivatives
cannot exceed 10% of the net assets. The risk associated with this type of investment will
be limited to the amount invested in the purchase.
The Sub-Fund may hold ancillary liquid assets within the limits foreseen in the Investment
Fund Law.
The Sub-Fund will not enter into repurchase/reverse repurchase transaction, securities
lending, margin lending transaction and buy-sell back or sell-buy back transaction, and will
not invest in TRS or Contracts for Difference (CFD). As a result, the Sub-Fund is not subject
to the Regulation (EU) 2015/2365 on transparency of securities financing transactions and
of reuse.
Besides, the Sub-Fund may invest (up to 10% of its net assets) in companies at initial public
offering (“IPO”) (i.e. offering of shares of a private corporation to the public in a new stock
issuance) after a convincing discretionary analysis.
The Sub-Fund may also invest (up to 10% of its net assets) in special purpose acquisition
companies (“SPACs”), which are companies only formed to raise capital through an IPO for
the purpose of acquiring or merging with an existing company and qualifying as eligible
investments as per article 41 of the Investment Fund Law.
The examples of indicators used for each of the E, S, and G criteria are as follows:
• Environmental indicators: environmental policy and actions, results of action plans
put in place by the company, exposure of suppliers to environmental risks, positive
or negative impact of products on the environment.
• Social indicators: attractiveness of the employer brand, employee retention, anti-
discrimination, employee protection, exposure of suppliers to social risks, relations
with civil society;
• Governance indicators: competence of the management team, checks and
balances, respect for minority shareholders, business ethics.
The Sub-Fund focuses on selecting the top-rated issuers from an extra-financial perspective
within their investment universe (“best in universe” approach). The Sub-Fund also invests
in companies that have adopted a CSR approach and have an improving momentum in their
ESG practices (“best efforts” approach).
69
The Sub-Fund applies two extra-financial filters in its stock-picking: after controversial
sectors and practices are excluded, stocks must meet a minimum ESG rating requirement.
These ratings are determined by the Management Company and applied to the entire
portfolio.
The ESG rating is out of 10 and is awarded to each issuer. This score is determined as
follows:
• Governance: The Governance rating represents approximately 60% of the overall
ESG score. This is a long-standing bias for La Financière de l’Echiquier, which has
attached particular importance to this subject since the company’s creation.
• Environmental and Social: Social and environmental criteria are combined to
determine a “Responsibility score”. Its calculation takes into account the type of
company:
- for industrial stocks: the social and environmental criteria are equally
weighted in the Responsibility score.
- for service stocks: the “Social” score accounts for 2/3 of the “Responsibility”
score, while the “Environmental” score represents 1/3 of the “Responsibility”
score.
The ESG rating of issuers in the portfolio must always be equal to 100%.
If a company’s rating falls below the minimum required by the Management Company for
the Sub-Fund, the position in the issuer would be sold in the best interests of the
Shareholders.
2. Risk Profile
The loss of capital arises when a unit is sold at a lower price than its purchase value.
Unitholders are informed that the capital initially invested may not be returned. The Sub-
Fund has no capital guarantee or protection.
The Sub-Fund has exposure of at least 60% to equities. If the equities or indices to which
the portfolio is exposed decline, the net asset value of the Sub-Fund could fall. On small-
and medium-cap markets, the volume of securities listed on the stock exchange is relatively
less, and therefore market downturns are more significant and rapid than on large-cap
markets. The net asset value of the Sub-Fund can therefore fall more rapidly and more
sharply.
The discretionary management style applied to the Sub-Fund relies on stock selection. There
is a risk that at any given point in time the Sub-Fund will not be invested in the best-
70
performing stocks. The Sub-Fund's performance can therefore fall below the investment
objective. The net asset value of the Sub-Fund can also show negative performance.
The Sub-Fund has exposure of no more than 25% to fixed-income products. The net asset
value of the Sub-Fund can fall if interest rates rise.
Up to 25% of the Sub-Fund is exposed to money market instruments or bonds. The credit
risk corresponds to the risk of a private issuer's credit quality falling or the issuer defaulting.
The value of the debt securities or bonds in which the Sub-Fund is invested can fall, causing
a drop in the Sub-Fund's net asset value.
This concerns the risk of a decline in investment currencies relative to the portfolio's
benchmark currency, the euro. If a currency falls relative to the euro, the Sub-Fund's net
asset value could fall.
This concerns the risk of non-achievement of the derivatives’ intended objectives and
involves additional risks inherent to these instruments as more described in section “Risk
factors” of Part A of this Prospectus.
These securities may be subject to greater volatility than more established securities as a
result of factors such as the absence of a past public market offering, non-seasonal
transactions, the number of securities that can be traded and a lack of information about
the issuer. Investing in these securities can lead to an increase of the possible expenses as
well as a shorter holding time periods. Moreover, the investment in initial public offering can
have a significant impact on the Sub-Fund’s performance.
These securities may be subject to specific risks such as dilution, liquidity, conflicts of
interests or the uncertainty as to the identification, evaluation as well as eligibility of the
target company and can be hard to evaluate because of a lack of trading history and relative
lack of public information. Moreover, the structure of SPACs can be complex and their
characteristics may vary largely from one SPAC to another, meaning that the Management
Company will study each SPAC individually to ensure compliance with article 41 of the
Investment Fund Law.
4. Valuation Date
The Valuation Date of this Sub-Fund will be each full Bank Business Day as defined in section
“Net Asset Value” in Luxembourg.
5. Subscription
Shares are available for subsequent subscriptions on each Valuation Date on a forward
pricing base.
Applications for shares must be received by the Registrar and Transfer Agent on the
Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt with
on the basis of the Net Asset Value per Share applicable on that Valuation Date. Applications
for shares received by the Registrar and Transfer Agent after that cut-off time will be dealt
with on the next Valuation Date.
Shareholders are entitled to redeem their Shares on each Valuation Date on a forward pricing
base. Applications for redemptions must be received by the Registrar and Transfer Agent on
the Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt
with on the basis of the Net Asset Value per Share applicable on that Valuation Date.
Applications for redemptions received by the Registrar and Transfer Agent after that cut-off
time will be dealt with on the next Valuation Date.
Redemption proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date and after receipt of the
proper documentation.
Applications for conversion must be received by the Registrar and Transfer on the Valuation
Date until 10:00 a.m. Luxembourg time to be dealt with on the basis of the Net Asset Value
per Share applicable on that Valuation Date. Applications for conversion received by the
Registrar and Transfer Agent after that cut-off time will be dealt with on the next Valuation
Date.
The Classes available in this Sub-Fund are listed in the table below. The Classes are either
accumulating or distributing classes according to information in section “Income Policy” in
Part A of this Prospectus.
72
Initial
Hedged
minimum
against Initial
Income Curre subscripti
Classes currency Investors Share
policy ncy on and
exposur Amount
holding
e
amount
Institutional
investors and EUR
K (EUR) Accumulation EUR NO
financial 100,000.-
EUR 1,000.-
intermediaries
Institutional
investors and USD USD
K (USD) Accumulation USD NO
financial 100,000.- 1,000.-
intermediaries
Institutional
investors and CHF
K (CHF) Accumulation CHF NO
financial
CHF 1,000.-
100,000.-
intermediaries
Institutional
investors and GBP
K (GBP) Accumulation GBP NO
financial 100,000.-
GBP 1,000.-
intermediaries
The initial minimum subscription and holding amount for classes K are valid for investors
whose first subscription takes place from September 16, 2019. For investors present in the
Sub-Fund before this date, there is no minimum.
The Company may in its discretion waive minimum subscription and/or holding amounts. In
such latter case, the Company will ensure that concerned investors are equally treated.
73
8. Expenses
An investor who subscribes converts or redeems shares through paying agents may be
required to pay fees connected to the transactions processed by said paying agents in the
jurisdictions in which shares are offered.
The Key Information Document(s) issued for the Classes of shares also contain additional
information on ongoing charges incurred by the Sub-Fund.
74
ECHIQUIER ARTY SRI FUND
SUB-FUND SPECIFICS
The Sub-Fund “Echiquier Arty SRI Fund” is a Feeder Fund of the Master Fund
“Echiquier Arty SRI“, a sub-fund of a SICAV constituted under French laws and
qualifying as a master UCITS under Directive 2009/65/EC, meaning that it invests in
practice substantially all of its assets into the Master Fund and will therefore hold virtually
no or very low percentage of its assets in ancillary liquid assets. The Sub-Fund invests in the
share classes “Echiquier Arty SRI” of the Master Fund. Therefore, this addendum shall be
read in conjunction with the prospectus of the Master Fund “Echiquier Arty SRI”.
The Master Fund, established on 30 May 2008, appointed La Financière de l’Echiquier S.A.
as its management company, being also the Management Company of the Sub-Fund. It
must, at all times, (i) have at least one feeder UCITS among its shareholders, (ii) not itself
become a feeder UCITS, and (iii) not hold shares or units of a feeder UCITS.
The Sub-Fund invests at least 85% of its assets in “Echiquier Arty SRI” units of the
Master Fund “Echiquier Arty SRI” as there terms are defined in the prospectus of the Master
Fund, i.e. capitalization or income units dedicated to all investors or institutional investors.
This objective is associated with an extra-financial approach in compliance with the
provisions of Article 8 of SFDR, including an allocated percentage to Sustainable Investments
and integrating the consideration of Sustainability Risk and ESG criteria as described in Part
A, Section 4. This extra-financial objective/approach of the Sub-Fund is to contribute to the
progress of companies on ESG issues by engaging with them in regular dialogue and by
sharing with them specific areas for improvement that are monitored over time.
The up to 15% residual assets of the Sub-Fund are invested in Ancillary liquid assets only
as may be required from time to time for dealing liquidity purposes and payment of costs
and expenses of the Sub-Fund. The Sub-Fund intends to minimize the level of ancillary liquid
assets held for these purposes.
The Sub-Fund will not enter into financial derivative instruments apart from hedging the
currency exposure of Classes of share not denominated in EUR.
The Sub-Fund will not enter into repurchase/reverse repurchase transaction, securities
lending, margin lending transaction and buy-sell back or sell-buy back transaction, and will
not invest in TRS or Contracts for Difference (CFD). As a result, the Sub-Fund is not subject
to the Regulation (EU) 2015/2365 on transparency of securities financing transactions and
of reuse.
75
The Master Fund targets short and medium-term performance through discretionary and
opportunity management on fixed-income and equity markets.
The composite index 25% €STR capitalised + 25% MSCI EUROPE Net Return + 50% IBOXX
EURO CORPORATE 3-5 may be a representative indicator for the management objective of
the Master Fund. The composite index is not consistent with environmental and social
characteristics promoted by the Master Fund. It is used solely for information purposes and
is calculated in Euros, with dividends reinvested. The investment universe is thus made up
of the three market indices comprising the Master Fund’s benchmark index.
This objective is combined with a non-financial approach incorporating ESG criteria. The
non-financial objective is to help companies move forward on ESG issues by engaging in
dialogue with them on a regular basis and by sharing with them specific areas of
improvement monitored over time.
The Master Fund invests at least 40% of its assets into Sustainable Investments.
The management of the Master Fund is based on ‘bond picking’ for fixed-income markets
and on ‘stock picking’ for equity markets, and relies on discretionary management:
- For equities, the “stock picking” selection is obtained through the implementation of a
process that involves direct contact with the companies in which the Sub-Fund invests. This
management is based on a fundamental analysis of each file, supported by an internally
developed rating based on several criteria, including:
The Master Fund invests between 0% and up to 50% of its assets in equities. The Master
Fund invests mainly in medium and large capitalisations. However, the Master Fund may
invest in small capitalisations (i.e. under 1 billion euros) up to 10% of its assets. Investment
in equities will be made in actions of European Union, EFTA countries and the United
Kingdom (the “Europe Zone”). The Master Fund reserves the right to invest a maximum of
15% of its assets in listed equities in a country outside the Europe Zone, including emerging
markets.
- For interest rate products, the Master Fund has a minimum exposure of 40% to bonds or
negotiable debt securities. The percentage of negotiable debt securities and bonds not
deemed ‘Investment grade’ (at least Standard & Poor’s BBB- rating or equivalent) must not
exceed respectively 35% (for bonds) and 15% (for negotiable debt securities) of the net
assets. The Master Fund invests in negotiable debt securities and bonds in countries from
the Europe Zone. However, the Master Fund may invest up to 10% in bonds outside the
Europe Zone, including emerging markets. The Master Fund can also invest up to a
maximum of 40% of its net assets in subordinated bonds issued by the banking, insurance
and corporate sectors, including a maximum of 10% in contingency convertible bonds
(known as "coco" bonds). This investment portfolio will be managed within a sensitivity
range between 0 and 8.
The Master Fund may also invest in securities with embedded derivatives:
- Bonds with early redemption options: the manager may use these bonds ("callable"
or puttable") throughout the bond portfolio;
76
- Contingent convertible bonds in the financial sector: the manager may trade in these
securities up to a limit of 10% of the net assets;
- Other securities with embedded derivatives: the manager may invest up to 10% of
the net assets in securities with embedded derivatives (warrants, convertible bonds,
etc.) traded on regulated or over-the-counter markets. No rating constraints apply
to convertible bonds.
The Master Fund may operate in the market for forward financial instruments in order to:
- Reduce the portfolio’s exposure to equity markets, and to currency and interest rate
risks;
- Exceptionally expose the portfolio to currency, fixed-income and equity risks. Under no
circumstances whatsoever does the Sub-Fund intend to adopt a strategy overexposing
the portfolio to these different risks.
The Master Fund is not permitted to invest in securitisation products (ABS, CDO, etc.) or
credit derivatives (e.g. CDS) traded over the counter.
The examples of indicators used for each of the E, S, and G criteria are as follows:
• Environmental indicators: environmental policy and actions, results of action plans
put in place by the company, exposure of suppliers to environmental risks, positive
or negative impact of products on the environment;
• Social indicators: attractiveness of the employer brand, employee retention, anti-
discrimination, employee protection, exposure of suppliers to social risks, relations
with civil society;
• Governance indicators: competence of the management team, checks and balances,
respect for minority shareholders, business ethics.
The Master Fund focuses on selecting the top-rated issuers from a non-financial perspective
within their investment universe (“best in universe” approach). This Master Fund also invests
in companies that have adopted a CSR approach and have an improving momentum in their
ESG practices (“best efforts” approach). The Master Fund applies two non-financial filters in
its stock-picking: after controversial sectors and practices are excluded, stocks must meet
a minimum ESG rating requirement.
The ESG rating is out of 10 and is awarded to each issuer. This score is determined as
follows:
• Governance: The Governance rating represents approximately 60% of the overall
ESG score. This is a long-standing bias for La Financière de l’Echiquier, which has
attached particular importance to this subject since the company’s creation;
• Environmental and Social: Social and environmental criteria are combined to
determine a “Responsibility” score. Its calculation takes into account the type of
company:
- for industrial stocks: the social and environmental criteria are equally weighted in
the “Responsibility” score.
- for service stocks: the “Social” score accounts for 2/3 of the “Responsibility” score,
while the “Environmental” score represents 1/3 of the “Responsibility” score.
The ESG rating of issuers in the portfolio must always be equal to 95%. This rating may be
lowered if significant controversy arises.
77
If a company’s rating falls below the minimum required by the management company for
the Master Fund, the position in the issuer would be sold in the best interests of the
unitholders/ shareholders.
This ESG approach results in a selectivity rate (reduction of the investment universe) of at
least 20%.
The SRI analysis approach for companies put in place by La Financière de l’Echiquier is based
on a qualitative analysis of these players’ environmental, social and governance practices.
A number of limitations may be identified, in connection with the management company’s
methodology but also more broadly with the quality of the information available on these
issues.
For more detailed information on the rating methodology used for the Master Fund and its
limits, investors should refer to the Transparency Code of La Financière de l’Echiquier
available on www.lfde.com.
2. Risk Profile
It is intended that the performance of the various Classes of shares offered by the Sub-Fund
will be similar to that of the “Echiquier Arty SRI” units of the Master Fund. However, the
performance of both funds will not be equal due, in particular, to costs and expenses incurred
by the Sub-Fund and the reference currency of the Classes of shares that may differ from
that of the Master Fund.
The risk profile of the Sub-Fund is similar to the risk profile of the Master Fund as follows:
The discretionary management style is based on anticipating trends on the different markets
(equities, bonds, derivatives) and on the selection of securities. There is a risk that at any
given point in time the Master Fund will not be invested on the best-performing markets or
stocks.
The loss of capital arises when a unit is sold at a lower price than its purchase value.
Unitholders are informed that the capital initially invested may not be returned. The Master
Fund has no capital guarantee or protection.
78
The Master Fund invests a minimum of 40% of its assets in fixed-income products. The net
asset value of the Master Fund can fall if interest rates rise.
The Master Fund has exposure of at least 40 % to money market instruments and bonds.
Credit risk, due, in particular, to investment in "speculative securities", corresponds to the
risk of a private issuer's credit quality falling or the issuer defaulting. The value of the debt
securities or bonds in which the Master Fund is invested can fall, causing a drop in the Master
Fund's net asset value. This risk is greater as the Master Fund may invest in non-investment
grade securities, which may be speculative in nature, and, on an ancillary basis, in unrated
securities.
The Master Fund invests a maximum of 50% of its assets in equities. If the equities or indices
to which the portfolio is exposed decline, the net asset value of the Master Fund could fall.
On small- and medium-cap markets, the volume of securities listed on the stock exchange
is relatively less, and therefore market downturns are more significant and rapid than on
large-cap markets. The net asset value of the Master Fund can therefore fall more rapidly
and more sharply.
This concerns the risk of a decline in investment currencies relative to the portfolio's
benchmark currency, the euro. If a currency falls relative to the euro, the Master Fund's net
asset value could fall.
The Master Fund specifically invests in "high yield speculative securities". Since the volume
of trades negotiated on these types of instruments can be reduced, consequently market
movements may be more pronounced, both upward and downward.
This concerns the risk of non-achievement of the derivatives’ intended objectives and
involves additional risks inherent to these instruments as more described in section “Risk
factors” of Part A of this Prospectus.
The Management Company's risk management process as applicable to the Master Fund
reflects the investment objectives and policy of the Master Fund. Upon request, Shareholders
can receive further information from the Management Company in relation to the Master
Fund's risk management. These risks are further described in section “Risk factors” of Part
A of this Prospectus.
Generally, the profile of the typical investor for whom the Feeder Sub-Fund has been
designed is an investor wishing to invest in the Master Fund and who is prepared to accept
fluctuations in the value of its investment and the risks associated with investing in the
Master Fund through the Feeder Sub-Fund, as described in the section on "Risk Factors"
of this Prospectus and in the prospectus of the Master Fund.
79
Investors should note that investment of the Sub-Fund is not suitable for UCITS since the
Sub-Fund invests at least 85% of its assets in the Master Fund.
4. Valuation Date
The Valuation Date of this Sub-Fund will be each full Bank Business Day as defined in section
“Net Asset Value” that corresponds to valuation dates of the Master Fund. As a result, the
Valuation Date of the Sub-Fund will be each full bank business day in Luxembourg and in
France.
5. Subscription
Shares are available for subsequent subscriptions on each Valuation Date on a forward
pricing base.
Applications for shares must be received by the Registrar and Transfer Agent on the
Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt with
on the basis of the Net Asset Value per Share applicable on that Valuation Date. Applications
for shares received by the Registrar and Transfer Agent after that cut-off time will be dealt
with on the next Valuation Date.
Subscription proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date.
The Directors may, at their sole discretion, accept subscriptions below minimum as stated
in the table below.
Shareholders are entitled to redeem their Shares on each Valuation Date on a forward pricing
base. Applications for redemptions must be received by the Registrar and Transfer Agent on
the Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt
with on the basis of the Net Asset Value per Share applicable on that Valuation Date.
Applications for redemptions received by the Registrar and Transfer Agent after that cut-off
time will be dealt with on the next Valuation Date.
The Master Fund has a redemption gate mechanism, which may have an impact on the
redemptions of Shares of the Sub-Fund. If on a given dealing day of the Master Fund, the
sum of redemption requests minus the sum of subscription requests represents more than
five per cent (5%) of the net assets, the management company of the Master Fund may
decide to trigger the redemption gate mechanism. The management company of the Master
Fund may decide to redeem shares above the 5% threshold if the liquidity conditions allow
it. Should this gate mechanism be applied, Shareholders will be informed via a specific
mention on the Management Company’s website.
Redemption proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date and after receipt of the
proper documentation.
80
Applications for conversion must be received by the Registrar and Transfer Agent on the
Valuation Date until 10:00 a.m. Luxembourg time to be dealt with on the basis of the Net
Asset Value per Share applicable on that Valuation Date. Applications for conversion received
by the Registrar and Transfer Agent after that cut-off time will be dealt with on the next
Valuation Date.
The Classes available in this Sub-Fund are listed in the table below. The Classes are either
accumulating or distributing classes according to information in section “Income Policy” in
Part A of this Prospectus.
Initial
Hedged minimum
Initial
Income Curren against subscripti
Classes Investors Share
policy cy currency on and
Amount
exposure holding
amount
Management
companies from
the LBP AM group Other
or other institutional
institutional EUR
I (EUR) Accumulation EUR NO
investors
investors:
EUR 1,000.-
subscribing a
minimum amount 1,000,000.-
of EUR 1,000,000.
-
Management Other
companies from institutional
the LBP AM group USD
I (USD) Accumulation USD NO
or other
investors:
1,000.-
USD
institutional
1,000,000.-
investors
81
subscribing a
minimum amount
of USD 1,000,000.
-
Management
companies from
the LBP AM group Other
or other institutional
institutional CHF
I (CHF) Accumulation CHF NO
investors
investors:
1,000.-
CHF
subscribing a
minimum amount 1,000,000.-
of CHF 1,000,000.
-
Management
companies from
the LBP AM group Other
or other institutional
institutional GBP
I (GBP) Accumulation GBP NO
investors
investors:
1,000.-
GBP
subscribing a
minimum amount 1,000,000.-
of GBP 1,000,000.
-
Dedicated to
marketing by
G (EUR) Accumulation EUR NO
financial
None EUR 1,000.-
intermediaries
Dedicated to
marketing by USD
G (USD) Accumulation USD NO
financial
None
1,000.-
intermediaries
Dedicated to
marketing by
G (CHF) Accumulation CHF NO
financial
None CHF 1,000.-
intermediaries
Dedicated to
marketing by
G (GBP) Accumulation GBP NO
financial
None GBP 1,000.-
intermediaries
Dedicated to
G (EUR) - marketing by
Income EUR NO None EUR 1,000.-
Inc financial
intermediaries
The Company may in its discretion waive minimum subscription and/or holding amounts. In
such latter case, the Company will ensure that concerned investors are equally treated.
