Armen’s remuneration policy complies with regulations, in particular Directive 2011/61/EU on alternative investment fund managers (the AIFM Directive). Member States shall require AIFMs to have remuneration policies and practices for those categories of staff, including senior management, risk takers, those performing control functions, and any employees receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers, whose professional activities have a material impact on the risk profiles of the AIFMs or of the AIFs they manage, that are consistent with and promote sound and effective risk management and do not encourage risk-taking which is inconsistent with the risk profiles, rules or instruments of incorporation of the AIFs they manage.
Armen therefore observes its transparency requirements in the annual reports on the AIFs it manages, by providing the following details: the qualitative and quantitative criteria on which its remuneration policy is based; The number of beneficiaries; The total amount of annual gross fixed and variable remuneration over the year; The amount of annual gross variable remuneration over the year paid to staff members whose activities have a material impact on the risk profiles of the AIFs they manage.
Armen also observes its transparency requirements in the company’s annual reports, by providing the following details: the number of beneficiaries; The total amount of annual gross fixed and variable remuneration over the year.
Armen has a procedure for handling any complaints made by its clients reasonably and rapidly, involving a mechanism that allows it to process investor complaints in a fair and standardized manner. As per AMF instruction n°2012-07, a complaint is a statement declaring the client’s dissatisfaction with the asset management company. A request for information, notices, clarification, service or performance is not a complaint.
Any complaint must be sent by post to Armen for the attention of Renaud Tourmente at 6, Place de la Madeleine – 75008 Paris France. The company can also be contacted by email at the address rtourmente@armen.eu. Armen undertakes to handle complaints within eight working days from receipt, free of charge. However, if Armen is unable to handle the complaint within this time-frame, it will send acknowledgement of receipt within eight working days from receipt and handle the complaint within at most two months, except in the event of special circumstances duly justified, between the date the complaint is received and the date it sends its reply to the client.
Armen records complaints received in a log, applies official procedures to follow up and resolve incidents, and takes corrective measures if an irregularity has been identified.
If a complaint is rejected or not resolved in full or in part, the person may submit the case to the AMF ombudsman. The AMF ombudsman is the relevant mediator for any disputes concerning a financial instrument, investment service or, more generally, any matter falling within the AMF’s jurisdiction. It is the relevant public mediator, within the meaning of paragraph 7 of article L. 611-1 of the French Consumer Code, if a dispute arises between a financial professional (asset management company) and a consumer, that is a natural person acting for a purpose that does not fall within the domain of their commercial, industrial, self-employed or agricultural activity.
All consumers have the right to refer, free of charge, to a consumer ombudsman within the meaning of Title I of Book VI of the French Consumer Code. The AMF ombudsman can also handle a dispute that falls within the AMF’s jurisdiction if the dispute concerns a financial professional (asset management company) and a client who is a legal person or natural person acting for a purpose that falls within the domain of their commercial, industrial, self-employed or agricultural activity, as a saver or investor.
The client can submit a complaint to the AMF ombudsman:
Therefore, in the course of managing its funds, Armen takes all reasonable steps to detect potential conflicts of interest:
Such conflicts may include any of the following situations:
Armen upholds and applies provisions with a view to taking all reasonable steps to detect, avoid, manage and monitor conflicts of interest in order to prevent them from compromising the interests of its funds and investors in these funds. For this purpose, Armen maps potential conflicts of interest, updates the map regularly and keeps a list of all the cases that have arisen and how they were resolved.
In addition, if it cannot with any reasonable degree of certainty rule out the risk of compromising the interests of investors in its funds, Armen will inform these investors clearly, before taking any action on their behalf, of the general nature or cause of these conflicts of interest, and establish appropriate policies and procedures.
Note that Armen has a compliance and internal control department that controls its activities independently and is responsible for ensuring that the policy for managing conflicts of interest is up to date and applied. Employees may inform the Head of Compliance and Internal Control of any potential or proven conflicts of interest.