8. Expenses
The Sub-Fund is investing in the Master Fund. At the level of the Master Fund, the fees,
charges and expenses associated with such investment are (i) an annual management fee
and (ii) other expenses of the Master Fund, as described in its prospectus. Details on the
actual charges and expenses incurred at the level of the Master Fund are available on the
website of the Management Company at www.lfde.com. The KID(s) issued for each Share
Class also contain additional information on ongoing charges incurred by the Company
(aggregated with the charges incurred at the level of the Master Fund).
In compliance with the provisions of point IX C) of section 4.2 under Chapter 4 “Investment
Objectives and Policies” above, no subscription or redemption fees will be charged to the
Sub-Fund when investing in the Master Fund.
83
Classe Subs Conve Man Mana Rebate Max Perfor Centr Depo Annu
s cripti rsion age geme grante Managem manc al sitary al
on Fee ment nt d by ent Fee, e Fee Admi Fee Tax
Fee Fee Fee the including nistra
feed Mast Manag the fees tion
er er ement at the Fee
Fund Compa Master
ny to Fund’s
the level and
feeder the
* rebate
granted
by the
Managem
ent
Company
*
Max None Max
Max Max
A 3% Min Max EUR Max 0.05
1.50 1.50 None
(EUR) 95% 1.50% 20,00 0.01% %
% %
0
Max None Max
Max Max
A 3% Min Max EUR Max 0.05
1.50 1.50 None
(USD) 95% 1.50% 20,00 0.01% %
% %
0
Max None Max
Max Max
A 3% Min Max EUR Max 0.05
1.50 1.50 None
(CHF) 95% 1.50% 20,00 0.01% %
% %
0
Max None Max
Max Max
A 3% Min Max EUR Max 0.05
1.50 1.50 None
(GBP) 95% 1.50% 20,00 0.01% %
% %
0
Max None Max
Max
R 3% Max Min EUR Max 0.05
1.50 Max 2% None
(EUR) 2% 95% 20,00 0.01% %
%
0
Max None Max
Max
R 3% Max Min EUR Max 0.05
1.50 Max 2% None
(USD) 2% 95% 20,00 0.01% %
%
0
Max None Max
Max
R 3% Max Min EUR Max 0.05
1.50 Max 2% None
(CHF) 2% 95% 20,00 0.01% %
%
0
Max None Max
Max
R 3% Max Min EUR Max 0.05
1.50 Max 2% None
(GBP) 2% 95% 20,00 0.01% %
%
0
Max None Max
Max
I 3% Max0 Min Max EUR Max 0.01
1.50 None
(EUR) ,90% 95% 0,90% 20,00 0.01% %
%
0
84
Max None Max
Max Max
I 3% Min Max USD Max 0.01
0,90 1.50 None
(USD) 95% 0,90% 20,00 0.01% %
% %
0
Max None Max
Max Max
I 3% Min Max CHF Max 0.01
0,90 1.50 None
(CHF) 95% 0,90% 20,00 0.01% %
% %
0
Max None Max
Max Max
I 3% Min Max GBP Max 0.01
0,90 1.50 None
(GBP) 95% 0,90% 20,00 0.01% %
% %
0
Max None Max
Max Max
D 3% Min Max EUR Max 0.05
1.50 1.50 None
(EUR) 95% 1.50% 20,00 0.01% %
% %
0
Max None Max
Max Max
D 3% Min Max USD Max 0.05
1.50 1.50 None
(USD) 95% 1.50% 20,00 0.01% %
% %
0
Max None Max
Max Max
D 3% Min Max CHF Max 0.05
1.50 1.50 None
(CHF) 95% 1.50% 20,00 0.01% %
% %
0
Max None Max
Max Max
D 3% Min Max GBP Max 0.05
1.50 1.50 None
(GBP) 95% 1.50% 20,00 0.01% %
% %
0
Max
Max Max
G Max Min Max EUR Max 0.05
None 1.10 1.10 None
(EUR) 3% 95% 1.10% 40,00 0.01% %
% %
0
Max
Max Max
G Max Min Max EUR Max 0.05
None 1.10 1.10 None
(USD) 3% 95% 1.10% 40,00 0.01% %
% %
0
Max
Max Max
G Max Min Max EUR Max 0.05
None 1.10 1.10 None
(CHF) 3% 95% 1.10% 40,00 0.01% %
% %
0
Max
Max Max
G Max Min Max EUR Max 0.05
None 1.10 1.10 None
(GBP) 3% 95% 1.10% 40,00 0.01% %
% %
0
Max
G Max Max
Max Min Max EUR Max 0.05
(EUR) 3%
None 1.10 1.10
95% 1.10%
None
40,00 0.01% %
- Inc % %
0
*All or a portion of management fees charged at the level of the Master Fund are rebated to the Feeder Sub-
Fund by the Management Company and the management fee payable by the Sub-Fund for each Class offered
is set at such rates so as to ensure that, for any given Class, the aggregate amount of the management fee
for that Class and the management fee payable at the level of the Master Fund for the “Arty” Class (in which
the Sub-Fund invests) corresponds to the management fee that would have been paid by an investor investing
directly in “Arty” Class of the Master Fund.
Moreover, there is no performance fee charged on any share class of the Master Fund.
85
An investor who subscribes converts or redeems shares through paying agents may be required
to pay fees connected to the transactions processed by said paying agents in the jurisdictions
in which shares are offered.
The Key Information Document(s) issued for the Classes of shares also contain additional
information on ongoing charges incurred by the Sub-Fund (aggregated with the charges
incurred at the level of the Master Fund).
86
ECHIQUIER WORLD EQUITY GROWTH FUND
SUB-FUND SPECIFICS
The Sub-Fund “Echiquier World Equity Growth Fund” is long-term performance through
exposure on growth securities in international markets, investing in international leaders.
The MSCI All Country World Index could be used as an a posteriori performance comparison.
This index, which is used solely for information purposes, is calculated in EUR and dividends
reinvested by MSCI. This index covers 50 countries from all geographic areas (developed
countries and emerging countries). It is not consistent with environmental and social
characteristics promoted by this Sub-Fund.
The management of the Sub-Fund is based on a stock picking. The investment strategy is
aimed at selecting securities offering the best current or potential growth, which are leaders
on markets of a significant size over all geographic areas.
The Sub-Fund invests at least 10% of its assets into Sustainable Investments.
The Sub-Fund has exposure of at least 60% to eurozone equities and/or global and
emerging-market equities. The Sub-Fund assets consist primarily of large-caps. However,
the Sub-Fund reserves the right to invest up to 10% of its net assets in small-caps and mid-
caps.
The Sub-Fund reserves the option to invest a maximum of 40% in fixed-income products.
The bonds in question are securities deemed ‘Investment grade’, i.e. rated at least BBB- by
Standard & Poor’s or equivalent.
- Hedging the portfolio against currency risk, and also, to a lesser extent, against equity
risk when the manager anticipates a sharp drop in market performance;
- Exposing the portfolio from time to time to equity risk during periods of heavy
subscription. Under no circumstances whatsoever does the Sub-Fund intend to adopt a
strategy overexposing the portfolio to equity risk.
On an ancillary basis, the Sub-Fund may invest in units/shares of UCITS and/or other UCIs
up to 10% of its net assets.
The Sub-Fund may invest in securities with embedded derivatives (warrants, subscription
certificates, etc.) traded on eurozone and/or international regulated markets or over the
87
counter. The use of embedded derivatives, as opposed to the other derivative instruments
listed above, will mainly be as a result of the Sub-Fund seeking to optimise the hedging
strategy, or, if appropriate, to improve the performance of the portfolio by reducing the
costs related to the use of these financial instruments in order to achieve the investment
objective. In any event, the amounts invested in securities with embedded derivatives
cannot exceed 10% of the net assets. The risk associated with this type of investment will
be limited to the amount invested in the purchase.
The Sub-Fund may hold ancillary liquid assets within the limits foreseen in the Investment
Fund Law.
The Sub-Fund will not enter into repurchase/reverse repurchase transaction, securities
lending, margin lending transaction and buy-sell back or sell-buy back transaction, and will
not invest in TRS or Contracts for Difference (CFD). As a result, the Sub-Fund is not subject
to the Regulation (EU) 2015/2365 on transparency of securities financing transactions and
of reuse.
Besides, the Sub-Fund may invest (up to 10% of its net assets) in companies at initial public
offering (“IPO”) (i.e. offering of shares of a private corporation to the public in a new stock
issuance) after a convincing discretionary analysis.
The Sub-Fund may also invest (up to 10% of its net assets) in special purpose acquisition
companies (“SPACs”), which are companies only formed to raise capital through an IPO for
the purpose of acquiring or merging with an existing company and qualifying as eligible
investments as per article 41 of the Investment Fund Law.
The examples of indicators used for each of the E, S, and G criteria are as follows:
• Environmental indicators: environmental policy and actions, results of action plans
put in place by the company, exposure of suppliers to environmental risks, positive
or negative impact of products on the environment;
• Social indicators: attractiveness of the employer brand, employee loyalty, fight
against discrimination, employee protection, exposure of suppliers to social risks,
relations with civil society;
• Governance indicators: competence of the management team, counter-power,
respect for minority shareholders, business ethics.
The extra financial objectives consist in the management of the Sub-Fund to:
88
➢ Conducting an exclusionary approach based on sectoral and normative exclusions.
The methodological limitations of the ESG approach mainly concern the reliability of extra-
financial data published by issuers and the subjective nature of the rating implemented
within the Management Company.
2. Risk Profile
The list of risks below is not exhaustive: investors should analyse the risks inherent in each
investment and draw their own conclusions. The main risks to which investors are exposed
are as follows:
The loss of capital arises when a unit is sold at a lower price than its purchase value.
Unitholders are informed that the capital initially invested may not be returned. The Sub-
Fund has no capital guarantee or protection.
The Sub-Fund has exposure of at least 60% to equities. If the equities or indices to which
the portfolio is exposed decline, the net asset value of the Sub-Fund could fall. There is a
risk associated with investing in the emerging countries, due essentially to the operating
and supervision conditions on these markets, which may differ from the standards prevailing
on the major international markets, and to political and regulatory factors.
This concerns the risk of a decline in investment currencies relative to the portfolio's
benchmark currency, the euro. If a currency falls relative to the euro, the Sub-Fund’s net
asset value could fall.
The discretionary management style applied to the fund relies on stock selection. There is a
risk that at any given point in time the Sub-Fund will not be invested in the best-performing
stocks. The Sub-Fund's performance can therefore fall below the investment objective. The
net asset value of the Sub-Fund can also show negative performance.
The Sub-Fund has exposure of no more than 40% to fixed-income products. The net asset
value of the Sub-Fund can fall if interest rates rise.
This concerns the risk of non-achievement of the derivatives’ intended objectives and
involves additional risks inherent to these instruments as more described in section “Risk
factors” of Part A of this Prospectus.
These securities may be subject to greater volatility than more established securities as a
result of factors such as the absence of a past public market offering, non-seasonal
transactions, the number of securities that can be traded and a lack of information about
the issuer. Investing in these securities can lead to an increase of the possible expenses as
well as a shorter holding time periods. Moreover the investment in initial public offering can
have a significant impact on the Sub-Fund’s performance.
These securities may be subject to specific risks such as dilution, liquidity, conflicts of
interests or the uncertainty as to the identification, evaluation as well as eligibility of the
target company and can be hard to evaluate because of a lack of trading history and relative
lack of public information. Moreover, the structure of SPACs can be complex and their
characteristics may vary largely from one SPAC to another, meaning that the Management
Company will study each SPAC individually to ensure compliance with article 41 of the
Investment Fund Law.
Generally, the profile of the typical investor for whom the Sub-Fund has been designed is an
investor wishing to invest in the equity markets and who is prepared to accept fluctuations
in the value of its investment and the risks associated with investing in the Sub-Fund, as
described in the section on "Risk Factors" of this Prospectus.
4. Valuation Date
The Valuation Date of this Sub-Fund will be each full Bank Business Day as defined in section
“Net Asset Value” in Luxembourg.
5. Subscription
90
Shares are available for subsequent subscriptions on each Valuation Date on a forward
pricing base.
Applications for shares must be received by the Registrar and Transfer Agent on the
Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt with
on the basis of the Net Asset Value per Share applicable on that Valuation Date. Applications
for shares received by the Registrar and Transfer Agent after that cut-off time will be dealt
with on the next Valuation Date.
Subscription proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date.
The Directors may, at their sole discretion, accept subscriptions below minimum as stated
in the table below.
Shareholders are entitled to redeem their Shares on each Valuation Date on a forward pricing
base. Applications for redemptions must be received by the Registrar and Transfer Agent on
the Valuation date until the cut-off time fixed at 10:00 a.m. Luxembourg time before the
relevant Valuation Date to be dealt with on the basis of the Net Asset Value per Share
applicable on that Valuation Date. Applications for redemptions received by the Registrar
and Transfer Agent after that cut-off time will be dealt with on the next Valuation Date.
Redemption proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date and after receipt of the
proper documentation.
Applications for conversion must be received by the Registrar and Transfer Agent on the
Valuation Date until 10:00 a.m. Luxembourg time to be dealt with on the basis of the Net
Asset Value per Share applicable on that Valuation Date. Applications for conversion received
by the Registrar and Transfer Agent after that cut-off time will be dealt with on the next
Valuation Date.
The Classes available in this Sub-Fund are listed in the table below. The Classes are either
accumulating or distributing classes according to information in section “Income Policy” in
Part A of this Prospectus.
91
Initial
Hedged minimum
Initial
Income against subscriptio
Classes Currency Investors Share
policy currency n and
Amount
exposure holding
amount
Institutional
investors and EUR EUR
K (EUR) Accumulation EUR NO
financial 100.000.- 1,000.-
intermediaries
Institutional
investors and USD USD
K (USD) Accumulation USD NO
financial 100.000.- 1,000.-
intermediaries
Institutional
investors and CHF CHF
K (CHF) Accumulation CHF NO
financial 1,000.-
100.000.-
intermediaries
Institutional
investors and GBP GBP
K (GBP) Accumulation GBP NO
financial 100.000.- 1,000.-
intermediaries
USD
B (USD) Accumulation USD NO All investors None
100.-
Management
companies from the
Other
LBP AM group or
institutional
IXL other institutional EUR
Accumulation EUR NO investors:
(EUR) investors 1,000.-
EUR
subscribing a
30,000,000.-
minimum amount
of EUR 30,000,000.
The initial minimum subscription and holding amount for classes K are valid for investors
whose first subscription takes place from September 16, 2019. For investors present in the
Sub-Fund before this date, there is no minimum.
92
8. Expenses
An investor who subscribes converts or redeems shares through paying agents may be
required to pay fees connected to the transactions processed by said paying agents in the
jurisdictions in which shares are offered.
The Key Information Document(s) issued for the Classes of shares also contain additional
information on ongoing charges incurred by the Sub-Fund.
93
ECHIQUIER MAJOR SRI GROWTH EUROPE FUND
SUB-FUND SPECIFICS
The Sub-Fund “Echiquier Major SRI Growth Europe Fund” is long-term performance
through exposure to European equity markets, investing in leaders with strong growth
perspectives.
In addition to the ESG investment policy described, the Sub-Fund might further exclude
some sectors of activity and financial instruments with ESG scoring below 6.
The MSCI Europe Index is a benchmark for the management objective of the Sub-Fund. This
index, which is used for information purposes, represents the share markets of Europe’s
most developed countries. It is not consistent with environmental and social characteristics
promoted by this Sub-Fund. It is calculated in EUR, and dividends are reinvested.
The Sub-Fund systematically integrates ESG criteria into financial management to result in
a selectivity rate (reduction of the European equity market investment universe) of at least
25%. The manager endeavours to select the issuers with the best non-financial scorings in
their investment universe. These scorings are determined by the Management Company and
applied to the entire portfolio.
The Sub-Fund invests at least 40% of its assets into Sustainable Investments.
The Sub-Fund has a minimum exposure of 60% to European equities and a maximum of
25% to non-European equities. At least 60% of the Sub-Fund assets are invested in major
European equities. Up to 40% of its assets can be exposed to small-cap and mid-cap
equities.
The Sub-Fund reserves the option to invest a maximum of 25% in fixed-income products.
The bonds in question are securities deemed ‘Investment grade’, i.e. rated at least BBB- by
Standard & Poor’s or equivalent.
94
On an ancillary basis, the Sub-Fund may invest in units/shares of UCITS and/or other UCIs
up to 10% of its net assets.
The Sub-Fund may invest in securities with embedded derivatives (warrants, subscription
certificates, etc.) traded on eurozone and/or international regulated markets or over the
counter. The use of embedded derivatives, as opposed to the other derivative instruments
listed above, will mainly be as a result of the Sub-Fund seeking to optimise the hedging
strategy, or, if appropriate, to improve the performance of the portfolio by reducing the
costs related to the use of these financial instruments in order to achieve the investment
objective. In any event, the amounts invested in securities with embedded derivatives
cannot exceed 10% of the net assets. The risk associated with this type of investment will
be limited to the amount invested in the purchase.
The Sub-Fund may hold ancillary liquid assets within the limits foreseen in the Investment
Fund Law.
The Sub-Fund will not enter into repurchase/reverse repurchase transaction, securities
lending, margin lending transaction and buy-sell back or sell-buy back transaction, and will
not invest in TRS or Contracts for Difference (CFD). As a result, the Sub-Fund is not subject
to the Regulation (EU) 2015/2365 on transparency of securities financing transactions and
of reuse.
Besides, the Sub-Fund may invest (up to 10% of its net assets) in companies at initial public
offering (“IPO”) (i.e. offering of shares of a private corporation to the public in a new stock
issuance) after a convincing discretionary analysis.
The Sub-Fund may also invest (up to 10% of its net assets) in special purpose acquisition
companies (“SPACs”), which are companies only formed to raise capital through an IPO for
the purpose of acquiring or merging with an existing company and qualifying as eligible
investments as per article 41 of the Investment Fund Law.
The examples of indicators used for each of the E, S, and G criteria are as follows:
• Environmental indicators: environmental policy and actions, results of action plans
put in place by the company, exposure of suppliers to environmental risks, positive
or negative impact of products on the environment.
• Social indicators: attractiveness of the employer brand, employee retention, anti
discrimination, employee protection, exposure of suppliers to social risks, relations
with civil society.
• Governance indicators: competence of the management team, checks and
balances, respect for minority shareholders, business ethics.
The Sub-Fund focuses on selecting the top-rated issuers from an extra-financial perspective
within their investment universe (“best in universe” approach). This Sub-Fund also invests
in companies that have adopted a CSR approach and have an improving momentum in their
ESG practices (“best efforts” approach). The Sub-Fund applies two extra-financial filters in
its stock-picking: after controversial sectors and practices are excluded, stocks must meet
a minimum ESG rating requirement. These ratings are determined by the Management
Company and applied to the
entire portfolio.
The ESG rating is out of 10 and is awarded to each issuer. This score is determined as
follows:
95
• Governance: The Governance rating represents approximately 60% of the overall
ESG score. This is a long-standing bias for La Financière de l’Echiquier, which has
attached particular importance to this subject since the company’s creation.
• Environmental and Social: Social and environmental criteria are combined to
determine a “Responsibility” score. Its calculation takes into account the type of
company:
- for industrial stocks: the social and environmental criteria are equally
weighted in the “Responsibility” score.
- for service stocks: the “Social” score accounts for 2/3 of the “Responsibility”
score, while the “Environmental” score represents 1/3 of the “Responsibility”
score.
The ESG rating of issuers in the portfolio must always be equal to 100%.
If a company’s rating falls below the minimum required by the Management Company for
the sub-fund, the position in the issuer would be sold in the best interests of the
shareholders.
2. Risk Profile
The loss of capital arises when a unit is sold at a lower price than its purchase value.
Unitholders are informed that the capital initially invested may not be returned. The Sub-
Fund has no capital guarantee or protection.
The Sub-Fund has exposure of at least 60% to equities. If the equities or indices to which
the portfolio is exposed decline, the fund's Net Asset Value could also decline. On small- and
medium-cap markets, the volume of securities listed on the stock exchange is relatively less,
and therefore market downturns are more significant and rapid than on large-cap markets.
The net asset value of the Sub-Fund can therefore fall more rapidly and more sharply.
The discretionary management style applied to the Sub-Fund relies on stock selection. There
is a risk that at any given point in time the Sub-Fund will not be invested in the best-
performing stocks. The Sub-Fund's performance can therefore fall below the investment
objective. The net asset value of the Sub-Fund can also show negative performance.
The Sub-Fund has exposure of no more than 25% to fixed-income products. The net asset
value of the Sub-Fund can fall if interest rates rise.
96
➢ Credit risk: Yes
Up to 25% of the Sub-Fund is exposed to money market instruments or bonds. The credit
risk corresponds to the risk of a private issuer's credit quality falling or the issuer defaulting.
The value of the debt securities or bonds in which the Sub-Fund is invested can fall, causing
a drop in the Sub-Fund's net asset value.
This concerns the risk of a decline in investment currencies relative to the portfolio's
benchmark currency, the euro. If a currency falls relative to the euro, the Sub-Fund's net
asset value could fall.
This concerns the risk of non-achievement of the derivatives’ intended objectives and
involves additional risks inherent to these instruments as more described in section “Risk
factors” of Part A of this Prospectus.
These securities may be subject to greater volatility than more established securities as a
result of factors such as the absence of a past public market offering, non-seasonal
transactions, the number of securities that can be traded and a lack of information about
the issuer. Investing in these securities can lead to an increase of the possible expenses as
well as a shorter holding time periods. Moreover, the investment in initial public offering can
have a significant impact on the Sub-Fund’s performance.
These securities may be subject to specific risks such as dilution, liquidity, conflicts of
interests or the uncertainty as to the identification, evaluation as well as eligibility of the
target company and can be hard to evaluate because of a lack of trading history and relative
lack of public information. Moreover, the structure of SPACs can be complex and their
characteristics may vary largely from one SPAC to another, meaning that the Management
Company will study each SPAC individually to ensure compliance with article 41 of the
Investment Fund Law.
Generally, the profile of the typical investor for whom the Sub-Fund has been designed is an
investor wishing to invest in the equity markets and who is prepared to accept fluctuations
in the value of its investment and the risks associated with investing in the Sub-Fund, as
described in the section on "Risk Factors" of this Prospectus.
4. Valuation Date
97
The Valuation Date of this Sub-Fund will be each full Bank Business Day as defined in section
“Net Asset Value” in Luxembourg.
5. Subscription
Shares are available for subsequent subscriptions on each Valuation Date on a forward
pricing base.
Applications for shares must be received by the Registrar and Transfer Agent on the
Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt with
on the basis of the Net Asset Value per Share applicable on that Valuation Date. Applications
for shares received by the Registrar and Transfer Agent after that cut-off time will be dealt
with on the next Valuation Date.
Subscription proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date.
The Directors may, at their sole discretion, accept subscriptions below minimum as stated
in the table below.
Shareholders are entitled to redeem their Shares on each Valuation Date on a forward pricing
base. Applications for redemptions must be received by the Registrar and Transfer Agent on
the Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time before the
relevant Valuation Date to be dealt with on the basis of the Net Asset Value per Share
applicable on that Valuation Date. Applications for redemptions received by the Registrar
and Transfer Agent after that cut-off time will be dealt with on the next Valuation Date.
Redemption proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date and after receipt of the
proper documentation.
Applications for conversion must be received by the Registrar and Transfer Agent on the
Valuation Date until 10:00 a.m. Luxembourg time to be dealt with on the basis of the Net
Asset Value per Share applicable on that Valuation Date. Applications for conversion received
by the Registrar and Transfer Agent after that cut-off time will be dealt with on the next
Valuation Date.
The Classes available in this Sub-Fund are listed in the table below. The Classes are either
accumulating or distributing classes according to information in section “Income Policy” in
Part A of this Prospectus.
98
Initial
Hedged minimum
Initial
Income Curren against subscriptio
Classes Investors Share
Policy cy currency n and
Amount
exposure holding
amount
Institutional investors EUR EUR
K (EUR) Accumulation EUR NO and financial
100,000.- 1,000.-
intermediaries
Institutional investors USD USD
K (USD) Accumulation USD NO and financial
100,000.- 1,000.-
intermediaries
Institutional investors CHF CHF
K (CHF) Accumulation CHF NO and financial
100,000.- 1,000.-
intermediaries
Institutional investors GBP GBP
K (GBP) Accumulation GBP NO and financial
100,000.- 1,000.-
intermediaries
EUR
B (EUR) Accumulation EUR NO All investors None
100.-
USD
B (USD) Accumulation USD NO All investors None
100.-
CHF
B (CHF) Accumulation CHF NO All investors None
100.-
GBP
B (GBP) Accumulation GBP NO All investors None
100.-
Management
companies from the
LBP AM group or other Other
IXL institutional institutional EUR
Accumulation EUR NO
(EUR) investors: EUR 1,000.-
investors subscribing 30,000,000.-
a minimum amount of
EUR 30,000,000. -
The initial minimum subscription and holding amount for classes K are valid for investors
whose first subscription takes place from September 16, 2019. For investors present in the
Sub-Fund before this date, there is no minimum.
8. Expenses
99
Classes Sub Conversio Max Performa Central Depositar Annual Tax
scri n Fee Manage nce Fee Administrati y Fee
ptio ment on Fee
n Fee
Fee
The Key Information Document(s) issued for the Classes of shares also contain additional
information on ongoing charges incurred by the Sub-Fund.
100
ECHIQUIER ARTIFICIAL INTELLIGENCE
SUB-FUND SPECIFICS
The actively managed Sub-Fund “Echiquier Artificial Intelligence” is a dynamic fund seeking
long-term performance through exposure on growth securities in international markets.
Particularly the Sub-Fund seeks to invest in companies developing Artificial Intelligence
and/or companies benefiting from it.
The objective of the Sub-Fund is to achieve, over the recommended investment period, a
performance net of fees higher than that of its benchmark index, the MSCI World Index Net
Total Return. However, the Sub-Fund does not aim to replicate the performance of this index
and the composition of the portfolio may therefore differ significantly from that of its
performance indicator (i.e. the Sub-Fund may invest in instruments that are not part of the
benchmark index). The index is not consistent with environmental and social characteristics
promoted by the Sub-Fund.
The main strategy of the Sub-Fund is based on a stock picking bottom-up approach. Buy
and sell prices are determined for each selected stocks based on a mid-term valuation.
Thereby, selected cases have been subject to a very selective process based on a
quantitative and a qualitative analysis. The Management Company can also conduct trading
operations to take advantage of short-term market movements. The investment strategy is
aimed at selecting securities participating in the development of artificial intelligence or in
securities that are benefiting from the adoption of this technology. The investment strategy
will also include securities whose activity is indirectly linked to artificial intelligence
(ecosystem, infrastructure, etc.). Depending on the Management Company’s conviction,
portfolio construction can lead to a concentrated portfolio (less than 50 stocks).
The Sub-Fund invests at least 10% of its assets into Sustainable Investments.
The Sub-Fund has an exposure of at least 60% to global equities including Eurozone and
emerging-market equities. Exposure to emerging-market equities will however be limited to
30% of the net assets. At the date of this Prospectus, the targeted emerging countries are:
Mexico, Brazil, Argentina, Venezuela, Colombia, Chile, Peru, China, South Korea, India,
Taiwan, Indonesia, Thailand, Hong Kong, Malaysia, Pakistan, Philippines, Singapore, Russia,
Turkey, Poland, Czech Republic, Hungary, South Africa, Egypt, Israel and Saudi Arabia. Such
investments include exposure (up to 15% of the net assets on a global basis) to Chinese
equities by investing in Participatory Notes (“P-Notes”), American Depositary Receipt
(“ADR”) or Global Depositary Receipt (“GDR”) and in Chinese companies (up to 10% of the
net assets) that are listed on the Hong Kong Stock Exchange, via the Shanghai-Hong Kong
and Shenzhen Stock Connect. Lastly, the Sub-Fund will in any event not be exposed to more
than 10% of its net assets in RMB (i.e. CNH and CNY).
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The Sub-Fund is exposed across capitalizations of all sizes.
On an ancillary basis, and for liquidity management purposes, the Sub-Fund reserves the
right to invest a maximum of 40% of the net assets in fixed-income products, that are
deemed ‘Investment grade’, i.e. rated at least BBB- by Standard & Poor’s or equivalent.
- Hedging the portfolio against currency risk, and also, to a lesser extent, against equity
risk when the manager anticipates a sharp drop in market performance;
- Exposing the portfolio from time to time to equity risk during periods of heavy
subscription. Under no circumstances whatsoever does the Sub-Fund intend to adopt a
strategy overexposing the Sub-Fund’s portfolio.
On an ancillary basis, the Sub-Fund may invest in units/shares of UCITS and/or other UCIs
up to 10% of its net assets.
The Sub-Fund may invest in securities with embedded derivatives (warrants, subscription
certificates, etc.) traded on eurozone and/or international regulated markets or over the
counter. The use of embedded derivatives, as opposed to the other derivative instruments
listed above, will mainly be as a result of the Sub-Fund seeking to optimise the hedging
strategy, or, if appropriate, to improve the performance of the portfolio by reducing the
costs related to the use of these financial instruments in order to achieve the investment
objective. In any event, the amounts invested in securities with embedded derivatives
cannot exceed 10% of the net assets. The risk associated with this type of investment will
be limited to the amount invested in the purchase.
The Sub-Fund may hold ancillary liquid assets within the limits foreseen in the Investment
Fund Law.
The Sub-Fund will not enter into repurchase/reverse repurchase transaction, securities
lending, margin lending transaction and buy-sell back or sell-buy back transaction, and will
not invest in Total Return Swap (TRS) or Contracts for Difference (CFD). As a result, the
Sub-Fund is not subject to the CSSF Circular 14/592 and not subject to the Regulations (EU)
2015/2365 on transparency of securities financing transactions and of reuse.
Besides, the Sub-Fund may invest (up to 10% of its net assets) in companies at initial public
offering (“IPO”) (i.e. offering of shares of a private corporation to the public in a new stock
issuance) after a convincing discretionary analysis.
The Sub-Fund may also invest (up to 10% of its net assets) in special purpose acquisition
companies (“SPACs”), which are companies only formed to raise capital through an IPO for
the purpose of acquiring or merging with an existing company and qualifying as eligible
investments as per article 41 of the Investment Fund Law.
Lastly, the Sub-Fund will not be invested in ABS/MBS, distressed or defaulted securities or
in Contingent Convertible Bonds (“Cocos”).
The examples of indicators used for each of the E, S, and G criteria are as follows:
• Environmental indicators: environmental policy and actions, results of action plans
put in place by the company, exposure of suppliers to environmental risks, positive
or negative impact of products on the environment;
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• Social indicators: attractiveness of the employer brand, employee loyalty, fight
against discrimination, employee protection, exposure of suppliers to social risks,
relations with civil society;
• Governance indicators: competence of the management team, counter-power,
respect for minority shareholders, business ethics.
The extra financial objectives consist in the management of the Sub-Fund to:
The ESG rating is out of 10 and is awarded to each issuer. This rating is determined by an
internal methodology of the management company and is composed as follows:
• Governance: The Governance rating represents approximately 60% of the overall
ESG score. This is a historical bias of La Financière de l'Echiquier, which has attached
particular importance to this subject since its creation.;
• Environmental and Social: Social and environmental criteria are combined to
determine a “Responsibility” score. Its calculation takes into account the type of
company concerned:
- for industrial stocks: the social and environmental criteria are equally weighted in
the “Responsibility” score.
- for service stocks: the “Social” score accounts for 2/3 of the “Responsibility” score,
while the “Environmental” score represents 1/3 of the “Responsibility” score.
The methodological limitations of the ESG approach mainly concern the reliability of extra-
financial data published by issuers and the subjective nature of the rating implemented
within the Management Company.
2. Risk Profile
The loss of capital arises when a unit is sold at a lower price than its purchase value.
Unitholders are informed that the capital initially invested may not be returned. The Sub-
Fund has no capital guarantee or protection.
The Sub-Fund has exposure of at least 60% to equities. If the equities or indices to which
the portfolio is exposed decline, the net asset value of the Sub-Fund could fall. There is a
risk associated with investing in the emerging countries, due essentially to the operating
and supervision conditions on these markets, which may differ from the standards prevailing
on the major international markets, and to political and regulatory factors.
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➢ Currency risk: Yes
This concerns the risk of a decline in investment currencies relative to the portfolio's
benchmark currency, the euro. If a currency falls relative to the euro, the Sub-Fund’s net
asset value could fall.
The discretionary management style applied to the Sub-Fund relies on stock selection. There
is a risk that at any given point in time the Sub-Fund will not be invested in the best-
performing stocks. The Sub-Fund's performance can therefore fall below the investment
objective. The net asset value of the Sub-Fund can also show negative performance.
The Sub-Fund has exposure of no more than 40% to fixed-income products. The net asset
value of the Sub-Fund can fall if interest rates rise.
This concerns the risk of non-achievement of the derivatives’ intended objectives and
involves additional risks inherent to these instruments as more described in section “Risk
factors” of Part A of this Prospectus.
The Sub-Fund may be exposed to emerging market risks. Specific risks in connection with
emerging markets shall then be considered as further described in Part A “General
Information”.
The Sub-Fund may be exposed to the Shenzhen and Shanghai-Hong Kong Stock Connect
(“SSE” and “SEHK”, together the “Stock Connect”). Specific risks in connection with China
shall then be considered as further described in Part A “General Information” and “Legal and
beneficial ownership risks”.
Investment into a given country may be made via direct investments into that market or by
depositary receipts traded on other international exchanges, including unsponsored
depositary receipts, in order to benefit from increased liquidity in a particular security and
other advantages. A depositary receipt admitted to the official listing on a stock exchange
in an eligible state or traded on a regulated market in which the security to which it relates
normally trades. Unsponsored depositary receipts may not provide as much information
about the underlying issuer and may not carry the same voting privileges as sponsored
depositary receipts.
These securities may be subject to greater volatility than more established securities as a
result of factors such as the absence of a past public market offering, non-seasonal
transactions, the number of securities that can be traded and a lack of information about
the issuer. Investing in these securities can lead to an increase of the possible expenses as
well as a shorter holding time periods. Moreover, the investment in initial public offering can
have a significant impact on the Sub-Fund’s performance.
These securities may be subject to specific risks such as dilution, liquidity, conflicts of
interests or the uncertainty as to the identification, evaluation as well as eligibility of the
target company and can be hard to evaluate because of a lack of trading history and relative
lack of public information. Moreover, the structure of SPACs can be complex and their
characteristics may vary largely from one SPAC to another, meaning that the Management
Company will study each SPAC individually to ensure compliance with article 41 of the
Investment Fund Law.
Generally, the profile of the typical investor for whom the Sub-Fund has been designed is an
investor wishing to invest in International Equities and who is prepared to accept
fluctuations in the value of its investment and the risks associated with investing in the
Sub-Fund, as described in the section on "Risk Factors" of this Prospectus.
4. Valuation Date
105
Valuation dates of the Sub-Fund will be each full bank Business Day as defined in section
“Net Asset Value” in Luxembourg.
5. Subscription
Shares are available for subsequent subscriptions on each Valuation Date on a forward
pricing base.
Applications for shares must be received by the Registrar and Transfer Agent on the
Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt with
on the basis of the Net Asset Value per Share applicable on that Valuation Date. Applications
for shares received by the Registrar and Transfer Agent after that cut-off time will be dealt
with on the next Valuation Date.
Subscription proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date.
The Directors may, at their sole discretion, accept subscriptions below minimum as stated
in the table below.
Shareholders are entitled to redeem their Shares on each Valuation Date on a forward pricing
base. Applications for redemptions must be received by the Registrar and Transfer Agent on
the Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time before the
relevant Valuation Date to be dealt with on the basis of the Net Asset Value per Share
applicable on that Valuation Date. Applications for redemptions received by the Registrar
and Transfer Agent after that cut-off time will be dealt with on the next Valuation Date.
Redemption proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date and after receipt of the
proper documentation.
Applications for conversion must be received by the Registrar and Transfer Agent on the
Valuation Date until 10:00 a.m. Luxembourg time to be dealt with on the basis of the Net
Asset Value per Share applicable on that Valuation Date. Applications for conversion received
by the Registrar and Transfer Agent after that cut-off time will be dealt with on the next
Valuation Date.
The Classes available in this Sub-Fund are listed in the table below. The Classes are either
accumulating or distributing classes according to information in section “Income Policy” in
Part A of this Prospectus.
106
Initial
Hedged
minimum Initial
Income Curren against
Classes Investors subscription Share
Policy cy currency
and holding Amount
exposure
amount
Institutional
K investors and
Accumulation EUR NO None EUR 100.-
(EUR) financial
intermediaries
Institutional
K investors and
Accumulation USD NO None USD 100.-
(USD) financial
intermediaries
K Institutional
(USD- investors and
Accumulation EUR YES* None EUR 100.-
hedged financial
intermediaries
)
B
Accumulation EUR NO All investors None EUR 100.-
(EUR)
B
Accumulation USD NO All investors None USD 100.-
(USD)
M EUR
Accumulation EUR NO All investors EUR 1,000.-
(EUR) 1,000,000.-
Management
companies
from the LBP
AM group or
other Other
IXL institutional institutional
Accumulation EUR NO investors EUR 1,000.-
(EUR) investors: EUR
subscribing a 30,000,000.-
minimum
amount of
EUR
30,000,000. -
Management
companies
from the LBP
AM group or
IXL other Other
(USD- institutional institutional
Accumulation EUR YES* EUR 1,000.-
hedged investors investors: EUR
subscribing a 30,000,000.-
)
minimum
amount of
EUR
30,000,000. -
*The share-classes IXL (USD-hedged) and K (USD-hedged) are hedged only against the investment positions in
USD of their underlying portfolio.
Subscription in the Class M was only possible as long as the asset of the Sub-Fund was below
EUR 50,000,000. Since 23 October 2019, the subscription in this share is closed.
The Company may in its discretion waive minimum subscription and/or holding amounts. In
such latter case, the Company will ensure that concerned investors are equally treated.
8. Expenses
108
Frequency of crystallisation of the performance fee and Observation Period
The frequency of crystallisation, i.e. the frequency at which the provisions for the performance fees
can be definitively retained by the Management Company, is annual.
The Observation Period starts for the first time as from 01 August 2020 and will end on 31 July 2021
for class B (EUR), whereas for class B (USD) the Observation Period starts for the first time on 06
January 2021 and ends on 30 September 2022. As from the 01 August 2021, the Observation period
ends on 30 September each year. Therefore, the following Observation Period for class B (EUR) will
run exceptionally from 01 August 2021 to 30 September 2022. In case of launch of a new Class in the
course of the financial year of the Sub-Fund, performance fees will only be crystallised after at least
twelve months from the date of launch of such a new Class. As a result, in case a new Class is launched
in March of "Year 1", performance fees will only be crystallised in September of "Year 2”.
Reference indicator
MSCI World Index Net Total Return, including reinvested net dividends.
Calculation method
The performance fee, net of all costs, is provisioned at each net asset value.
The performance fee is adjusted at each net asset value calculation, on the basis of 15% including all
taxes of the outperformance of the Sub-Fund compared to the reference indicator, on the condition
that the Sub-Fund’s performance is positive (the net asset value is higher than the net asset value at
the start of the period).
If the Sub-Fund underperforms the benchmark, this provision is adjusted through writebacks. Provision
writebacks are capped at the level of the allocations made.
The methodology applied for the calculation of performance fees is based on the “fictional asset”
calculation method, which simulates a fictional asset subject to the same subscription and redemption
conditions as the original Sub-Fund, incremented by the performance of the benchmark. This fictional
asset is then compared with the performance of the Sub-Fund’s actual assets. The difference between
the two assets therefore gives the Sub-Fund’s outperformance relative to its reference indicator.
When shares/units are redeemed, if there is a provision for performance fees, the amount proportional
to the redeemed shares/units is paid to the management company.
Relative
Underperformance Underperformance Performance
Fund Index performance Net relative Performance
of the previous to be offset over fee
performance performance over the performance fee
year to be offset the next year calculation
year
Year
5% 0% 5% 0% 5% 0% Yes 15% x 5%
1
109
Year
3% 3% 0% 0% 0% 0% No -
2
Year
-5% 0% -5% 0% -5% -5% No -
3
Year
5% 2% 3% -5% -2% -2% No -
4
Year
7% 5% 2% -2% 0% 0% No -
5
Year
10% 5% 5% 0% 5% 0% Yes 15% x 5%
6
Year
9% 4% 5% 0% 5% 0% Yes 15% x 5%
7
Year
-15% -5% -10% 0% -10% -10% No -
8
Year
-2% -4% 2% -10% -8% -8% No -
9
Year
0% -2% 2% -8% -6% -6% No -
10
Year
2% 0% 2% -6% -4% -4% No -
11
Year
10% 10% 0% -4% -4% 0%* No -
12
Year
6% 4% 2% 0% 2% 0% Yes 15% x 2%
13
Year
-6% 0% -6% 0% -6% -6% No -
14
Year
4% 2% 2% -6% -4% -4% No -
15
Year
6% 4% 2% -4% -2% -2% No
16
Year
10% 14% -4% -2% -6% -6% No
17
Year
7% 7% 0% -6% -6% -4%** No
18
Year
6% 1% 5% -4% 1% 0% Yes 15% x 1%
19
* The underperformance of year 12 to be offset in the following year (year 13) is 0% and not -4%
(“theoretical” underperformance to be offset the following year). The residual underperformance of
year 8 that was not fully offset in the subsequent years is abandoned since the five-year Performance
Fee Reference Period expired (the underperformance of year 8 could only be offset until year 12).
**The underperformance of year 18 to be offset in the following year (year 19) is -4% and not -6%
(“theoretical” underperformance to be offset the following year). The share of the residual
underperformance of year 14 (-2%) that was not fully offset in the subsequent years is abandoned
since the five-year Performance Fee Reference Period expired (the underperformance of year 14 could
only be offset until year 18).
An investor who subscribes, converts or redeems shares through paying agents may be
required to pay fees connected to the transactions processed by said paying agents in the
jurisdictions in which shares are offered.
The Key Information Document(s) issued for the Classes of shares also contain additional
information on ongoing charges incurred by the Sub-Fund.
110
ECHIQUIER SPACE
SUB-FUND SPECIFICS
The actively managed Sub-Fund “Echiquier Space” is a dynamic sub-fund seeking long-
term performance through exposure to international equity markets and more specifically in
companies of the space industry sector, in compliance with the Article 8 of SFDR.
The objective of the Sub-Fund is to achieve, over the recommended investment period, a
performance net of fees higher than that of its benchmark index, the MSCI All Country Index
Net Return (Euro) but including reinvested net dividends. This index is an international
equity index, which tracks stocks from developed and emerging markets countries,
calculated in EUR.
However, the Sub-Fund does not aim to replicate the performance of this index and the
composition of the portfolio may therefore differ significantly from that of its performance
indicator. The MSCI All Country Index Net Return (Euro) index is used solely for calculation
of performance and information purposes, is not consistent with environmental and social
characteristics promoted by the Sub-Fund.
The values used result from the setting of target purchase and sale prices. The selected
securities therefore underwent a highly selective qualitative process. The methodology
involving the setting of a purchase price and a sale price make it possible to establish a
position on securities presenting a potential for future appreciation by the market.
The investment strategy aims to select stocks that present, according to the analysis of the
management company, a sustainable level of growth* and that operate in the space
universe, directly or indirectly, through a segmentation of this universe according to the
area of economic intervention:
111
From Earth: includes companies with an activity primarily based on Earth but enabling the
development of the space ecosystem (rocket/satellite/space asset manufacturing, space
asset management, space application development, financing and insurance, etc.).
Between Earth and Space: companies that bridge the two frontiers (sending and
recovering space assets, telecommunication systems, planetary observation, space asset
defense, etc.).
For Space: purely space-based activities (space mining, space exploration, industrial
manufacturing in space, space tourism, etc.).
Technologies that enable it: companies developing the technologies that enable this
revolution to take off (cloud computing, semiconductor products, industrial design software,
simulation software, databases, communication technologies, basic research, etc.).
* "Sustainable growth": the ability of a company to address a large market, which is itself growing, enabling the
company to generate revenue growth both through the growth of its market and through its ability to take market
share.
The Sub-Fund invests at least 10% of its assets into Sustainable Investments.
At all times, a minimum of 75% of the net assets of the Sub-Fund be invested in listed
equities, including a maximum of 30% in emerging equities. These will mainly be stocks
whose market capitalisation is over 1 billion euros, including up to 25% of its net assets in
small caps. Compliance with the market capitalisation criterion is assessed at the time of
the initial investment in the equities in question.
Such investments include exposure (up to 15% of the net assets on a global basis) to
Chinese equities by investing in Participatory Notes (“P-Notes”), American Depositary
Receipt (“ADR”) or Global Depositary Receipt (“GDR”) and in Chinese companies (up to 10%
of the net assets) that are listed on the Hong Kong Stock Exchange, via the Shanghai-Hong
Kong and Shenzhen Stock Connect. Lastly, the Sub-Fund will in any event not be exposed
to more than 10% of its net assets in RMB (i.e. CNH and CNY).
Besides, the Sub-Fund may invest (up to 10% of its net assets) in companies at initial public
offering (“IPO”) (i.e. offering of shares of a private corporation to the public in a new stock
issuance) after a convincing discretionary analysis.
The Sub-Fund may also invest (up to 10% of its net assets) in special purpose acquisition
companies (“SPACs”), which are companies only formed to raise capital through an IPO for
the purpose of acquiring or merging with an existing company and qualifying as eligible
investments as per article 41 of the Investment Fund Law.
For cash management purposes, and up to a limit of 25%, the Sub-Fund may invest:
• in negotiable debt securities. The longest maturity of debt securities used for the
Sub-Fund’s cash management shall be 5 years. Such short-term securities have a
Standard & Poor’s rating of investment grade or an equivalent rating by another
ratings agency.
112
• in bonds. The maximum maturity of bonds is 12 years. In this regard, particular
attention will be given to the credit quality of the companies that issue these
securities. Eligible securities are deemed investment grade, i.e., having a minimum
Standard & Poor’s rating of BBB- or equivalent or considered as such by the
management team. No limits have been set for the proportion of bonds of sovereign
and private issuers in the portfolio.
Prior to purchase and for monitoring purposes over the life of securities, the credit risk is
assessed on the basis of research and analysis carried out in-house by the Management
Company and using the ratings produced by the rating agencies. The ratings mentioned
above are those used by the portfolio managers at the time of the initial investment. If a
rating is downgraded over the life of an investment, the portfolio manager will conduct an
analysis on a case-by-case basis and decide whether or not to maintain the position
concerned (i.e. position non in default based on the analysis). The investment limits defined
in relation to the assessment of credit risk by the rating agencies may therefore be adjusted
slightly to reflect the management team’s own analysis.
The Sub-Fund may invest in financial futures traded on international regulated markets
and/or over the counter. In this context, the Sub-Fund may take positions by using index
futures, options on securities and indices and currency and forex forward options in order:
• to hedge the portfolio against currency risk and equity market risk when the manager
anticipates a strong deterioration in market performance.
These transactions shall be limited to 100% of the Sub-Fund’s assets. Financial instruments
are entered into with intermediaries selected by the Management Company that have no
say on the composition or management of the Sub-Fund’s portfolio.
On an ancillary basis, the Sub-Fund may invest in units/shares of UCITS and/or other UCIs
up to 10% of its net assets.
The Sub-Fund may invest in securities with embedded derivatives (warrants, subscription
certificates, etc.) traded on eurozone and/or international regulated markets or over the
counter. The use of embedded derivatives, as opposed to the other derivative instruments
listed above, will mainly be as a result of the Sub-Fund seeking to optimise the hedging
strategy, or, if appropriate, to improve the performance of the portfolio by reducing the
costs related to the use of these financial instruments in order to achieve the investment
objective. In any event, the amounts invested in securities with embedded derivatives
cannot exceed 10% of the net assets. The risk associated with this type of investment will
be limited to the amount invested in the purchase.
The Sub-Fund may hold ancillary liquid assets within the limits foreseen in the Investment
Fund Law.
The Sub-Fund will not enter into repurchase/reverse repurchase transaction, securities
lending, margin lending transaction and buy-sell back or sell-buy back transaction, and will
not invest in Total Return Swap (TRS) or Contracts for Difference (CFD). As a result, the
Sub-Fund is not subject to the CSSF Circular 14/592 and not subject to the Regulations (EU)
2015/2365 on transparency of securities financing transactions and of reuse.
The examples of indicators used for each of the E, S, and G criteria are as follows:
The extra financial objectives consist in the management of the Sub-Fund to:
The ESG rating is out of 10 and is awarded to each issuer. This rating is determined by an
internal methodology of the management company and is composed as follows:
- for industrial stocks: the social and environmental criteria are equally weighted in the
“Responsibility” score.
- for service stocks: the “Social” score accounts for 2/3 of the “Responsibility” score, while
the “Environmental” score represents 1/3 of the “Responsibility” score.
- for the equity universe (minimum 75% of of the Sub-Fund’s assets): international
equities meeting the quantitative growth criteria, as defined above, and then the
qualitative criteria for intervention in the space universe according to the four areas
of intervention listed above,
- for the fixed income universe (maximum 25% of the Sub-Fund’s assets):
approximately 80 European corporate issuers, in which the management team has
already invested in over the past few years, and which regularly issue commercial
papers.
The methodological limitations of the ESG approach mainly concern the reliability of extra-
financial data published by issuers and the subjective nature of the rating implemented
within the Management Company.
114
Information regarding the environmental or social characteristics of the Sub-Fund as per
Regulation 2022/1288 is available in “Part C” of this Prospectus.
2. Risk Profile
The loss of capital arises when a unit is sold at a lower price than its purchase value.
Unitholders are informed that the capital initially invested may not be returned. The Sub-
Fund has no capital guarantee or protection.
The Sub-Fund has exposure of at least 60% to equities. If the equities or indices to which
the portfolio is exposed decline, the net asset value of the Sub-Fund could fall. There is a
risk associated with investing in the emerging countries, due essentially to the operating
and supervision conditions on these markets, which may differ from the standards prevailing
on the major international markets, and to political and regulatory factors.
This concerns the risk of a decline in investment currencies relative to the portfolio's
benchmark currency, the euro. If a currency falls relative to the euro, the Sub-Fund’s net
asset value could fall.
The discretionary management style applied to the fund relies on stock selection. There is a
risk that at any given point in time the Sub-Fund will not be invested in the best-performing
stocks. The Sub-Fund's performance can therefore fall below the investment objective. The
net asset value of the Sub-Fund can also show negative performance.
The Sub-Fund has exposure of no more than 25% to fixed-income products. The net asset
value of the Sub-Fund can fall if interest rates rise.
This concerns the risk of non-achievement of the derivatives’ intended objectives and
involves additional risks inherent to these instruments as more described in section “Risk
factors” of Part A of this Prospectus.
The Sub-Fund may be exposed to emerging market risks. Specific risks in connection with
emerging markets shall then be considered as further described in Part A “General
Information”.
The Sub-Fund may be exposed to the Shenzhen and Shanghai-Hong Kong Stock Connect
(“SSE” and “SEHK”, together the “Stock Connect”). Specific risks in connection with China
shall then be considered as further described in Part A “General Information” and “Legal and
beneficial ownership risks”.
115
➢ P-Notes risks risk: Yes
Investment into a given country may be made via direct investments into that market or by
depositary receipts traded on other international exchanges, including unsponsored
depositary receipts, in order to benefit from increased liquidity in a particular security and
other advantages. A depositary receipt admitted to the official listing on a stock exchange
in an eligible state or traded on a regulated market in which the security to which it relates
normally trades. Unsponsored depositary receipts may not provide as much information
about the underlying issuer and may not carry the same voting privileges as sponsored
depositary receipts.
These securities may be subject to greater volatility than more established securities as a
result of factors such as the absence of a past public market offering, non-seasonal
transactions, the number of securities that can be traded and a lack of information about
the issuer. Investing in these securities can lead to an increase of the possible expenses as
well as a shorter holding time periods. Moreover, the investment in initial public offering can
have a significant impact on the Sub-Fund’s performance.
These securities may be subject to specific risks such as dilution, liquidity, conflicts of
interests or the uncertainty as to the identification, evaluation as well as eligibility of the
target company and can be hard to evaluate because of a lack of trading history and relative
lack of public information. Moreover, the structure of SPACs can be complex and their
characteristics may vary largely from one SPAC to another, meaning that the Management
116
Company will study each SPAC individually to ensure compliance with article 41 of the
Investment Fund Law.
The Sub-Fund is intended for individuals or institutional investors who are aware of the
inherent risk in holding shares in such a sub-fund, which is a high risk due to investment in
listed equities around the world. The Sub-Fund may be used for variable-capital, unit-linked
individual life insurance policies.
The appropriate amount to invest in the Sub-Fund depends on the personal situation of the
investor. In deciding how much to invest, they should take into account their personal assets
and any business assets, their cash requirements at the time and in 5 years, and whether
they are willing to take risks on equity markets. Investors are also strongly advised to
diversify their investments sufficiently so as not to be exposed solely to the risks of this Sub-
Fund.
4. Valuation Date
Valuation dates of the Sub-Fund will be each full bank Business Day as defined in section
“Net Asset Value” in Luxembourg.
5. Subscription
Subscriptions are carried out in in thousandths. The minimum initial subscription amount for
the F shares is 250,000 euros, with the exception of the Management Company, which may
subscribe for only one share. The F share-class was closed for new subscriptions on 23
September 2022, as it reached its goal of an outstanding amount of EUR 50 million.
However, current “founder subscribers” (i.e. shareholders invested in the F share-class
before reaching the goal), may continue to invest in the Sub-Fund.
The F share-class is now re-opened until 30 September 2023.
Applications for shares must be received by the Registrar and Transfer Agent on the
Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt with
on the basis of the Net Asset Value per Share applicable on that Valuation Date. Applications
for shares received by the Registrar and Transfer Agent after that cut-off time will be dealt
with on the next Valuation Date.
Subscription proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date.
The Directors may, at their sole discretion, accept subscriptions below minimum as stated
in the table below.
117
Shareholders are entitled to redeem their Shares on each Valuation Date on a forward pricing
base. Applications for redemptions must be received by the Registrar and Transfer Agent on
the Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time before the
relevant Valuation Date to be dealt with on the basis of the Net Asset Value per Share
applicable on that Valuation Date. Applications for redemptions received by the Registrar
and Transfer Agent after that cut-off time will be dealt with on the next Valuation Date.
Redemption proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date and after receipt of the
proper documentation.
• on sub-funds with the same Net Asset Value calculation frequency and the same
centralisation date;
Applications for conversion must be received by the Registrar and Transfer Agent on the
Valuation Date until 10:00 a.m. Luxembourg time to be dealt with on the basis of the Net
Asset Value per Share applicable on that Valuation Date. Applications for conversion received
by the Registrar and Transfer Agent after that cut-off time will be dealt with on the next
Valuation Date.
The Classes available in this Sub-Fund are listed in the table below. The Classes are either
accumulating or distributing classes according to information in section “Income Policy” in
Part A of this Prospectus.
Initial
Hedged
Income minimum Initial
Curren against
Classes Investors subscription Share
policy cy currency
and holding Amount
exposure
amount
Founder
F (EUR) Accumulation EUR NO
subscribers
EUR 5,000,000.00 EUR 100.-
118
financial
intermediaries
Institutional
investors and
K (USD) Accumulation USD NO
financial
None USD 100.-
intermediaries
Institutional
investors and
K (CHF) Accumulation CHF NO
financial
None CHF 100.-
intermediaries
Management
companies
from the LBP
AM group or
other
Other institutional EUR
IXL institutional
Accumulation EUR NO investors: EUR
(EUR) investors
30,000,000. - 1,000. -
subscribing a
minimum
amount of
EUR
30,000,000. -
o are subject to national law forbidding any inducements to distributors (i.e the United
Kingdom and the Netherlands); or
The Company may in its discretion waive minimum subscription and/or holding amounts. In
such latter case, the Company will ensure that concerned investors are equally treated.
9. Expenses
Centr
al
Conver Depo
Subscrip Managem Performance Admi Annual
Classes sion sitar
tion Fee ent Fee Fee* nistra Tax
Fee y Fee
tion
Fee
15% on the
positive
difference Max
Max
B Max between the EUR
Max 3% None 0.01 0.05%
(EUR) 1.65% Sub-Fund’s 40,00
%
performance 0
(net of fixed
management
119
fees) and the
performance of
the MSCI All
Country World
Index NET
RETURN index*
15% on the
positive
difference
between the
Max
Sub-Fund’s
USD
performance
equiva Max
B Max (net of fixed
Max 3% None lent of 0.01 0.05%
(USD) 1.65% management
EUR %
fees) and the
40,00
performance of
0
the MSCI All
Country World
Index NET
RETURN index*
15% on the
positive
difference
between the
Max
Sub-Fund’s
CHF
performance
equiva Max
B Max (net of fixed
Max 3% None lent of 0.01 0.05%
(CHF) 1.65% management
EUR %
fees) and the
40,00
performance of
0
the MSCI All
Country World
Index NET
RETURN index*
Max
Max
F Max EUR
Max 3% None None 0.01 0.05%
(EUR) 0.75% 40,00
%
0
Max
Max
K Max EUR
Max 3% None None 0.01 0.05%
(EUR) 1.00% 40,00
%
0
Max
USD
equiv
Max
K Max alent
Max 3% None None 0.01 0.05%
(USD) 1.00% of
%
EUR
40,00
0
120
Max
CHF
equiv
Max
K Max alent
Max 3% None None 0.01 0.05%
(CHF) 1.00% of
%
EUR
40,00
0
Max
Max
IXL(EU Max EUR
Max 3% None None 0.01 0.01%
R) 0.70% 40,00
%
0
Reference indicator
MSCI All Country World Index Net Return (Euro) including reinvested net dividends.
Calculation method
The performance fee, net of all costs, is provisioned at each net asset value.
The performance fee is adjusted at each net asset value calculation, on the basis of 15% including all
taxes of the outperformance of the Sub-Fund compared to the reference indicator, on the condition
that the Sub-Fund’s performance is positive (the net asset value is higher than the net asset value at
the start of the period).
If the Sub-Fund underperforms the benchmark, this provision is adjusted through writebacks. Provision
writebacks are capped at the level of the allocations made.
The methodology applied for the calculation of performance fees is based on the “fictional asset”
calculation method, which simulates a fictional asset subject to the same subscription and redemption
conditions as the original Sub-Fund, incremented by the performance of the benchmark. This fictional
asset is then compared with the performance of the Sub-Fund’s actual assets. The difference between
the two assets therefore gives the Sub-Fund’s outperformance relative to its reference indicator.
121
underperformance has occurred within this first 5-year period and has not been caught up by the end
of this first period, a new period of up to 5 years will begin from this new year of underperformance.
When shares/units are redeemed, if there is a provision for performance fees, the amount proportional
to the redeemed shares/units is paid to the management company.
Relative
Underperformance Underperformance Performance
Fund Index performance Net relative Performance
of the previous to be offset over fee
performance performance over the performance fee
year to be offset the next year calculation
year
Year
5% 0% 5% 0% 5% 0% Yes 15% x 5%
1
Year
3% 3% 0% 0% 0% 0% No -
2
Year
-5% 0% -5% 0% -5% -5% No -
3
Year
5% 2% 3% -5% -2% -2% No -
4
Year
7% 5% 2% -2% 0% 0% No -
5
Year
10% 5% 5% 0% 5% 0% Yes 15% x 5%
6
Year
9% 4% 5% 0% 5% 0% Yes 15% x 5%
7
Year
-15% -5% -10% 0% -10% -10% No -
8
Year
-2% -4% 2% -10% -8% -8% No -
9
Year
0% -2% 2% -8% -6% -6% No -
10
Year
2% 0% 2% -6% -4% -4% No -
11
Year
10% 10% 0% -4% -4% 0%* No -
12
Year
6% 4% 2% 0% 2% 0% Yes 15% x 2%
13
Year
-6% 0% -6% 0% -6% -6% No -
14
Year
4% 2% 2% -6% -4% -4% No -
15
Year
6% 4% 2% -4% -2% -2% No
16
Year
10% 14% -4% -2% -6% -6% No
17
Year
7% 7% 0% -6% -6% -4%** No
18
Year
6% 1% 5% -4% 1% 0% Yes 15% x 1%
19
* The underperformance of year 12 to be offset in the following year (year 13) is 0% and not -4%
(“theoretical” underperformance to be offset the following year). The residual underperformance of
year 8 that was not fully offset in the subsequent years is abandoned since the five-year Performance
Fee Reference Period expired (the underperformance of year 8 could only be offset until year 12).
**The underperformance of year 18 to be offset in the following year (year 19) is -4% and not -6%
(“theoretical” underperformance to be offset the following year). The share of the residual
underperformance of year 14 (-2%) that was not fully offset in the subsequent years is abandoned
122
since the five-year Performance Fee Reference Period expired (the underperformance of year 14 could
only be offset until year 18).
An investor who subscribes, converts or redeems shares through paying agents may be
required to pay fees connected to the transactions processed by said paying agents in the
jurisdictions in which shares are offered.
The Key Information Document(s) issued for the Classes of shares also contain additional
information on ongoing charges incurred by the Sub-Fund.
123
ECHIQUIER INDIA
SUB-FUND SPECIFICS
The actively managed Sub-Fund “Echiquier India” is a dynamic sub-fund seeking long-
term performance through exposure to Indian equity securities, in compliance with the
Article 8 of SFDR.
The objective of the Sub-Fund is to achieve, over the recommended investment period, a
performance net of fees higher than that of its benchmark index, the MSCI India 10/40
Index (Euro) but including reinvested net dividends. This index is an Indian equity index,
which tracks stocks from India, calculated in EUR.
However, the Sub-Fund does not aim to replicate the performance of this index and the
composition of the portfolio may therefore differ significantly from that of its performance
indicator. The MSCI India 10/40 Index (Euro) index is used solely for calculation of
performance and information purposes, is not consistent with environmental and social
characteristics promoted by the Sub-Fund.
The Sub-Fund invests mainly in the Indian equity markets of all sectors and of all
capitalization sizes. It has a direct exposure of at least 60% to Indian equities.
The Sub-Fund systematically integrates ESG criteria into financial management to result in
a selectivity rate (reduction of the equity market investment universe) of at least 20%. The
manager then endeavours to select the issuers with the best non-financial scorings in their
investment universe. These scorings are determined by the Management Company and
applied to the entire portfolio.
The Sub-Fund reserves the option to invest a maximum of 40% in fixed-income debt
instruments, including money market instruments. These instruments must be ‘Investment
grade’ rated, i.e. at least BBB- by Standard & Poor’s or equivalent. They will mainly consist
in instruments from European issuers (EU + EFTA + United Kingdom). Investments in fixed-
income instruments from issuers outside of this geographical zone (including from emerging
markets) will be limited to 10%. No limits have been set for the proportion of bonds of
sovereign and private issuers.
124
- Hedging the portfolio against currency risk, and also, to a lesser extent, against equity
risk when the manager anticipates a sharp drop in market performance;
- Exposing the portfolio from time to time to equity risk during periods of heavy
subscription. Under no circumstances whatsoever does the Sub-Fund intend to adopt a
strategy overexposing the portfolio to equity risk.
On an ancillary basis, the Sub-Fund may invest in units/shares of UCITS and/or other UCIs
up to 10% of its net assets.
The Sub-Fund may invest in securities with embedded derivatives (warrants, subscription
certificates, etc.) traded on eurozone and/or international regulated markets or over the
counter. The use of embedded derivatives, as opposed to the other derivative instruments
listed above, will mainly be as a result of the Sub-Fund seeking to optimise the hedging
strategy, or, if appropriate, to improve the performance of the portfolio by reducing the
costs related to the use of these financial instruments in order to achieve the investment
objective. In any event, the amounts invested in securities with embedded derivatives
cannot exceed 10% of the net assets. The risk associated with this type of investment will
be limited to the amount invested in the purchase.
The Sub-Fund may hold ancillary liquid assets within the limits foreseen in the Investment
Fund Law.
The Sub-Fund will not enter into repurchase/reverse repurchase transaction, securities
lending, margin lending transaction and buy-sell back or sell-buy back transaction, and will
not invest in TRS or Contracts for Difference (CFD). As a result, the Sub-Fund is not subject
to the Regulation (EU) 2015/2365 on transparency of securities financing transactions and
of reuse.
Besides, the Sub-Fund may invest (up to 10% of its net assets) in Indian companies at initial
public offering (“IPO”) (i.e. offering of shares of a private corporation to the public in a new
stock issuance) after a convincing discretionary analysis.
The extra financial objectives consist in the management of the Sub-Fund to:
➢ Conduct an ESG analysis on the investment universe, which are the issuers part of
the MSCI India 10/40 Index (Euro), on the basis of Socially Responsible Investing
(SRI) criteria, in order to determine, after reduction of the investment universe by
20% (including the two following filters: exclusion and quantitative rating), the SRI
average rating which the Sub-Fund will have to exceed (the “Improved Average
Rating”);
➢ Select the issuers, some of which may not be included in the Restricted Investment
Universe.
The ESG selectivity approach is based on a rating developed and provided by the
Management Company. The latter applies, based on specific weightings, the following 4
pillars:
• responsible governance: this pillar has the particular objective of evaluating the
organization and effectiveness of powers within each issuer (for example, for companies:
assess the balance of powers, the remuneration of managers, business ethics or even tax
practices);
• sustainable management of resources: this pillar allows for example the analysis of the
environmental and human capital impacts for each issuer (e.g., quality working conditions,
management of relations with suppliers);
125
• Economic and energy transition: this pillar allows, for example, the assessment of each
issuer's strategy in favour of energy transition (e.g., greenhouse gas reduction efforts,
response to long-term challenges); and
• Territorial development: this pillar allows, for example, the analysis of each issuer's
strategy regarding access to basic services.
Several criteria are identified for each pillar and monitored through indicators collected from
extra-financial rating agencies. The Management Company utilizes this rating as a
quantitative decision-making tool, aiming to exclude securities with lower ratings. The
methodology implemented by the Management Company helps to reduce biases, especially
those related to capital or sectors, that could artificially improve the rating through allocation
decisions.
The Management Company's exclusion list is used as a second filter. Indeed, the
Management Company establishes an exclusion list after having analyzed ESG controversies
or allegations, defined notably as severe, systematic violations without corrective measures
of ESG-related rights or impacts. The exclusion list also includes controversial sectors such
as tobacco, gambling and coal.
Further to the selectivity approach, the Management Company selects securities based on
their financial and extra-financial characteristics. The Sub-Fund is actively managed on a
discretionary basis without reference to the MSCI India 10/40 Index (Euro), other indices or
sectors of activity. Securities are chosen following the financial and extra-financial research
conducted by the Management Company.
The management policy aims to select securities with the most attractive potential for
appreciation and profit capacity, according to the Management Company's analysis. The
selection of securities is based on the intrinsic quality of companies, including:
- Earnings growth
- Visibility
- Strategy
- Management
- Prospects for market development worldwide
- Qualitative extra-financial analysis of the company with particular attention to
governance.
The construction of the portfolio enables to get an Improved Average Rating, an average
SRI rating of the portfolio better than the average SRI rating of the investment universe
after reduction by 20%. All the securities from the investment universe are therefore eligible,
provided the average extra-financial rating of the Sub-Fund meets the above condition. With
this approach of rating improvement, which corresponds to an ESG integration with a
significative involvement in the management, the Management Company puts in place the
SRI strategy of the portfolio.
The methodological limitations of the ESG approach mainly concern the reliability of extra-
financial data published by issuers and the subjective nature of the rating implemented
within the Management Company.
126
2. Risk Profile
The list of risks below is not exhaustive: investors should analyse the risks inherent in each
investment and draw their own conclusions. The main risks to which investors are exposed
are as follows:
The loss of capital arises when a unit is sold at a lower price than its purchase value.
Unitholders are informed that the capital initially invested may not be returned. The Sub-
Fund has no capital guarantee or protection.
The Sub-Fund has exposure of at least 60% to equities. If the equities or indices to which
the portfolio is exposed decline, the net asset value of the Sub-Fund could fall. There is a
risk associated with investing in the emerging countries, due essentially to the operating
and supervision conditions on these markets, which may differ from the standards prevailing
on the major international markets, and to political and regulatory factors.
This concerns the risk of a decline in investment currencies relative to the portfolio's
currency, the euro. If a currency falls relative to the euro, the Sub-Fund’s net asset value
could fall.
The discretionary management style applied to the Sub-Fund relies on stock selection. There
is a risk that at any given point in time the Sub-Fund will not be invested in the best-
performing stocks. The Sub-Fund's performance can therefore fall below the investment
objective. The net asset value of the Sub-Fund can also show negative performance.
The Sub-Fund has exposure of no more than 40% to fixed-income products. The net asset
value of the Sub-Fund can fall if interest rates rise.
The Sub-Fund may be exposed to emerging market risks. Specific risks in connection with
emerging markets shall then be considered as further described in Part A “General
Information”.
This concerns the risk of non-achievement of the derivatives’ intended objectives and
involves additional risks inherent to these instruments as more described in section “Risk
factors” of Part A of this Prospectus.
These securities may be subject to greater volatility than more established securities as a
result of factors such as the absence of a past public market offering, non-seasonal
127
transactions, the number of securities that can be traded and a lack of information about
the issuer. Investing in these securities can lead to an increase of the possible expenses as
well as a shorter holding time periods. Moreover, the investment in initial public offering can
have a significant impact on the Sub-Fund’s performance.
Generally, the profile of the typical investor for whom the Sub-Fund has been designed is an
investor wishing to invest in the Indian equity market and who is prepared to accept
fluctuations in the value of its investment and the risks associated with investing in the
Sub-Fund, as described in the section on "Risk Factors" of this Prospectus.
4. Valuation Date
The Valuation Date of this Sub-Fund will be each full Bank Business Day as defined in section
“Net Asset Value” in Luxembourg.
5. Subscription
Shares are available for subsequent subscriptions on each Valuation Date on a forward
pricing base.
Applications for shares must be received by the Registrar and Transfer Agent on the
Valuation Date until the cut-off time fixed at 10:00 a.m. Luxembourg time to be dealt with
on the basis of the Net Asset Value per Share applicable on that Valuation Date. Applications
for shares received by the Registrar and Transfer Agent after that cut-off time will be dealt
with on the next Valuation Date.
Subscription proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date.
The Directors may, at their sole discretion, accept subscriptions below minimum as stated
in the table below.
Shareholders are entitled to redeem their Shares on each Valuation Date on a forward pricing
base. Applications for redemptions must be received by the Registrar and Transfer Agent on
the Valuation date until the cut-off time fixed at 10:00 a.m. Luxembourg time before the
relevant Valuation Date to be dealt with on the basis of the Net Asset Value per Share
applicable on that Valuation Date. Applications for redemptions received by the Registrar
and Transfer Agent after that cut-off time will be dealt with on the next Valuation Date.
128
Redemption proceeds will be paid in the reference currency of the respective Class. Payment
will be effected within two (2) days after the relevant Valuation Date and after receipt of the
proper documentation.
Applications for conversion must be received by the Registrar and Transfer Agent on the
Valuation Date until 10:00 a.m. Luxembourg time to be dealt with on the basis of the Net
Asset Value per Share applicable on that Valuation Date. Applications for conversion received
by the Registrar and Transfer Agent after that cut-off time will be dealt with on the next
Valuation Date.
The Classes available in this Sub-Fund are listed in the table below. The Classes are either
accumulating or distributing classes according to information in section “Income Policy” in
Part A of this Prospectus.
Initial
Hedged minimum
Initial
Income against subscriptio
Classes Currency Investors Share
policy currency n and
Amount
exposure holding
amount
USD
A (USD) Accumulation USD NO All investors None 100.-
Institutional
investors and
K (EUR) Accumulation EUR NO
financial
None EUR 100.-
intermediaries
Institutional
investors and USD
K (USD) Accumulation USD NO
financial
None
100.-
intermediaries
Institutional
investors and
K (CHF) Accumulation CHF NO
financial
None CHF 100.-
intermediaries
Institutional
investors and
K (GBP) Accumulation GBP NO
financial
None GBP 100.-
intermediaries
129
Subscription in the Class(es) K is limited to INSTITUTIONAL INVESTORS and investors
subscribing through intermediaries providing an independent advisory service or
discretionary investment management (including the management company within the
limits of the offer Echiquier Club Sélection), management companies which are managing
funds of funds or distributors who:
o are subject to national law forbidding any inducements to distributors (i.e the United
Kingdom and the Netherlands);
or
o provide investment services and activities as defined by the MiFID II directive,
o and for which they are exclusively remunerated by their clients.
The Company may in its discretion waive minimum subscription and/or holding amounts. In
such latter case, the Company will ensure that concerned investors are equally treated.
8. Expenses
130
Classes Subscri Convers Max Perform Central Deposita Annual
ption ion Fee Manage ance Administ ry Fee Tax
Fee ment Fee ration
Fee Fee
15% on
the
positive
difference
between
the Sub-
Fund’s
performan
ce (net of
A Max fixed Max EUR Max
Max 3% None 0.05%
(EUR) 1.65% managem 40,000 0.01%
ent fees)
and the
performan
ce of the
MSCI India
10/40
Index
(Euro)
index*
15% on
the
positive
difference
between
the Sub-
Fund’s
performan
ce (net of
A Max fixed Max EUR Max
Max 3% None 0.05%
(USD) 1.65% managem 40,000 0.01%
ent fees)
and the
performan
ce of the
MSCI India
10/40
Index
(Euro)
index*
15% on
the
positive
difference
between
the Sub-
Fund’s
performan
ce (net of
A Max fixed Max EUR Max
Max 3% None 0.05%
(CHF) 1.65% managem 40,000 0.01%
ent fees)
and the
performan
ce of the
MSCI India
10/40
Index
(Euro)
index*
131
15% on
the
positive
difference
between
the Sub-
Fund’s
performan
ce (net of
A Max fixed Max EUR Max
Max 3% None 0.05%
(GBP) 1.65% managem 40,000 0.01%
ent fees)
and the
performan
ce of the
MSCI India
10/40
Index
(Euro)
index*
Reference indicator
MSCI India 10/40 Index (Euro), including reinvested net dividends.
Calculation method
The performance fee, net of all costs, is provisioned at each net asset value.
The performance fee is adjusted at each net asset value calculation, on the basis of 15% including all
taxes of the outperformance of the Sub-Fund compared to the reference indicator, on the condition
that the Sub-Fund’s performance is positive (the net asset value is higher than the net asset value at
the start of the period).
If the Sub-Fund underperforms the benchmark, this provision is adjusted through writebacks. Provision
writebacks are capped at the level of the allocations made.
The methodology applied for the calculation of performance fees is based on the “fictional asset”
calculation method, which simulates a fictional asset subject to the same subscription and redemption
conditions as the original Sub-Fund, incremented by the performance of the benchmark. This fictional
132
asset is then compared with the performance of the Sub-Fund’s actual assets. The difference between
the two assets therefore gives the Sub-Fund’s outperformance relative to its reference indicator.
When shares/units are redeemed, if there is a provision for performance fees, the amount proportional
to the redeemed shares/units is paid to the management company.
Relative
Underperformance Underperformance Performance
Fund Index performance Net relative Performance
of the previous to be offset over fee
performance performance over the performance fee
year to be offset the next year calculation
year
Year
5% 0% 5% 0% 5% 0% Yes 15% x 5%
1
Year
3% 3% 0% 0% 0% 0% No -
2
Year
-5% 0% -5% 0% -5% -5% No -
3
Year
5% 2% 3% -5% -2% -2% No -
4
Year
7% 5% 2% -2% 0% 0% No -
5
Year
10% 5% 5% 0% 5% 0% Yes 15% x 5%
6
Year
9% 4% 5% 0% 5% 0% Yes 15% x 5%
7
Year
-15% -5% -10% 0% -10% -10% No -
8
Year
-2% -4% 2% -10% -8% -8% No -
9
Year
0% -2% 2% -8% -6% -6% No -
10
Year
2% 0% 2% -6% -4% -4% No -
11
Year
10% 10% 0% -4% -4% 0%* No -
12
Year
6% 4% 2% 0% 2% 0% Yes 15% x 2%
13
Year
-6% 0% -6% 0% -6% -6% No -
14
Year
4% 2% 2% -6% -4% -4% No -
15
133
Year
6% 4% 2% -4% -2% -2% No
16
Year
10% 14% -4% -2% -6% -6% No
17
Year
7% 7% 0% -6% -6% -4%** No
18
Year
6% 1% 5% -4% 1% 0% Yes 15% x 1%
19
* The underperformance of year 12 to be offset in the following year (year 13) is 0% and not -4%
(“theoretical” underperformance to be offset the following year). The residual underperformance of year 8
that was not fully offset in the subsequent years is abandoned since the five-year Performance Fee Reference
Period expired (the underperformance of year 8 could only be offset until year 12).
**The underperformance of year 18 to be offset in the following year (year 19) is -4% and not -6%
(“theoretical” underperformance to be offset the following year). The share of the residual underperformance
of year 14 (-2%) that was not fully offset in the subsequent years is abandoned since the five-year
Performance Fee Reference Period expired (the underperformance of year 14 could only be offset until year
18).
An investor who subscribes converts or redeems shares through paying agents may be required
to pay fees connected to the transactions processed by said paying agents in the jurisdictions in
which shares are offered.
The Key Information Document(s) issued for the Classes of shares also contain additional
information on ongoing charges incurred by the Sub-Fund.
134
PART C: PRECONTRACTUAL DOCUMENTS IN COMPLIANCE WITH EU REGULATION
2022/1288
135
Template pre-contractual disclosure for the financial products referred to in Article 8, paragraphs 1, 2 and
2a, of Regulation (EU) 2019/2088 and Article 6, first paragraph, of Regulation (EU) 2020/852
Product name:
Sustainable investment
ECHIQUIER AGENOR SRI MID CAP Legal entity identifier: 529900B8JFSLDIBA3F40
means an investment in an
economic activity that EUROPE FUND
contributes to an
Environmental and/or social characteristics
environmental or social
objective, provided that the Does this financial product have a sustainable investment objective?
investment does not
significantly harm any
environmental or social
☐ Yes ☒No
objective and that the
investee companies follow ☐ It will make a minimum of sustainable ☒ It promotes environmental and social (E/S) characteristics
good governance practices. investments with an environmental objective: and while it does not have as its objective a sustainable investment, it
:% will have a minimum proportion of 40% of sustainable investments
The EU Taxonomy is a
classification system ☐ in economic activities that qualify as ☐ with an environmental objective in economic activities that
laid down in Regulation (EU) environmentally sustainable under the EU qualify as environmentally sustainable under the EU Taxonomy
2020/852, establishing a list Taxonomy
☒ with an environmental objective in economic activities that do
of environmentally
sustainable economic
☐ in economic activities that do not qualify not qualify as environmentally sustainable under the EU
activities. That Regulation as environmentally sustainable under the EU Taxonomy
Taxonomy
does not lay down a list of
socially sustainable economic
☒ with a social objective
activities. Sustainable ☐ It will make a minimum ofsustainable
investments with an
investments with a social objective: %
☐ It promotes E/S characteristics, but will not make any sustainable
environmental objective might
investments
be aligned with the
Taxonomy or not.
What environmental and/or social characteristics are promoted by this financial product?
The responsible investment strategy is based on ESG criteria highlighting the environmental and/or social
Sustainability indicators are
characteristics promoted by this financial product, such as a reduction in the environmental impact of companies in
used to verify if the financial
terms of air pollution, preserving biodiversity, companies taking environmental risks into account or an improvement
product complies with the
in working conditions, the protection of employees, the fight against discrimination, etc.
environmental or social
characteristics promoted by
No specific index has been designated as a benchmark to determine whether the financial product is in line with the
the financial product.
environmental and/or social characteristics it promotes.
⚪ What sustainability indicators are used to measure the attainment of each of the
Sustainability indicators environmental or social characteristics promoted by this financial product?
measure how the
The contribution to one of the aforementioned environmental and social objectives is assessed using various
environmental or social
sources, including:
characteristics promoted by
For all environmental and social objectives:
the financial product are
- The “GREaT” score, the proprietary quantitative analysis methodology of the LBP AM Group, which covers all
attained..
environmental and social objectives,
- The “SDG” score, a proprietary qualitative analysis of LFDE that assesses companies’ products, services and
practices with a view to measuring their contribution to achieving the United Nations Sustainable Development
Goals (SDGs).
For objectives specific to climate and biodiversity:
- The issuer’s commitment to a decarbonisation trajectory in its activities compatible with the objectives of the Paris
Agreement, according to criteria defined by the Management Company,
- The “Greenfin” score, a quantitative indicator measuring the exposure of the business model of an issuer to green
activities as defined by the French government label Greenfin, dedicated to financing the energy and ecological
transition,
- The “Bird” score, a proprietary quantitative indicator of the LBP AM Group that aims to assess companies
primarily on their policies as well as on their practices and impacts related to biodiversity,
- The “Climate & Biodiversity Maturity” score, a proprietary qualitative analysis of LFDE that aims to assess the
maturity of companies in their consideration of the current and future climate and biodiversity issues they face.
ECHIQUIER AGENOR SRI MID CAP EUROPE FUND - Annexe SFDR article 8 1
For the specific theme of access to healthcare:
- The “AAAA” (Acceptability, Accessibility, Affordability, Availability) score, a proprietary qualitative analysis of LFDE
that aims to assess the contribution of companies through their products and services to the four dimensions of
access to healthcare (Availability, Geographical Accessibility, Financial Accessibility, Acceptability) inspired by the
work of the World Health Organization (WHO) on the subject.
Additional information about the various scores is available in the “SFDR – Sustainable Investment Methodology”
document available on the Management Company’s website (https://www.lfde.com), in the “Responsible
Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ What are the objectives of the sustainable investments that the financial product partially
intends to make and how does the sustainable investment contribute to such objectives?
Note that the methodology applied does not make it possible to measure the contribution of investments according
to the definition of the European Taxonomy (i.e. the taxonomy alignment of investments).
However, the contribution of investments to environmental objectives within the meaning of Article 2(17) of
Regulation (EU) 2019/2088 (“SFDR Regulation”) is measured using indicators specific to the LBP AM Group and
specified above.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ How do the sustainable investments that the financial product partially intends to make not cause
significant harm to any environmental or social sustainable investment objective?
In order to ensure that an investment contributing to a sustainability objective, according to the analysis method
presented above, does not cause significant harm to any environmental or social sustainable investment objective,
the methodology applied systematically considers, on a cumulative basis:
- The issuer's exposure to sectors that are sensitive in terms of environmental and social aspects (such as thermal
coal, controversial weapons, tobacco, gambling, etc.) in connection with the exclusion policies applicable in the
Management Companies of the LBP AM Group. A more complete description of the exclusions is available in the
“Exclusion Policy” document available on the Management Company’s website (https://www.lfde.com), in the
“Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - Approach and
Methodologies”.
- The issuer’s exposure to a severe controversy on environmental, social and governance issues.
ECHIQUIER AGENOR SRI MID CAP EUROPE FUND - Annexe SFDR article 8 2
- How have the indicators for adverse impacts on sustainability factors been taken into
account?
Principal adverse impacts
are the most significant Commission Delegated Regulation (EU) 2022/1288 (hereinafter the “SFDR Delegated Regulation”) defines a list of
negative impacts of indicators to measure the adverse impacts of an issuer on environmental and social sustainability factors
investment decisions on (hereinafter the “adverse impact indicators”). The adverse impact indicators are calculated for each issuer, when
sustainability factors relating the data is available and integrated into the extra-financial analysis tool.
to environmental, social and Some indicators have been directly integrated, either into the proprietary GREaT scoring methodology used to
employee matters, respect for identify both a positive contribution or significant adverse impact, or into the controversy indicator mentioned above,
human rights and anti- or into the exclusion policies. The principal adverse impacts are also taken into account through the shareholder
corruption and anti-bribery engagement approach with companies in order to improve their transparency on these indicators and reduce their
matters.
negative externalities.
- How are the sustainable investments aligned with the OECD Guidelines for Multinational
Enterprises and the UN Guiding Principles on Business and Human Rights?
In order to ensure that the sustainable investments are aligned with the OECD Guidelines for Multinational
Enterprises and the United Nations Guidelines on Business and Human Rights, the Management Company
systematically controls:
- The issuer’s exposure to a critical risk of serious breach of the OECD Guidelines for Multinational Enterprises and
the UN Guidelines on Business and Human Rights.
- The proper application of the Management Company’s exclusion policy relating to these international treaties and
the process for ad hoc controversy monitoring.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
The EU Taxonomy sets out a “do not significant harm” principle by which Taxonomyaligned investments should
not significantly harm EU Taxonomy objectives and is accompanied by specific EU criteria. The “do no
significant harm” principle applies only to those investments underlying the financial product that take into
account the EU criteria for environmentally sustainable economic activities. The investments underlying the
remaining portion of this financial product do not take into account European Union criteria for environmentally
sustainable economic activities. Any other sustainable investments must also not significantly harm any
environmental or social objectives.
Does this financial product consider principal adverse impacts on sustainability factors?
☒ Yes
☐ No
Regarding the adverse impacts, this financial product takes into account 14 mandatory indicators from Table 1 of
Annex I of European Commission Delegated Regulation (EU) 2022/1288, and also includes the following two
additional indicators:
- investments in companies without carbon reduction initiatives and
- investments in issuers without a workplace accident prevention policy
They are taken into account in the various areas of the management company's responsible investment approach:
through the exclusion policy (sectoral and norm-based), the ESG analysis methodology, the various impact scores,
the measurement and management of ESG performance indicators and engagement with companies.
Additional information about how the principal adverse impacts are taken into account is available in the document
“Article 4 SFDR: Principal adverse impacts” accessible on the Management Company’s website (https://
www.lfde.com), in the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents -
SFDR”.
ECHIQUIER AGENOR SRI MID CAP EUROPE FUND - Annexe SFDR article 8 3
What investment strategy does this financial product follow?
Echiquier Agenor SRI Mid Cap Europe Fund is a stock-picking UCI. It invests in European growth small and mid-
caps, selected in particular for the quality of their management.
The investment strategy
guides investment decisions
⚪ What are the binding elements of the investment strategy used to select the investments to attain each
based on factors such as
of the environmental or social characteristics promoted by this financial product?
investment objectives and
risk tolerance. The mandatory elements used to select investments and achieve the environmental and social characteristics
promoted by the Fund are as follows:
- the Management Company's exclusion policy and the resulting sectoral or norm-based exclusion constraints,
- the binding ESG assessment of each of the issuers in the portfolio,
- constraints associated with the sustainability indicators presented in the section “What sustainability indicators are
used to measure the attainment of each of the environmental or social characteristics promoted by this financial
product?” above.
⚪ What is the committed minimum rate to reduce the scope of the investments considered prior to the
application of that investment strategy?
The implementation of sectoral and norm-based exclusion filters and a binding ESG score make it possible to
reduce the investment universe.
⚪ What is the policy to assess good governance practices of the investee companies?
The monitoring of the application of good governance principles by issuers is controlled through two indicators:
• A quantitative indicator derived from the proprietary “GREaT” analysis methodology, the “Governance” pillar
notably covering issues such as balance of powers, fair remuneration and business ethics.
• An indicator derived from LFDE’s internal qualitative analysis. The analysis covers, among other things, issues
related to the competence of the management team, the existence of effective counter-powers, diversity on the
board, respect of minority shareholders and the assessment of extra-financial risks.
An issuer is deemed to have applied the principles of good governance when this is demonstrated by one of the
two aforementioned indicators.
Good governance practices
include sound management
structures, employee
relations, remuneration of
staff and tax compliance.
ECHIQUIER AGENOR SRI MID CAP EUROPE FUND - Annexe SFDR article 8 4
What is the asset allocation planned for this financial product?
The financial product invests at least 90% of its assets in assets considered “eligible” according to the ESG process
implemented - therefore in investments that are aligned with the environmental and social characteristics promoted
(#1 Aligned with E/S characteristics).
Up to 10% of investments are not aligned with these characteristics (#2 Other).
The financial product invests at least 40% of its assets in assets considered to be sustainable investments (#1A
Sustainable).
A more detailed description of the specific asset allocation of this financial product can be found in its prospectus.
ECHIQUIER AGENOR SRI MID CAP EUROPE FUND - Annexe SFDR article 8 5
⚪ How does the use of derivatives attain the environmental or social characteristics promoted by the
financial product?
The derivatives used by the financial product are not intended to contribute to achieving the environmental or social
characteristics promoted. Their use is limited to hedging or temporary exposure in order to cover a strong
movement in liabilities, to gain temporary exposure to market beta or to accompany a change in strategy.
Furthermore, the Management Company ensures that the use of derivatives does not run counter to the
To comply with the EU environmental or social characteristics promoted by the financial product. In particular, the Management Company
taxonomy, the criteria for does not use derivatives to artificially improve the product’s extra-financial performance. The constraints relating to
fossil gas include limitations the use of derivatives are specified in the pre-contractual documentation for the financial product.
on emissions and switching
to renewable power or low- To what minimum extent are sustainable investments with an environmental objective
carbon fuels by the end of aligned with the EU Taxonomy?
2035. For nuclear energy,
the criteria include
The financial product may invest in environmentally sustainable economic activities, however the investments of
comprehensive safety and
this financial product do not take into account the European Union criteria for environmentally sustainable economic
waste management rules. activities. The financial product is committed to a 0% alignment with the European Taxonomy
Taxonomy-aligned:
Taxonomy-aligned:
Fossil gas
Fossil gas
Taxonomy-aligned:
Taxonomy-aligned:
Nuclear
Nuclear
Taxonomy-aligned (no
Taxonomy-aligned (no
fossil gas & nuclear)
fossil gas & nuclear)
Non Taxonomy-aligned
Non Taxonomy-aligned
are sustainable
This graph represents 100% of total investments.
investments with an
environmental * For the purpose of these graphs, “sovereign bonds” consist of all sovereign exposures.
objective that do not
take into account ⚪ What is the minimum share of investments in transitional and enabling activities?
the criteria for
environmentally The financial product does not commit to a minimum proportion of investment in transitional and enabling activities.
sustainable
economic activities What is the minimum share of sustainable investments with an environmental objective that are not
under the EU aligned with the EU Taxonomy?
taxonomy.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with an environmental objective that are not aligned with the
EU Taxonomy is 1%.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with a social objective is 1%.
(1) Fossil gas and nuclear activities will only be aligned with the EU Taxonomy if they contribute to limiting climate change (“climate change mitigation”) and do not cause significant harm to any other EU Taxonomy
objective - see explanatory note in the left margin. All criteria applicable to economic activities in the fossil gas and nuclear energy sectors that comply with the EU Taxonomy are defined in Commission
Delegated Regulation (EU) 2022/1214.
ECHIQUIER AGENOR SRI MID CAP EUROPE FUND - Annexe SFDR article 8 6
What investments are included under “#2 Other”, what is their purpose and are there any minimum
environmental or social safeguards?
Investments included in the category “#2 Other” of the financial product represent up to 10% of investments.
Depending on the eligible instruments as defined in the product’s prospectus, these may include derivatives traded
on regulated or organised markets to expose and hedge the portfolio, cash and unrated issuers.
Derivatives and cash do not provide environmental or social safeguards.
Is a specific index designated as a reference benchmark to determine whether this financial product is
aligned with the environmental and/or social characteristics that it promotes?
Not applicable
⚪ How does the designated index differ from a relevant broad market index?
Not applicable
⚪ Where can the methodology used for the calculation of the designated index be found?
Not applicable
More information about the Management Company’s extra-financial approach can be obtained through the
documents available on its website (https://www.lfde.com), in the “Responsible Investment” section, on the “To find
out more” page, under “LFDE Documents - SFDR”.
Additional information about the fund, in particular its regulatory documentation, is available on the Management
Company’s website (www.lfde.com), under the “Our Funds” section.
ECHIQUIER AGENOR SRI MID CAP EUROPE FUND - Annexe SFDR article 8 7
Template pre-contractual disclosure for the financial products referred to in Article 8, paragraphs 1, 2 and
2a, of Regulation (EU) 2019/2088 and Article 6, first paragraph, of Regulation (EU) 2020/852
Product name:
Sustainable investment Legal entity identifier: 969500I9FE435QANAU40
ECHIQUIER ARTY SRI FUND
means an investment in an
economic activity that Environmental and/or social characteristics
contributes to an
environmental or social Does this financial product have a sustainable investment objective?
objective, provided that the
investment does not ☐ Yes ☒No
significantly harm any
environmental or social
objective and that the
☐ It will make a minimum of sustainable ☒ It promotes environmental and social (E/S) characteristics
investee companies follow investments with an environmental objective: and while it does not have as its objective a sustainable investment, it
good governance practices. :% will have a minimum proportion of 40% of sustainable investments
☐ in economic activities that qualify as ☐ with an environmental objective in economic activities that
The EU Taxonomy is a
environmentally sustainable under the EU qualify as environmentally sustainable under the EU Taxonomy
classification system
Taxonomy
laid down in Regulation (EU)
☒ with an environmental objective in economic activities that do
2020/852, establishing a list ☐ in economic activities that do not qualify not qualify as environmentally sustainable under the EU
of environmentally
as environmentally sustainable under the EU Taxonomy
sustainable economic
Taxonomy
activities. That Regulation ☒ with a social objective
does not lay down a list of
socially sustainable economic ☐ It will make a minimum ofsustainable
activities. Sustainable investments with a social objective: %
☐ It promotes E/S characteristics, but will not make any sustainable
investments with an investments
environmental objective might
be aligned with the
Taxonomy or not.
What environmental and/or social characteristics are promoted by this financial product?
Sustainability indicators are The responsible investment strategy is based on ESG criteria highlighting the environmental and/or social
used to verify if the financial characteristics promoted by this financial product, such as a reduction in the environmental impact of companies in
product complies with the terms of air pollution, preserving biodiversity, companies taking environmental risks into account or an improvement
environmental or social in working conditions, the protection of employees, the fight against discrimination, etc.
characteristics promoted by
the financial product. No specific index has been designated as a benchmark to determine whether the financial product is in line with the
environmental and/or social characteristics it promotes.
⚪ What sustainability indicators are used to measure the attainment of each of the
Sustainability indicators
environmental or social characteristics promoted by this financial product?
measure how the
environmental or social The contribution to one of the aforementioned environmental and social objectives is assessed using various
characteristics promoted by sources, including:
the financial product are For all environmental and social objectives:
attained.. - The “GREaT” score, the proprietary quantitative analysis methodology of the LBP AM Group, which covers all
environmental and social objectives,
- The “SDG” score, a proprietary qualitative analysis of LFDE that assesses companies’ products, services and
practices with a view to measuring their contribution to achieving the United Nations Sustainable Development
Goals (SDGs).
For objectives specific to climate and biodiversity:
- The issuer’s commitment to a decarbonisation trajectory in its activities compatible with the objectives of the Paris
Agreement, according to criteria defined by the Management Company,
- The “Greenfin” score, a quantitative indicator measuring the exposure of the business model of an issuer to green
activities as defined by the French government label Greenfin, dedicated to financing the energy and ecological
transition,
- The “Bird” score, a proprietary quantitative indicator of the LBP AM Group that aims to assess companies
primarily on their policies as well as on their practices and impacts related to biodiversity,
- The “Climate & Biodiversity Maturity” score, a proprietary qualitative analysis of LFDE that aims to assess the
maturity of companies in their consideration of the current and future climate and biodiversity issues they face.
Additional information about the various scores is available in the “SFDR – Sustainable Investment Methodology”
document available on the Management Company’s website (https://www.lfde.com), in the “Responsible
Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ What are the objectives of the sustainable investments that the financial product partially
intends to make and how does the sustainable investment contribute to such objectives?
Note that the methodology applied does not make it possible to measure the contribution of investments according
to the definition of the European Taxonomy (i.e. the taxonomy alignment of investments).
However, the contribution of investments to environmental objectives within the meaning of Article 2(17) of
Regulation (EU) 2019/2088 (“SFDR Regulation”) is measured using indicators specific to the LBP AM Group and
specified above.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ How do the sustainable investments that the financial product partially intends to make not cause
significant harm to any environmental or social sustainable investment objective?
In order to ensure that an investment contributing to a sustainability objective, according to the analysis method
presented above, does not cause significant harm to any environmental or social sustainable investment objective,
the methodology applied systematically considers, on a cumulative basis:
- The issuer's exposure to sectors that are sensitive in terms of environmental and social aspects (such as thermal
coal, controversial weapons, tobacco, gambling, etc.) in connection with the exclusion policies applicable in the
Management Companies of the LBP AM Group. A more complete description of the exclusions is available in the
“Exclusion Policy” document available on the Management Company’s website (https://www.lfde.com), in the
“Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - Approach and
Methodologies”.
- The issuer’s exposure to a severe controversy on environmental, social and governance issues.
- How are the sustainable investments aligned with the OECD Guidelines for Multinational
Enterprises and the UN Guiding Principles on Business and Human Rights?
In order to ensure that the sustainable investments are aligned with the OECD Guidelines for Multinational
Enterprises and the United Nations Guidelines on Business and Human Rights, the Management Company
systematically controls:
- The issuer’s exposure to a critical risk of serious breach of the OECD Guidelines for Multinational Enterprises and
the UN Guidelines on Business and Human Rights.
- The proper application of the Management Company’s exclusion policy relating to these international treaties and
the process for ad hoc controversy monitoring.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
The EU Taxonomy sets out a “do not significant harm” principle by which Taxonomyaligned investments should
not significantly harm EU Taxonomy objectives and is accompanied by specific EU criteria. The “do no
significant harm” principle applies only to those investments underlying the financial product that take into
account the EU criteria for environmentally sustainable economic activities. The investments underlying the
remaining portion of this financial product do not take into account European Union criteria for environmentally
sustainable economic activities. Any other sustainable investments must also not significantly harm any
environmental or social objectives.
Does this financial product consider principal adverse impacts on sustainability factors?
☒ Yes
☐ No
Concernant les incidences négatives, ce produit financier prend en compte 14 indicateurs obligatoires du Tableau 1
de l'Annexe I du Règlement Délégué (UE) 2022/1288 de la Commission européenne, et inclut également les 2
indicateurs additionnels suivants :
- investments in companies without carbon reduction initiatives and
- investments in issuers without a workplace accident prevention policy
They are taken into account in the various areas of the management company's responsible investment approach:
through the exclusion policy (sectoral and norm-based), the ESG analysis methodology, the various impact scores,
the measurement and management of ESG performance indicators and engagement with companies.
Additional information about how the principal adverse impacts are taken into account is available in the document
“Article 4 SFDR: Principal adverse impacts” accessible on the Management Company’s website (https://
www.lfde.com), in the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents -
SFDR”.
This sub-fund is a feeder sub-fund of the Echiquier Arty SRI UCI (the “master UCI”). It is fully invested at all times in
Echiquier Arty SRI units of its master UCI, with cash on an ancillary basis.
The investment strategy
guides investment decisions
⚪ What are the binding elements of the investment strategy used to select the investments to attain each
based on factors such as
of the environmental or social characteristics promoted by this financial product?
investment objectives and
risk tolerance. The mandatory elements used to select investments and achieve the environmental and social characteristics
promoted by the Fund are as follows:
- the Management Company's exclusion policy and the resulting sectoral or norm-based exclusion constraints,
- the binding ESG assessment of each of the issuers in the portfolio,
- constraints associated with the sustainability indicators presented in the section “What sustainability indicators are
used to measure the attainment of each of the environmental or social characteristics promoted by this financial
product?” above.
⚪ What is the committed minimum rate to reduce the scope of the investments considered prior to the
application of that investment strategy?
The implementation of sectoral and norm-based exclusion filters and a binding ESG score make it possible to
reduce the investment universe.
⚪ What is the policy to assess good governance practices of the investee companies?
The monitoring of the application of good governance principles by issuers is controlled through two indicators:
• A quantitative indicator derived from the proprietary “GREaT” analysis methodology, the “Governance” pillar
notably covering issues such as balance of powers, fair remuneration and business ethics.
• An indicator derived from LFDE’s internal qualitative analysis. The analysis covers, among other things, issues
related to the competence of the management team, the existence of effective counter-powers, diversity on the
board, respect of minority shareholders and the assessment of extra-financial risks.
An issuer is deemed to have applied the principles of good governance when this is demonstrated by one of the
two aforementioned indicators.
Good governance practices
include sound management
structures, employee
relations, remuneration of
staff and tax compliance.
The financial product invests at least 90% of its assets in assets considered “eligible” according to the ESG process
implemented - therefore in investments that are aligned with the environmental and social characteristics promoted
(#1 Aligned with E/S characteristics).
Up to 10% of investments are not aligned with these characteristics (#2 Other).
The financial product invests at least 40% of its assets in assets considered to be sustainable investments (#1A
Sustainable).
A more detailed description of the specific asset allocation of this financial product can be found in its prospectus.
The derivatives used by the financial product are not intended to contribute to achieving the environmental or social
characteristics promoted. Their use is limited to hedging or temporary exposure in order to cover a strong
movement in liabilities, to gain temporary exposure to market beta or to accompany a change in strategy.
Furthermore, the Management Company ensures that the use of derivatives does not run counter to the
To comply with the EU environmental or social characteristics promoted by the financial product. In particular, the Management Company
taxonomy, the criteria for does not use derivatives to artificially improve the product’s extra-financial performance. The constraints relating to
fossil gas include limitations the use of derivatives are specified in the pre-contractual documentation for the financial product.
on emissions and switching
to renewable power or low- To what minimum extent are sustainable investments with an environmental objective
carbon fuels by the end of aligned with the EU Taxonomy?
2035. For nuclear energy,
the criteria include
The financial product may invest in environmentally sustainable economic activities, however the investments of
comprehensive safety and
this financial product do not take into account the European Union criteria for environmentally sustainable economic
waste management rules. activities. The financial product is committed to a 0% alignment with the European Taxonomy
Taxonomy-aligned:
Taxonomy-aligned:
Fossil gas
Fossil gas
Taxonomy-aligned:
Taxonomy-aligned:
Nuclear
Nuclear
Taxonomy-aligned (no
Taxonomy-aligned (no
fossil gas & nuclear)
fossil gas & nuclear)
Non Taxonomy-aligned
Non Taxonomy-aligned
are sustainable
This graph represents 100% of total investments.
investments with an
environmental * For the purpose of these graphs, “sovereign bonds” consist of all sovereign exposures.
objective that do not
take into account ⚪ What is the minimum share of investments in transitional and enabling activities?
the criteria for
environmentally The financial product does not commit to a minimum proportion of investment in transitional and enabling activities.
sustainable
economic activities What is the minimum share of sustainable investments with an environmental objective that are not
under the EU aligned with the EU Taxonomy?
taxonomy.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with an environmental objective that are not aligned with the
EU Taxonomy is 1%.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with a social objective is 1%.
(1) Fossil gas and nuclear activities will only be aligned with the EU Taxonomy if they contribute to limiting climate change (“climate change mitigation”) and do not cause significant harm to any other EU Taxonomy
objective - see explanatory note in the left margin. All criteria applicable to economic activities in the fossil gas and nuclear energy sectors that comply with the EU Taxonomy are defined in Commission
Delegated Regulation (EU) 2022/1214.
ECHIQUIER ARTY SRI FUND - Annexe SFDR article 8 6
What investments are included under “#2 Other”, what is their purpose and are there any minimum
environmental or social safeguards?
Investments included in the category “#2 Other” of the financial product represent up to 10% of investments.
Depending on the eligible instruments as defined in the product’s prospectus, these may include derivatives traded
on regulated or organised markets to expose and hedge the portfolio, cash and unrated issuers.
Derivatives and cash do not provide environmental or social safeguards.
Is a specific index designated as a reference benchmark to determine whether this financial product is
aligned with the environmental and/or social characteristics that it promotes?
Reference
benchmarks are indexes to Not applicable
measure whether the
financial product attains the ⚪ How is the reference benchmark continuously aligned with each of the environmental or social
environmental or social characteristics promoted by the financial product?
characteristics that they
promote. Not applicable
⚪ How is the alignment of the investment strategy with the methodology of the index ensured on a
continuous basis?
Not applicable
⚪ How does the designated index differ from a relevant broad market index?
Not applicable
⚪ Where can the methodology used for the calculation of the designated index be found?
Not applicable
More information about the Management Company’s extra-financial approach can be obtained through the
documents available on its website (https://www.lfde.com), in the “Responsible Investment” section, on the “To find
out more” page, under “LFDE Documents - SFDR”.
Additional information about the fund, in particular its regulatory documentation, is available on the Management
Company’s website (www.lfde.com), under the “Our Funds” section.
Product name:
Sustainable investment
ECHIQUIER WORLD EQUITY GROWTH Legal entity identifier: 529900BX1WZOQKIQNN14
means an investment in an
economic activity that FUND
contributes to an
Environmental and/or social characteristics
environmental or social
objective, provided that the Does this financial product have a sustainable investment objective?
investment does not
significantly harm any
environmental or social
☐ Yes ☒No
objective and that the
investee companies follow ☐ It will make a minimum of sustainable ☒ It promotes environmental and social (E/S) characteristics
good governance practices. investments with an environmental objective: and while it does not have as its objective a sustainable investment, it
:% will have a minimum proportion of 10% of sustainable investments
The EU Taxonomy is a
classification system ☐ in economic activities that qualify as ☐ with an environmental objective in economic activities that
laid down in Regulation (EU) environmentally sustainable under the EU qualify as environmentally sustainable under the EU Taxonomy
2020/852, establishing a list Taxonomy
☒ with an environmental objective in economic activities that do
of environmentally
sustainable economic
☐ in economic activities that do not qualify not qualify as environmentally sustainable under the EU
activities. That Regulation as environmentally sustainable under the EU Taxonomy
Taxonomy
does not lay down a list of
socially sustainable economic
☒ with a social objective
activities. Sustainable ☐ It will make a minimum ofsustainable
investments with an
investments with a social objective: %
☐ It promotes E/S characteristics, but will not make any sustainable
environmental objective might
investments
be aligned with the
Taxonomy or not.
What environmental and/or social characteristics are promoted by this financial product?
The responsible investment strategy is based on ESG criteria highlighting the environmental and/or social
Sustainability indicators are
characteristics promoted by this financial product, such as a reduction in the environmental impact of companies in
used to verify if the financial
terms of air pollution, preserving biodiversity, companies taking environmental risks into account or an improvement
product complies with the
in working conditions, the protection of employees, the fight against discrimination, etc.
environmental or social
characteristics promoted by
No specific index has been designated as a benchmark to determine whether the financial product is in line with the
the financial product.
environmental and/or social characteristics it promotes.
⚪ What sustainability indicators are used to measure the attainment of each of the
Sustainability indicators environmental or social characteristics promoted by this financial product?
measure how the
The contribution to one of the aforementioned environmental and social objectives is assessed using various
environmental or social
sources, including:
characteristics promoted by
For all environmental and social objectives:
the financial product are
- The “GREaT” score, the proprietary quantitative analysis methodology of the LBP AM Group, which covers all
attained..
environmental and social objectives,
- The “SDG” score, a proprietary qualitative analysis of LFDE that assesses companies’ products, services and
practices with a view to measuring their contribution to achieving the United Nations Sustainable Development
Goals (SDGs).
For objectives specific to climate and biodiversity:
- The issuer’s commitment to a decarbonisation trajectory in its activities compatible with the objectives of the Paris
Agreement, according to criteria defined by the Management Company,
- The “Greenfin” score, a quantitative indicator measuring the exposure of the business model of an issuer to green
activities as defined by the French government label Greenfin, dedicated to financing the energy and ecological
transition,
- The “Bird” score, a proprietary quantitative indicator of the LBP AM Group that aims to assess companies
primarily on their policies as well as on their practices and impacts related to biodiversity,
- The “Climate & Biodiversity Maturity” score, a proprietary qualitative analysis of LFDE that aims to assess the
maturity of companies in their consideration of the current and future climate and biodiversity issues they face.
Additional information about the various scores is available in the “SFDR – Sustainable Investment Methodology”
document available on the Management Company’s website (https://www.lfde.com), in the “Responsible
Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ What are the objectives of the sustainable investments that the financial product partially
intends to make and how does the sustainable investment contribute to such objectives?
Note that the methodology applied does not make it possible to measure the contribution of investments according
to the definition of the European Taxonomy (i.e. the taxonomy alignment of investments).
However, the contribution of investments to environmental objectives within the meaning of Article 2(17) of
Regulation (EU) 2019/2088 (“SFDR Regulation”) is measured using indicators specific to the LBP AM Group and
specified above.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ How do the sustainable investments that the financial product partially intends to make not cause
significant harm to any environmental or social sustainable investment objective?
In order to ensure that an investment contributing to a sustainability objective, according to the analysis method
presented above, does not cause significant harm to any environmental or social sustainable investment objective,
the methodology applied systematically considers, on a cumulative basis:
- The issuer's exposure to sectors that are sensitive in terms of environmental and social aspects (such as thermal
coal, controversial weapons, tobacco, gambling, etc.) in connection with the exclusion policies applicable in the
Management Companies of the LBP AM Group. A more complete description of the exclusions is available in the
“Exclusion Policy” document available on the Management Company’s website (https://www.lfde.com), in the
“Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - Approach and
Methodologies”.
- The issuer’s exposure to a severe controversy on environmental, social and governance issues.
- How are the sustainable investments aligned with the OECD Guidelines for Multinational
Enterprises and the UN Guiding Principles on Business and Human Rights?
In order to ensure that the sustainable investments are aligned with the OECD Guidelines for Multinational
Enterprises and the United Nations Guidelines on Business and Human Rights, the Management Company
systematically controls:
- The issuer’s exposure to a critical risk of serious breach of the OECD Guidelines for Multinational Enterprises and
the UN Guidelines on Business and Human Rights.
- The proper application of the Management Company’s exclusion policy relating to these international treaties and
the process for ad hoc controversy monitoring.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
The EU Taxonomy sets out a “do not significant harm” principle by which Taxonomyaligned investments should
not significantly harm EU Taxonomy objectives and is accompanied by specific EU criteria. The “do no
significant harm” principle applies only to those investments underlying the financial product that take into
account the EU criteria for environmentally sustainable economic activities. The investments underlying the
remaining portion of this financial product do not take into account European Union criteria for environmentally
sustainable economic activities. Any other sustainable investments must also not significantly harm any
environmental or social objectives.
Does this financial product consider principal adverse impacts on sustainability factors?
☒ Yes
☐ No
Echiquier World Equity Growth Fund is a stock-picking UCI. It is invested in large international stocks with strong
exposure to global growth, with solid global leadership positions in their sector.
The investment strategy
guides investment decisions
⚪ What are the binding elements of the investment strategy used to select the investments to attain each
based on factors such as
of the environmental or social characteristics promoted by this financial product?
investment objectives and
risk tolerance. The mandatory elements used to select investments and achieve the environmental and social characteristics
promoted by the Fund are as follows:
- the Management Company's exclusion policy and the resulting sectoral or norm-based exclusion constraints,
- the binding ESG assessment of each of the issuers in the portfolio,
- constraints associated with the sustainability indicators presented in the section “What sustainability indicators are
used to measure the attainment of each of the environmental or social characteristics promoted by this financial
product?” above.
⚪ What is the committed minimum rate to reduce the scope of the investments considered prior to the
application of that investment strategy?
The implementation of sectoral and norm-based exclusion filters and a binding ESG score make it possible to
reduce the investment universe.
⚪ What is the policy to assess good governance practices of the investee companies?
The monitoring of the application of good governance principles by issuers is controlled through two indicators:
• A quantitative indicator derived from the proprietary “GREaT” analysis methodology, the “Governance” pillar
notably covering issues such as balance of powers, fair remuneration and business ethics.
• An indicator derived from LFDE’s internal qualitative analysis. The analysis covers, among other things, issues
related to the competence of the management team, the existence of effective counter-powers, diversity on the
board, respect of minority shareholders and the assessment of extra-financial risks.
The financial product invests at least 90% of its assets in assets considered “eligible” according to the ESG process
implemented - therefore in investments that are aligned with the environmental and social characteristics promoted
(#1 Aligned with E/S characteristics).
Up to 10% of investments are not aligned with these characteristics (#2 Other).
The financial product invests at least 10% of its assets in assets considered to be sustainable investments (#1A
Sustainable).
A more detailed description of the specific asset allocation of this financial product can be found in its prospectus.
The derivatives used by the financial product are not intended to contribute to achieving the environmental or social
characteristics promoted. Their use is limited to hedging or temporary exposure in order to cover a strong
movement in liabilities, to gain temporary exposure to market beta or to accompany a change in strategy.
Furthermore, the Management Company ensures that the use of derivatives does not run counter to the
To comply with the EU environmental or social characteristics promoted by the financial product. In particular, the Management Company
taxonomy, the criteria for does not use derivatives to artificially improve the product’s extra-financial performance. The constraints relating to
fossil gas include limitations the use of derivatives are specified in the pre-contractual documentation for the financial product.
on emissions and switching
to renewable power or low- To what minimum extent are sustainable investments with an environmental objective
carbon fuels by the end of aligned with the EU Taxonomy?
2035. For nuclear energy,
the criteria include
The financial product may invest in environmentally sustainable economic activities, however the investments of
comprehensive safety and
this financial product do not take into account the European Union criteria for environmentally sustainable economic
waste management rules. activities. The financial product is committed to a 0% alignment with the European Taxonomy
Taxonomy-aligned:
Taxonomy-aligned:
Fossil gas
Fossil gas
Taxonomy-aligned:
Taxonomy-aligned:
Nuclear
Nuclear
Taxonomy-aligned (no
Taxonomy-aligned (no
fossil gas & nuclear)
fossil gas & nuclear)
Non Taxonomy-aligned
Non Taxonomy-aligned
are sustainable
This graph represents 100% of total investments.
investments with an
environmental * For the purpose of these graphs, “sovereign bonds” consist of all sovereign exposures.
objective that do not
take into account ⚪ What is the minimum share of investments in transitional and enabling activities?
the criteria for
environmentally The financial product does not commit to a minimum proportion of investment in transitional and enabling activities.
sustainable
economic activities What is the minimum share of sustainable investments with an environmental objective that are not
under the EU aligned with the EU Taxonomy?
taxonomy.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with an environmental objective that are not aligned with the
EU Taxonomy is 1%.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with a social objective is 1%.
(1) Fossil gas and nuclear activities will only be aligned with the EU Taxonomy if they contribute to limiting climate change (“climate change mitigation”) and do not cause significant harm to any other EU Taxonomy
objective - see explanatory note in the left margin. All criteria applicable to economic activities in the fossil gas and nuclear energy sectors that comply with the EU Taxonomy are defined in Commission
Delegated Regulation (EU) 2022/1214.
ECHIQUIER WORLD EQUITY GROWTH FUND - Annexe SFDR article 8 6
What investments are included under “#2 Other”, what is their purpose and are there any minimum
environmental or social safeguards?
Investments included in the category “#2 Other” of the financial product represent up to 10% of investments.
Depending on the eligible instruments as defined in the product’s prospectus, these may include derivatives traded
on regulated or organised markets to expose and hedge the portfolio, cash and unrated issuers.
Derivatives and cash do not provide environmental or social safeguards.
Is a specific index designated as a reference benchmark to determine whether this financial product is
aligned with the environmental and/or social characteristics that it promotes?
Not applicable
⚪ How does the designated index differ from a relevant broad market index?
Not applicable
⚪ Where can the methodology used for the calculation of the designated index be found?
Not applicable
More information about the Management Company’s extra-financial approach can be obtained through the
documents available on its website (https://www.lfde.com), in the “Responsible Investment” section, on the “To find
out more” page, under “LFDE Documents - SFDR”.
Additional information about the fund, in particular its regulatory documentation, is available on the Management
Company’s website (www.lfde.com), under the “Our Funds” section.
Product name:
Sustainable investment
ECHIQUIER MAJOR SRI GROWTH Legal entity identifier: 529900EHRFH1X6K6D360
means an investment in an
economic activity that EUROPE FUND
contributes to an
Environmental and/or social characteristics
environmental or social
objective, provided that the Does this financial product have a sustainable investment objective?
investment does not
significantly harm any
environmental or social
☐ Yes ☒No
objective and that the
investee companies follow ☐ It will make a minimum of sustainable ☒ It promotes environmental and social (E/S) characteristics
good governance practices. investments with an environmental objective: and while it does not have as its objective a sustainable investment, it
:% will have a minimum proportion of 40% of sustainable investments
The EU Taxonomy is a
classification system ☐ in economic activities that qualify as ☐ with an environmental objective in economic activities that
laid down in Regulation (EU) environmentally sustainable under the EU qualify as environmentally sustainable under the EU Taxonomy
2020/852, establishing a list Taxonomy
☒ with an environmental objective in economic activities that do
of environmentally
sustainable economic
☐ in economic activities that do not qualify not qualify as environmentally sustainable under the EU
activities. That Regulation as environmentally sustainable under the EU Taxonomy
Taxonomy
does not lay down a list of
socially sustainable economic
☒ with a social objective
activities. Sustainable ☐ It will make a minimum ofsustainable
investments with an
investments with a social objective: %
☐ It promotes E/S characteristics, but will not make any sustainable
environmental objective might
investments
be aligned with the
Taxonomy or not.
What environmental and/or social characteristics are promoted by this financial product?
Sustainability indicators ⚪ What sustainability indicators are used to measure the attainment of each of the
measure how the environmental or social characteristics promoted by this financial product?
environmental or social
The contribution to one of the aforementioned environmental and social objectives is assessed using various
characteristics promoted by
sources, including:
the financial product are
For all environmental and social objectives:
attained..
- The “GREaT” score, the proprietary quantitative analysis methodology of the LBP AM Group, which covers all
environmental and social objectives,
- The “SDG” score, a proprietary qualitative analysis of LFDE that assesses companies’ products, services and
practices with a view to measuring their contribution to achieving the United Nations Sustainable Development
Goals (SDGs).
For objectives specific to climate and biodiversity:
- The issuer’s commitment to a decarbonisation trajectory in its activities compatible with the objectives of the Paris
Agreement, according to criteria defined by the Management Company,
- The “Greenfin” score, a quantitative indicator measuring the exposure of the business model of an issuer to green
activities as defined by the French government label Greenfin, dedicated to financing the energy and ecological
transition,
- The “Bird” score, a proprietary quantitative indicator of the LBP AM Group that aims to assess companies
primarily on their policies as well as on their practices and impacts related to biodiversity,
- The “Climate & Biodiversity Maturity” score, a proprietary qualitative analysis of LFDE that aims to assess the
maturity of companies in their consideration of the current and future climate and biodiversity issues they face.
Additional information about the various scores is available in the “SFDR – Sustainable Investment Methodology”
document available on the Management Company’s website (https://www.lfde.com), in the “Responsible
Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ What are the objectives of the sustainable investments that the financial product partially
intends to make and how does the sustainable investment contribute to such objectives?
Note that the methodology applied does not make it possible to measure the contribution of investments according
to the definition of the European Taxonomy (i.e. the taxonomy alignment of investments).
However, the contribution of investments to environmental objectives within the meaning of Article 2(17) of
Regulation (EU) 2019/2088 (“SFDR Regulation”) is measured using indicators specific to the LBP AM Group and
specified above.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ How do the sustainable investments that the financial product partially intends to make not cause
significant harm to any environmental or social sustainable investment objective?
In order to ensure that an investment contributing to a sustainability objective, according to the analysis method
presented above, does not cause significant harm to any environmental or social sustainable investment objective,
the methodology applied systematically considers, on a cumulative basis:
- The issuer's exposure to sectors that are sensitive in terms of environmental and social aspects (such as thermal
coal, controversial weapons, tobacco, gambling, etc.) in connection with the exclusion policies applicable in the
Management Companies of the LBP AM Group. A more complete description of the exclusions is available in the
“Exclusion Policy” document available on the Management Company’s website (https://www.lfde.com), in the
“Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - Approach and
Methodologies”.
- The issuer’s exposure to a severe controversy on environmental, social and governance issues.
- How are the sustainable investments aligned with the OECD Guidelines for Multinational
Enterprises and the UN Guiding Principles on Business and Human Rights?
In order to ensure that the sustainable investments are aligned with the OECD Guidelines for Multinational
Enterprises and the United Nations Guidelines on Business and Human Rights, the Management Company
systematically controls:
- The issuer’s exposure to a critical risk of serious breach of the OECD Guidelines for Multinational Enterprises and
the UN Guidelines on Business and Human Rights.
- The proper application of the Management Company’s exclusion policy relating to these international treaties and
the process for ad hoc controversy monitoring.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
The EU Taxonomy sets out a “do not significant harm” principle by which Taxonomyaligned investments should
not significantly harm EU Taxonomy objectives and is accompanied by specific EU criteria. The “do no
significant harm” principle applies only to those investments underlying the financial product that take into
account the EU criteria for environmentally sustainable economic activities. The investments underlying the
remaining portion of this financial product do not take into account European Union criteria for environmentally
sustainable economic activities. Any other sustainable investments must also not significantly harm any
environmental or social objectives.
Does this financial product consider principal adverse impacts on sustainability factors?
☒ Yes
☐ No
Regarding the adverse impacts, this financial product takes into account 14 mandatory indicators from Table 1 of
Annex I of European Commission Delegated Regulation (EU) 2022/1288, and also includes the following two
additional indicators:
- investments in companies without carbon reduction initiatives and
- investments in issuers without a workplace accident prevention policy
They are taken into account in the various areas of the management company's responsible investment approach:
through the exclusion policy (sectoral and norm-based), the ESG analysis methodology, the various impact scores,
the measurement and management of ESG performance indicators and engagement with companies.
Additional information about how the principal adverse impacts are taken into account is available in the document
“Article 4 SFDR: Principal adverse impacts” accessible on the Management Company’s website (https://
www.lfde.com), in the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents -
SFDR”.
Echiquier Major SRI Growth Europe Fund is a stock-picking UCI. Its investment universe is that of large European
growth stocks, with solid leadership positions in their sector.
The investment strategy
guides investment decisions
⚪ What are the binding elements of the investment strategy used to select the investments to attain each
based on factors such as
of the environmental or social characteristics promoted by this financial product?
investment objectives and
risk tolerance. The mandatory elements used to select investments and achieve the environmental and social characteristics
promoted by the Fund are as follows:
- the Management Company's exclusion policy and the resulting sectoral or norm-based exclusion constraints,
- the binding ESG assessment of each of the issuers in the portfolio,
- constraints associated with the sustainability indicators presented in the section “What sustainability indicators are
used to measure the attainment of each of the environmental or social characteristics promoted by this financial
product?” above.
⚪ What is the committed minimum rate to reduce the scope of the investments considered prior to the
application of that investment strategy?
The implementation of sectoral and norm-based exclusion filters and a binding ESG score make it possible to
reduce the investment universe.
⚪ What is the policy to assess good governance practices of the investee companies?
The monitoring of the application of good governance principles by issuers is controlled through two indicators:
• A quantitative indicator derived from the proprietary “GREaT” analysis methodology, the “Governance” pillar
notably covering issues such as balance of powers, fair remuneration and business ethics.
• An indicator derived from LFDE’s internal qualitative analysis. The analysis covers, among other things, issues
related to the competence of the management team, the existence of effective counter-powers, diversity on the
board, respect of minority shareholders and the assessment of extra-financial risks.
An issuer is deemed to have applied the principles of good governance when this is demonstrated by one of the
two aforementioned indicators.
The financial product invests at least 90% of its assets in assets considered “eligible” according to the ESG process
implemented - therefore in investments that are aligned with the environmental and social characteristics promoted
(#1 Aligned with E/S characteristics).
Up to 10% of investments are not aligned with these characteristics (#2 Other).
The financial product invests at least 40% of its assets in assets considered to be sustainable investments (#1A
Sustainable).
A more detailed description of the specific asset allocation of this financial product can be found in its prospectus.
The derivatives used by the financial product are not intended to contribute to achieving the environmental or social
characteristics promoted. Their use is limited to hedging or temporary exposure in order to cover a strong
movement in liabilities, to gain temporary exposure to market beta or to accompany a change in strategy.
Furthermore, the Management Company ensures that the use of derivatives does not run counter to the
To comply with the EU environmental or social characteristics promoted by the financial product. In particular, the Management Company
taxonomy, the criteria for does not use derivatives to artificially improve the product’s extra-financial performance. The constraints relating to
fossil gas include limitations the use of derivatives are specified in the pre-contractual documentation for the financial product.
on emissions and switching
to renewable power or low- To what minimum extent are sustainable investments with an environmental objective
carbon fuels by the end of aligned with the EU Taxonomy?
2035. For nuclear energy,
the criteria include
The financial product may invest in environmentally sustainable economic activities, however the investments of
comprehensive safety and
this financial product do not take into account the European Union criteria for environmentally sustainable economic
waste management rules. activities. The financial product is committed to a 0% alignment with the European Taxonomy
Taxonomy-aligned:
Taxonomy-aligned:
Fossil gas
Fossil gas
Taxonomy-aligned:
Taxonomy-aligned:
Nuclear
Nuclear
Taxonomy-aligned (no
Taxonomy-aligned (no
fossil gas & nuclear)
fossil gas & nuclear)
Non Taxonomy-aligned
Non Taxonomy-aligned
are sustainable
This graph represents 100% of total investments.
investments with an
environmental * For the purpose of these graphs, “sovereign bonds” consist of all sovereign exposures.
objective that do not
take into account ⚪ What is the minimum share of investments in transitional and enabling activities?
the criteria for
environmentally The financial product does not commit to a minimum proportion of investment in transitional and enabling activities.
sustainable
economic activities What is the minimum share of sustainable investments with an environmental objective that are not
under the EU aligned with the EU Taxonomy?
taxonomy.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with an environmental objective that are not aligned with the
EU Taxonomy is 1%.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with a social objective is 1%.
(1) Fossil gas and nuclear activities will only be aligned with the EU Taxonomy if they contribute to limiting climate change (“climate change mitigation”) and do not cause significant harm to any other EU Taxonomy
objective - see explanatory note in the left margin. All criteria applicable to economic activities in the fossil gas and nuclear energy sectors that comply with the EU Taxonomy are defined in Commission
Delegated Regulation (EU) 2022/1214.
ECHIQUIER MAJOR SRI GROWTH EUROPE FUND - Annexe SFDR article 8 6
What investments are included under “#2 Other”, what is their purpose and are there any minimum
environmental or social safeguards?
Investments included in the category “#2 Other” of the financial product represent up to 10% of investments.
Depending on the eligible instruments as defined in the product’s prospectus, these may include derivatives traded
on regulated or organised markets to expose and hedge the portfolio, cash and unrated issuers.
Derivatives and cash do not provide environmental or social safeguards.
Is a specific index designated as a reference benchmark to determine whether this financial product is
aligned with the environmental and/or social characteristics that it promotes?
Not applicable
⚪ How does the designated index differ from a relevant broad market index?
Not applicable
⚪ Where can the methodology used for the calculation of the designated index be found?
Not applicable
More information about the Management Company’s extra-financial approach can be obtained through the
documents available on its website (https://www.lfde.com), in the “Responsible Investment” section, on the “To find
out more” page, under “LFDE Documents - SFDR”.
Additional information about the fund, in particular its regulatory documentation, is available on the Management
Company’s website (www.lfde.com), under the “Our Funds” section.
Product name:
Sustainable investment Legal entity identifier: 5299000XN3AJ5QX5ND70
ECHIQUIER ARTIFICIAL INTELLIGENCE
means an investment in an
economic activity that Environmental and/or social characteristics
contributes to an
environmental or social Does this financial product have a sustainable investment objective?
objective, provided that the
investment does not ☐ Yes ☒No
significantly harm any
environmental or social
objective and that the
☐ It will make a minimum of sustainable ☒ It promotes environmental and social (E/S) characteristics
investee companies follow investments with an environmental objective: and while it does not have as its objective a sustainable investment, it
good governance practices. :% will have a minimum proportion of 10% of sustainable investments
☐ in economic activities that qualify as ☐ with an environmental objective in economic activities that
The EU Taxonomy is a
environmentally sustainable under the EU qualify as environmentally sustainable under the EU Taxonomy
classification system
Taxonomy
laid down in Regulation (EU)
☒ with an environmental objective in economic activities that do
2020/852, establishing a list ☐ in economic activities that do not qualify not qualify as environmentally sustainable under the EU
of environmentally
as environmentally sustainable under the EU Taxonomy
sustainable economic
Taxonomy
activities. That Regulation ☒ with a social objective
does not lay down a list of
socially sustainable economic ☐ It will make a minimum ofsustainable
activities. Sustainable investments with a social objective: %
☐ It promotes E/S characteristics, but will not make any sustainable
investments with an investments
environmental objective might
be aligned with the
Taxonomy or not.
What environmental and/or social characteristics are promoted by this financial product?
Sustainability indicators are The responsible investment strategy is based on ESG criteria highlighting the environmental and/or social
used to verify if the financial characteristics promoted by this financial product, such as a reduction in the environmental impact of companies in
product complies with the terms of air pollution, preserving biodiversity, companies taking environmental risks into account or an improvement
environmental or social in working conditions, the protection of employees, the fight against discrimination, etc.
characteristics promoted by
the financial product. No specific index has been designated as a benchmark to determine whether the financial product is in line with the
environmental and/or social characteristics it promotes.
⚪ What sustainability indicators are used to measure the attainment of each of the
Sustainability indicators
environmental or social characteristics promoted by this financial product?
measure how the
environmental or social The contribution to one of the aforementioned environmental and social objectives is assessed using various
characteristics promoted by sources, including:
the financial product are For all environmental and social objectives:
attained.. - The “GREaT” score, the proprietary quantitative analysis methodology of the LBP AM Group, which covers all
environmental and social objectives,
- The “SDG” score, a proprietary qualitative analysis of LFDE that assesses companies’ products, services and
practices with a view to measuring their contribution to achieving the United Nations Sustainable Development
Goals (SDGs).
For objectives specific to climate and biodiversity:
- The issuer’s commitment to a decarbonisation trajectory in its activities compatible with the objectives of the Paris
Agreement, according to criteria defined by the Management Company,
- The “Greenfin” score, a quantitative indicator measuring the exposure of the business model of an issuer to green
activities as defined by the French government label Greenfin, dedicated to financing the energy and ecological
transition,
- The “Bird” score, a proprietary quantitative indicator of the LBP AM Group that aims to assess companies
primarily on their policies as well as on their practices and impacts related to biodiversity,
- The “Climate & Biodiversity Maturity” score, a proprietary qualitative analysis of LFDE that aims to assess the
maturity of companies in their consideration of the current and future climate and biodiversity issues they face.
Additional information about the various scores is available in the “SFDR – Sustainable Investment Methodology”
document available on the Management Company’s website (https://www.lfde.com), in the “Responsible
Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ What are the objectives of the sustainable investments that the financial product partially
intends to make and how does the sustainable investment contribute to such objectives?
Note that the methodology applied does not make it possible to measure the contribution of investments according
to the definition of the European Taxonomy (i.e. the taxonomy alignment of investments).
However, the contribution of investments to environmental objectives within the meaning of Article 2(17) of
Regulation (EU) 2019/2088 (“SFDR Regulation”) is measured using indicators specific to the LBP AM Group and
specified above.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ How do the sustainable investments that the financial product partially intends to make not cause
significant harm to any environmental or social sustainable investment objective?
In order to ensure that an investment contributing to a sustainability objective, according to the analysis method
presented above, does not cause significant harm to any environmental or social sustainable investment objective,
the methodology applied systematically considers, on a cumulative basis:
- The issuer's exposure to sectors that are sensitive in terms of environmental and social aspects (such as thermal
coal, controversial weapons, tobacco, gambling, etc.) in connection with the exclusion policies applicable in the
Management Companies of the LBP AM Group. A more complete description of the exclusions is available in the
“Exclusion Policy” document available on the Management Company’s website (https://www.lfde.com), in the
“Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - Approach and
Methodologies”.
- The issuer’s exposure to a severe controversy on environmental, social and governance issues.
- How are the sustainable investments aligned with the OECD Guidelines for Multinational
Enterprises and the UN Guiding Principles on Business and Human Rights?
In order to ensure that the sustainable investments are aligned with the OECD Guidelines for Multinational
Enterprises and the United Nations Guidelines on Business and Human Rights, the Management Company
systematically controls:
- The issuer’s exposure to a critical risk of serious breach of the OECD Guidelines for Multinational Enterprises and
the UN Guidelines on Business and Human Rights.
- The proper application of the Management Company’s exclusion policy relating to these international treaties and
the process for ad hoc controversy monitoring.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
The EU Taxonomy sets out a “do not significant harm” principle by which Taxonomyaligned investments should
not significantly harm EU Taxonomy objectives and is accompanied by specific EU criteria. The “do no
significant harm” principle applies only to those investments underlying the financial product that take into
account the EU criteria for environmentally sustainable economic activities. The investments underlying the
remaining portion of this financial product do not take into account European Union criteria for environmentally
sustainable economic activities. Any other sustainable investments must also not significantly harm any
environmental or social objectives.
Does this financial product consider principal adverse impacts on sustainability factors?
☒ Yes
☐ No
Regarding the adverse impacts, this financial product takes into account 14 mandatory indicators from Table 1 of
Annex I of European Commission Delegated Regulation (EU) 2022/1288, and also includes the following two
additional indicators:
- investments in companies without carbon reduction initiatives and
- investments in issuers without a workplace accident prevention policy
They are taken into account in the various areas of the management company's responsible investment approach:
through the exclusion policy (sectoral and norm-based), the ESG analysis methodology, the various impact scores,
the measurement and management of ESG performance indicators and engagement with companies.
Additional information about how the principal adverse impacts are taken into account is available in the document
“Article 4 SFDR: Principal adverse impacts” accessible on the Management Company’s website (https://
www.lfde.com), in the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents -
SFDR”.
Echiquier Artificial Intelligence is a SICAV sub-fund invested in large international stocks that benefit from or
develop artificial intelligence.
The investment strategy
guides investment decisions
⚪ What are the binding elements of the investment strategy used to select the investments to attain each
based on factors such as
of the environmental or social characteristics promoted by this financial product?
investment objectives and
risk tolerance. The mandatory elements used to select investments and achieve the environmental and social characteristics
promoted by the Fund are as follows:
- the Management Company's exclusion policy and the resulting sectoral or norm-based exclusion constraints,
- the binding ESG assessment of each of the issuers in the portfolio,
- constraints associated with the sustainability indicators presented in the section “What sustainability indicators are
used to measure the attainment of each of the environmental or social characteristics promoted by this financial
product?” above.
⚪ What is the committed minimum rate to reduce the scope of the investments considered prior to the
application of that investment strategy?
The implementation of sectoral and norm-based exclusion filters and a binding ESG score make it possible to
reduce the investment universe.
⚪ What is the policy to assess good governance practices of the investee companies?
The monitoring of the application of good governance principles by issuers is controlled through two indicators:
• A quantitative indicator derived from the proprietary “GREaT” analysis methodology, the “Governance” pillar
notably covering issues such as balance of powers, fair remuneration and business ethics.
• An indicator derived from LFDE’s internal qualitative analysis. The analysis covers, among other things, issues
related to the competence of the management team, the existence of effective counter-powers, diversity on the
board, respect of minority shareholders and the assessment of extra-financial risks.
An issuer is deemed to have applied the principles of good governance when this is demonstrated by one of the
two aforementioned indicators.
The financial product invests at least 90% of its assets in assets considered “eligible” according to the ESG process
implemented - therefore in investments that are aligned with the environmental and social characteristics promoted
(#1 Aligned with E/S characteristics).
Up to 10% of investments are not aligned with these characteristics (#2 Other).
The financial product invests at least 10% of its assets in assets considered to be sustainable investments (#1A
Sustainable).
A more detailed description of the specific asset allocation of this financial product can be found in its prospectus.
The derivatives used by the financial product are not intended to contribute to achieving the environmental or social
characteristics promoted. Their use is limited to hedging or temporary exposure in order to cover a strong
movement in liabilities, to gain temporary exposure to market beta or to accompany a change in strategy.
Furthermore, the Management Company ensures that the use of derivatives does not run counter to the
To comply with the EU environmental or social characteristics promoted by the financial product. In particular, the Management Company
taxonomy, the criteria for does not use derivatives to artificially improve the product’s extra-financial performance. The constraints relating to
fossil gas include limitations the use of derivatives are specified in the pre-contractual documentation for the financial product.
on emissions and switching
to renewable power or low- To what minimum extent are sustainable investments with an environmental objective
carbon fuels by the end of aligned with the EU Taxonomy?
2035. For nuclear energy,
the criteria include
The financial product may invest in environmentally sustainable economic activities, however the investments of
comprehensive safety and
this financial product do not take into account the European Union criteria for environmentally sustainable economic
waste management rules. activities. The financial product is committed to a 0% alignment with the European Taxonomy
Taxonomy-aligned:
Taxonomy-aligned:
Fossil gas
Fossil gas
Taxonomy-aligned:
Taxonomy-aligned:
Nuclear
Nuclear
Taxonomy-aligned (no
Taxonomy-aligned (no
fossil gas & nuclear)
fossil gas & nuclear)
Non Taxonomy-aligned
Non Taxonomy-aligned
are sustainable
This graph represents 100% of total investments.
investments with an
environmental * For the purpose of these graphs, “sovereign bonds” consist of all sovereign exposures.
objective that do not
take into account ⚪ What is the minimum share of investments in transitional and enabling activities?
the criteria for
environmentally The financial product does not commit to a minimum proportion of investment in transitional and enabling activities.
sustainable
economic activities What is the minimum share of sustainable investments with an environmental objective that are not
under the EU aligned with the EU Taxonomy?
taxonomy.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with an environmental objective that are not aligned with the
EU Taxonomy is 1%.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with a social objective is 1%.
(1) Fossil gas and nuclear activities will only be aligned with the EU Taxonomy if they contribute to limiting climate change (“climate change mitigation”) and do not cause significant harm to any other EU Taxonomy
objective - see explanatory note in the left margin. All criteria applicable to economic activities in the fossil gas and nuclear energy sectors that comply with the EU Taxonomy are defined in Commission
Delegated Regulation (EU) 2022/1214.
ECHIQUIER ARTIFICIAL INTELLIGENCE - Annexe SFDR article 8 6
What investments are included under “#2 Other”, what is their purpose and are there any minimum
environmental or social safeguards?
Investments included in the category “#2 Other” of the financial product represent up to 10% of investments.
Depending on the eligible instruments as defined in the product’s prospectus, these may include derivatives traded
on regulated or organised markets to expose and hedge the portfolio, cash and unrated issuers.
Derivatives and cash do not provide environmental or social safeguards.
Is a specific index designated as a reference benchmark to determine whether this financial product is
aligned with the environmental and/or social characteristics that it promotes?
Not applicable
⚪ How does the designated index differ from a relevant broad market index?
Not applicable
⚪ Where can the methodology used for the calculation of the designated index be found?
Not applicable
More information about the Management Company’s extra-financial approach can be obtained through the
documents available on its website (https://www.lfde.com), in the “Responsible Investment” section, on the “To find
out more” page, under “LFDE Documents - SFDR”.
Additional information about the fund, in particular its regulatory documentation, is available on the Management
Company’s website (www.lfde.com), under the “Our Funds” section.
Product name:
Sustainable investment Legal entity identifier: 529900LX87C9EMC05C69
ECHIQUIER SPACE
means an investment in an
economic activity that Environmental and/or social characteristics
contributes to an
environmental or social Does this financial product have a sustainable investment objective?
objective, provided that the
investment does not ☐ Yes ☒No
significantly harm any
environmental or social
objective and that the
☐ It will make a minimum of sustainable ☒ It promotes environmental and social (E/S) characteristics
investee companies follow investments with an environmental objective: and while it does not have as its objective a sustainable investment, it
good governance practices. % will have a minimum proportion of 10% of sustainable investments
☐ in economic activities that qualify as ☐ with an environmental objective in economic activities that
The EU Taxonomy is a
environmentally sustainable under the EU qualify as environmentally sustainable under the EU Taxonomy
classification system
Taxonomy
laid down in Regulation (EU)
☒ with an environmental objective in economic activities that do
2020/852, establishing a list ☐ in economic activities that do not qualify not qualify as environmentally sustainable under the EU
of environmentally
as environmentally sustainable under the EU Taxonomy
sustainable economic
Taxonomy
activities. That Regulation ☒ with a social objective
does not lay down a list of
socially sustainable economic ☐ It will make a minimum ofsustainable
activities. Sustainable investments with a social objective: %
☐ It promotes E/S characteristics, but will not make any sustainable
investments with an investments
environmental objective might
be aligned with the
Taxonomy or not.
What environmental and/or social characteristics are promoted by this financial product?
Sustainability indicators are The responsible investment strategy is based on ESG criteria highlighting the environmental and/or social
used to verify if the financial characteristics promoted by this financial product, such as a reduction in the environmental impact of companies in
product complies with the terms of air pollution, preserving biodiversity, companies taking environmental risks into account or an improvement
environmental or social in working conditions, the protection of employees, the fight against discrimination, etc.
characteristics promoted by
the financial product. No specific index has been designated as a benchmark to determine whether the financial product is in line with the
environmental and/or social characteristics it promotes.
⚪ What sustainability indicators are used to measure the attainment of each of the
Sustainability indicators
environmental or social characteristics promoted by this financial product?
measure how the
environmental or social The contribution to one of the aforementioned environmental and social objectives is assessed using various
characteristics promoted by sources, including:
the financial product are For all environmental and social objectives:
attained.. - The “GREaT” score, the proprietary quantitative analysis methodology of the LBP AM Group, which covers all
environmental and social objectives,
- The “SDG” score, a proprietary qualitative analysis of LFDE that assesses companies’ products, services and
practices with a view to measuring their contribution to achieving the United Nations Sustainable Development
Goals (SDGs).
For objectives specific to climate and biodiversity:
- The issuer’s commitment to a decarbonisation trajectory in its activities compatible with the objectives of the Paris
Agreement, according to criteria defined by the Management Company,
- The “Greenfin” score, a quantitative indicator measuring the exposure of the business model of an issuer to green
activities as defined by the French government label Greenfin, dedicated to financing the energy and ecological
transition,
- The “Bird” score, a proprietary quantitative indicator of the LBP AM Group that aims to assess companies
primarily on their policies as well as on their practices and impacts related to biodiversity,
- The “Climate & Biodiversity Maturity” score, a proprietary qualitative analysis of LFDE that aims to assess the
maturity of companies in their consideration of the current and future climate and biodiversity issues they face.
Additional information about the various scores is available in the “SFDR – Sustainable Investment Methodology”
document available on the Management Company’s website (https://www.lfde.com), in the “Responsible
Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ What are the objectives of the sustainable investments that the financial product partially
intends to make and how does the sustainable investment contribute to such objectives?
Note that the methodology applied does not make it possible to measure the contribution of investments according
to the definition of the European Taxonomy (i.e. the taxonomy alignment of investments).
However, the contribution of investments to environmental objectives within the meaning of Article 2(17) of
Regulation (EU) 2019/2088 (“SFDR Regulation”) is measured using indicators specific to the LBP AM Group and
specified above.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ How do the sustainable investments that the financial product partially intends to make not cause
significant harm to any environmental or social sustainable investment objective?
In order to ensure that an investment contributing to a sustainability objective, according to the analysis method
presented above, does not cause significant harm to any environmental or social sustainable investment objective,
the methodology applied systematically considers, on a cumulative basis:
- The issuer's exposure to sectors that are sensitive in terms of environmental and social aspects (such as thermal
coal, controversial weapons, tobacco, gambling, etc.) in connection with the exclusion policies applicable in the
Management Companies of the LBP AM Group. A more complete description of the exclusions is available in the
“Exclusion Policy” document available on the Management Company’s website (https://www.lfde.com), in the
“Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - Approach and
Methodologies”.
- The issuer’s exposure to a severe controversy on environmental, social and governance issues.
- How are the sustainable investments aligned with the OECD Guidelines for Multinational
Enterprises and the UN Guiding Principles on Business and Human Rights?
In order to ensure that the sustainable investments are aligned with the OECD Guidelines for Multinational
Enterprises and the United Nations Guidelines on Business and Human Rights, the Management Company
systematically controls:
- The issuer’s exposure to a critical risk of serious breach of the OECD Guidelines for Multinational Enterprises and
the UN Guidelines on Business and Human Rights.
- The proper application of the Management Company’s exclusion policy relating to these international treaties and
the process for ad hoc controversy monitoring.
A more complete description of the thresholds applied for each criterion is available in the “SFDR – Sustainable
Investment Methodology” document accessible on the Management Company’s website (https://www.lfde.com), in
the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
The EU Taxonomy sets out a “do not significant harm” principle by which Taxonomyaligned investments should
not significantly harm EU Taxonomy objectives and is accompanied by specific EU criteria. The “do no
significant harm” principle applies only to those investments underlying the financial product that take into
account the EU criteria for environmentally sustainable economic activities. The investments underlying the
remaining portion of this financial product do not take into account European Union criteria for environmentally
sustainable economic activities. Any other sustainable investments must also not significantly harm any
environmental or social objectives.
Does this financial product consider principal adverse impacts on sustainability factors?
☒ Yes
☐ No
Regarding the adverse impacts, this financial product takes into account 14 mandatory indicators from Table 1 of
Annex I of European Commission Delegated Regulation (EU) 2022/1288, and also includes the following two
additional indicators:
- investments in companies without carbon reduction initiatives and
- investments in issuers without a workplace accident prevention policy
They are taken into account in the various areas of the management company's responsible investment approach:
through the exclusion policy (sectoral and norm-based), the ESG analysis methodology, the various impact scores,
the measurement and management of ESG performance indicators and engagement with companies.
Additional information about how the principal adverse impacts are taken into account is available in the document
“Article 4 SFDR: Principal adverse impacts” accessible on the Management Company’s website (https://
www.lfde.com), in the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents -
SFDR”.
⚪ What is the committed minimum rate to reduce the scope of the investments considered prior to the
application of that investment strategy?
The implementation of sectoral and norm-based exclusion filters and a binding ESG score make it possible to
reduce the investment universe.
⚪ What is the policy to assess good governance practices of the investee companies?
The monitoring of the application of good governance principles by issuers is controlled through two indicators:
• A quantitative indicator derived from the proprietary “GREaT” analysis methodology, the “Governance” pillar
notably covering issues such as balance of powers, fair remuneration and business ethics.
• An indicator derived from LFDE’s internal qualitative analysis. The analysis covers, among other things, issues
related to the competence of the management team, the existence of effective counter-powers, diversity on the
Good governance practices
board, respect of minority shareholders and the assessment of extra-financial risks.
include sound management
structures, employee An issuer is deemed to have applied the principles of good governance when this is demonstrated by one of the
relations, remuneration of two aforementioned indicators.
staff and tax compliance.
The financial product invests at least 90% of its assets in assets considered “eligible” according to the ESG process
implemented - therefore in investments that are aligned with the environmental and social characteristics promoted
(#1 Aligned with E/S characteristics).
Up to 10% of investments are not aligned with these characteristics (#2 Other).
The financial product invests at least 10% of its assets in assets considered to be sustainable investments (#1A
Sustainable).
A more detailed description of the specific asset allocation of this financial product can be found in its prospectus.
The derivatives used by the financial product are not intended to contribute to achieving the environmental or social
characteristics promoted. Their use is limited to hedging or temporary exposure in order to cover a strong
movement in liabilities, to gain temporary exposure to market beta or to accompany a change in strategy.
Furthermore, the Management Company ensures that the use of derivatives does not run counter to the
To comply with the EU environmental or social characteristics promoted by the financial product. In particular, the Management Company
taxonomy, the criteria for does not use derivatives to artificially improve the product’s extra-financial performance. The constraints relating to
fossil gas include limitations the use of derivatives are specified in the pre-contractual documentation for the financial product.
on emissions and switching
to renewable power or low- To what minimum extent are sustainable investments with an environmental objective
carbon fuels by the end of aligned with the EU Taxonomy?
2035. For nuclear energy,
the criteria include
The financial product may invest in environmentally sustainable economic activities, however the investments of
comprehensive safety and
this financial product do not take into account the European Union criteria for environmentally sustainable economic
waste management rules. activities. The financial product is committed to a 0% alignment with the European Taxonomy
Taxonomy-aligned:
Taxonomy-aligned:
Fossil gas
Fossil gas
Taxonomy-aligned:
Taxonomy-aligned:
Nuclear
Nuclear
Taxonomy-aligned (no
Taxonomy-aligned (no
fossil gas & nuclear)
fossil gas & nuclear)
Non Taxonomy-aligned
Non Taxonomy-aligned
are sustainable
This graph represents 100% of total investments.
investments with an
environmental * For the purpose of these graphs, “sovereign bonds” consist of all sovereign exposures.
objective that do not
take into account ⚪ What is the minimum share of investments in transitional and enabling activities?
the criteria for
environmentally The financial product does not commit to a minimum proportion of investment in transitional and enabling activities.
sustainable
economic activities What is the minimum share of sustainable investments with an environmental objective that are not
under the EU aligned with the EU Taxonomy?
taxonomy.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with an environmental objective that are not aligned with the
EU Taxonomy is 1%.
This product intends to invest part of its assets in sustainable investments. These investments may contribute to
environmental or social objectives, without any commitment being made as to the minimum share of each one.
Thus, the minimum share of sustainable investments with a social objective is 1%.
(1) Fossil gas and nuclear activities will only be aligned with the EU Taxonomy if they contribute to limiting climate change (“climate change mitigation”) and do not cause significant harm to any other EU Taxonomy
objective - see explanatory note in the left margin. All criteria applicable to economic activities in the fossil gas and nuclear energy sectors that comply with the EU Taxonomy are defined in Commission
Delegated Regulation (EU) 2022/1214.
ECHIQUIER SPACE - Annexe SFDR article 8 6
What investments are included under “#2 Other”, what is their purpose and are there any minimum
environmental or social safeguards?
Investments included in the category “#2 Other” of the financial product represent up to 10% of investments.
Depending on the eligible instruments as defined in the product’s prospectus, these may include derivatives traded
on regulated or organised markets to expose and hedge the portfolio, cash and unrated issuers.
Derivatives and cash do not provide environmental or social safeguards.
Is a specific index designated as a reference benchmark to determine whether this financial product is
aligned with the environmental and/or social characteristics that it promotes?
Not applicable
⚪ How does the designated index differ from a relevant broad market index?
Not applicable
⚪ Where can the methodology used for the calculation of the designated index be found?
Not applicable
More information about the Management Company’s extra-financial approach can be obtained through the
documents available on its website (https://www.lfde.com), in the “Responsible Investment” section, on the “To find
out more” page, under “LFDE Documents - SFDR”.
Additional information about the fund, in particular its regulatory documentation, is available on the Management
Company’s website (www.lfde.com), under the “Our Funds” section.
good governance practices. considered environmentally sustainable considered environmentally sustainable under the EU taxonomy
under the EU taxonomy
☐ with an environmental objective in economic activities that are
☐
The EU taxonomy is a
classification system in economic activities that are not not considered environmentally sustainable under the EU
established by Regulation (EU) considered environmentally sustainable taxonomy
2020/852, which under the EU taxonomy
listsenvironmentally ☐ with a social objective
sustainable economic
activities. That Regulation
does not include a list of
☐ It will make a minimum ofsustainable ☒ It promotes E/S characteristics, but will not make any sustainable
The responsible investment strategy is based on ESG criteria highlighting the environmental and/or social
Sustainability indicators characteristics promoted by this financial product, such as a reduction in the environmental impact of companies in
measure how the terms of air pollution, preserving biodiversity, companies taking environmental risks into account or an improvement
environmental or social in working conditions, the protection of employees, the fight against discrimination, etc.
characteristics promoted by
the financial product are ⚪ What sustainability indicators are used to measure the achievement of each of the environmental or
attained. social characteristics promoted by the financial product?
The contribution to one of the aforementioned environmental and social objectives is assessed using various
sources, including:
For all environmental and social objectives:
- The “GREaT” score, the proprietary quantitative analysis methodology of the LBP AM Group, which covers all
environmental and social objectives,
- The “SDG” score, a proprietary qualitative analysis of LFDE that assesses companies’ products, services and
practices with a view to measuring their contribution to achieving the United Nations Sustainable Development
Goals (SDGs).
For objectives specific to climate and biodiversity:
- The issuer’s commitment to a decarbonisation trajectory in its activities compatible with the objectives of the Paris
Agreement, according to criteria defined by the Management Company,
- The “Greenfin” score, a quantitative indicator measuring the exposure of the business model of an issuer
to green activities as defined by the French government label Greenfin, dedicated to financing the energy
and ecological transition,
- The “Bird” score, a proprietary quantitative indicator of the LBP AM Group that aims to assess companies
primarily on their policies as well as on their practices and impacts related to biodiversity,
- The “Climate & Biodiversity Maturity” score, a proprietary qualitative analysis of LFDE that aims to assess the
maturity of companies in their consideration of the current and future climate and biodiversity issues they face.
Additional information about the various scores is available in the “SFDR – Sustainable Investment Methodology”
document available on the Management Company’s website (https://www.lfde.com), in the “Responsible
Investment” section, on the “To find out more” page, under “LFDE Documents - SFDR”.
⚪ What are the objectives of sustainable investments that the financial product intends to pursue in
particular, and how do the investments made contribute to these objectives?
Not applicable, the financial product is not committed to having a minimum amount of sustainable investment.
⚪ To what extent do the sustainable investments that the financial product partially intends to make not
cause significant harm to an environmental or social sustainable investment objective?
Not applicable, the financial product is not committed to having a minimum amount of sustainable investment.
Does this financial product take into account the main negative impacts on sustainability factors?
☒ Yes
☐ No
Regarding the adverse impacts, this financial product takes into account 14 mandatory indicators from Table 1 of
Annex I of European Commission Delegated Regulation (EU) 2022/1288, and also includes the following two
additional indicators:
Additional information about how the principal adverse impacts are taken into account is available in the document
“Article 4 SFDR: Principal adverse impacts” accessible on the Management Company’s website (https://
www.lfde.com), in the “Responsible Investment” section, on the “To find out more” page, under “LFDE Documents -
SFDR”.
The financial product implements a financial strategy focused on investing in the Indian equity markets, including all
sectors and sizes. It also systematically integrates an extra-financial approach without this being a determining
factor in investment decisions
- the Management Company's exclusion policy and the resulting sectoral or norm-based exclusion constraints,
- the constraints associated with the sustainability indicators defined above; the thresholds applied for each
indicator are available in the “SFDR – Sustainable Investment Methodology” document accessible on the
Management Company’s website (https://www.lfde.com), in the “Responsible Investment” section, on the “To find
out more” page, under “LFDE Documents - SFDR”
⚪ What is the minimum proportion by which the financial product undertakes to reduce its investment
scope before applying this investment strategy?
The implementation of sectoral and norm-based exclusion filters and a binding ESG score make it possible to
reduce the investment universe.
⚪ What is the policy implemented to assess the good governance practices of the companies in which the
financial product invests?
Good governance
practices include sound
The monitoring of the application of good governance principles by issuers is controlled through two indicators:
management structures, • A quantitative indicator derived from the proprietary “GREaT” analysis methodology, the “Governance” pillar,
employee relations, which covers issues such as balance of powers, fair remuneration and business ethics.
remuneration of staff and tax • An indicator derived from LFDE’s internal qualitative analysis. The analysis covers, among other things, issues
compliance. related to the competence of the management team, the existence of effective counter-powers, diversity on the
board, respect of minority shareholders and the assessment of extra-financial risks.
An issuer is deemed to have applied the principles of good governance when this is demonstrated by one of the
two aforementioned indicators.
The financial product invests at least 80% of its assets in assets considered “eligible” according to the ESG process
implemented - therefore in investments that are aligned with the environmental and social characteristics promoted
(#1 Aligned with E/S characteristics).
Up to 20% of investments are not aligned with these characteristics (#2 Other).
The financial product invests at least 0% of its assets in assets considered to be sustainable investments (#1A
Sustainable).
A more detailed description of the specific asset allocation of this financial product can be found in its prospectus.
Not applicable
To what minimum extent are sustainable investments with an environmental objective aligned with the EU
taxonomy?
Not applicable, this financial product is likely to invest in sustainable investments, but there is no commitment to a
minimum percentage of sustainable investment.
To comply with the EU ⚪ Does the financial product invest in fossil gas and/or nuclear energy related activities that comply with
taxonomy, the criteria for the EU taxonomy?
☐
fossil gas include limitations
Yes
on emissions and switching
to renewable power or low- ☐ In fossil gas
carbon fuels by the end of ☐ In nuclear energy
2035. For nuclear energy, ☒ No
the criteria include
comprehensive safety and The two graphs below show in green the minimum percentage of investments aligned with the EU
waste management rules. taxonomy. As there is no appropriate methodology to determine the taxonomy-alignment of sovereign
bonds*, the first graph shows the taxonomy alignment in relation to all the investments of the financial
Enabling activities directly
product, including sovereign bonds, while the second graph shows the taxonomy alignment only in
enable other activities to
relation to the investments of the financial product other than sovereign bonds.
make a substantial
contribution to achieving an
environmental objective.
* For the purpose of these graphs, “sovereign bonds” consist of all sovereign exposures.
The financial product does not commit to a minimum proportion of investment in transitional and enabling activities.
The symbol
represents sustainable What is the minimum proportion of sustainable investments with an environmental objective that are not
investments with an aligned with the EU taxonomy?
environmental objective that
do not take into account Not applicable, this financial product is likely to invest in sustainable investments, but there is no commitment to a
the criteria applicable to minimum percentage of sustainable investment.
environmentally sustainable
What is the minimum proportion of socially sustainable investments?
economic activities under the
EU taxonomy.
Not applicable, this financial product is likely to invest in sustainable investments, but there is no commitment to a
minimum percentage of sustainable investment.
What investments are included in the “#2 Others” category, what is their purpose and do minimum
environmental or social guarantees apply to them?
Investments included in the category "#2 Other" of the financial product represent up to 20% of investments and are
derivatives traded on regulated or organised markets to expose and hedge the portfolio, cash and unrated issuers.
Derivatives and cash do not provide environmental or social safeguards.
Not applicable
⚪ How is the benchmark constantly aligned with each of the environmental or social characteristics
promoted by the financial product?
The benchmark indices are
indices used to measure
Not applicable
whether the financial product
achieves the environmental
⚪ How is the alignment of the investment strategy with the index methodology guaranteed at all times?
or social characteristics it
promotes. Not applicable
⚪ How does the designated index differ from a comparable broad market index?
Not applicable
⚪ Where can I find the method used to calculate the designated index?
Not applicable
More information about the Management Company’s extra-financial approach can be obtained through the
documents available on its website (https://www.lfde.com), in the “Responsible Investment” section, on the “To find
out more” page, under “LFDE Documents - SFDR”. Additional information about the fund, in particular its regulatory
documentation, is available on the Management Company’s website (www.lfde.com), under the “Our Funds”
section.