Our duties as an asset manager
Swing pricing: Protecting holders from fund dilution
Preamble: Fundamental principles adopted by Mirova
In order to better safeguard the interests of its long-term shareholders, Mirova has decided to introduce a swing pricing mechanism based on the methodology recommended by the French Asset Management Association's (AFG) charter.
The list below indicates the funds that swing pricing will be applied to. The swing pricing mechanism is triggered when a certain threshold (a percentage of the fund's net assets) is reached.
- Mirova Euro Green and Sustainable Bond Fund
- Mirova Euro Green and Sustainable Corporate Bond Fund
- Mirova Global Green Bond Fund
It is not guaranteed that a shareholder who purchases or redeems an amount below a fund's threshold will benefit from an unswung NAV. The swing pricing trigger is appreciated globally and takes all inflows/outflows (i.e. the net balance of the subscriptions/redemptions of all shareholders) into account.
Moreover, Mirova reserves the right to modify the swing pricing parameters at any time, especially during crisis situations.
An FAQ on the subject has been made available on Mirova’s website in order to respond to shareholders’ questions about how the mechanism will work and what it will impact. It applies to professional and non-professional clients in accordance with the the Markets in Financial Instruments Directive.
• The FAQ is available on Mirova’s website.
• The FAQ can also be requested from the Distribution Services Department by email at: ClientServicingAM@Natixis.com, or by mail at:
MIROVA - Ostrum Asset Management
Direction « des Services Clients à la Distribution »
43, avenue Pierre Mendès-France - 75013 Paris
Compensation Policy - Management Report Appendix
Mirova’s compensation policy was drafted in accordance with Directive 2011/61/EU (the Alternative Investment Fund Managers Directive) and Article L.533-22-2 of the French Monetary and Financial Code which applies to holding companies established on French territory which manage AIFs.
Mirova follows the ESMA and the AMF’s recommendations.
Mirova’s compensation policy also extends to all of the company’s activities (UCITS, AIFs and management mandates).
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Corruption is fraudulent, unethical behavior and is subject to heavy criminal and administrative sanctions. Violations of the anti-corruption regulations are serious and can damage Mirova’s reputation. Μirova does business with integrity in order to protect itself from all forms of influence and corruption, including the use of and acceptance of “bribes” in trade relations and the corruption of public officials.
Anti-Personnel Landmines And Cluster Munitions Exclusion Policy
In accordance with the treaties signed by the French government, the funds directly managed by Mirova do not invest in companies that manufacture, sell, or stock anti-personnel mines and cluster bombs.
Policy for processing complaints
General Information and Principles
MIROVA has put in place a complaint processing system in order to handle its clients’ complaints in an efficient, transparent, and uniform manner, in accordance with applicable regulations.
Access to this service is free of charge and clients can submit complaints (i) in French, or (ii) in one of the official languages of the country where the UCITS was marketed or where the service was provided.
Definition of a complaint
A complaint is a statement of a client’s dissatisfaction with a professional service. Requests for additional information, advice, clarifications, and services are not complaints.
Questions and complaints may include, but are not limited to topics such as: portfolio management, portfolio performance, pricing aspects, legal documentation, and any elements related to the service provided.
Processing complaints at MIROVA
Complaints can be made by mail, phone, or email. They can also be made directly, through the client’s usual contact.
Complaints sent by mail should be addressed to:
Direction du service client NIMI
43, avenue Pierre Mendès-France
Complaints made by telephone are recorded by the client support personnel. Clients who are part of the Caisse d’Epargne and Banque Populaire networks can submit their complaints:
- By email at: Relation-Clients-Reseaux@natixis.com
All other clients can submit their complaints:
- By email at: ClientServicingAM@natixis.com
- acknowledge receipt of all complaints it receives within a maximum period of 10 days, except in cases where a response can be sent within that period,
- respond to complaints within a maximum period of 2 months starting from the date of their receipt,
- in the event that these conditions cannot be met, Mirova will inform the client of the progress of their complaint and the cause of the delay.
Mediation by the Autorité des Marchés Financiers (AMF)
The AMF’s Ombudsman’s services may be called upon by any interested party (whether a natural or legal person) in the context of an individual dispute regarding financial investments.
You can contact the AMF’s Ombudsman by mail at:
Médiateur de l’AMF
Autorité des marchés financiers
17, place de la Bourse
75082 PARIS CEDEX 02
A form to request mediation is available online on the AMF’s website (www.amf-france.org).
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Policy for withholding tax
Claim policy for reimbursement of foreign withholding tax for CIUs managed by MIROVA - September 2014
French or Luxembourg CIUs may receive dividends net of withholding tax on foreign shares held. In some cases, the withholding tax rate applied to dividends received by French or Luxembourg CIUs may differ from that applied to dividends paid to CIUs located in the same country as the asset’s issuer.
In certain European Union countries, following the Court of Justice of the European Union’s judgment on May 10, 2012, these circumstances make it possible to file a claim with the competent authorities in order to be reimbursed for this rate difference.
In such cases, our policy is to file claims on behalf of the managed CIU, in the interests of the investors, if the conditions, such as the likelihood of recovery, the time necessary, and the cost, seem favorable to investors. This allows for materiality thresholds to be determined.
It should be noted, however, that this claim policy involves contingencies in terms of actual and final reimbursement amounts and deadlines. CIUs may have to bear external costs without receiving the expected reimbursements. Expenses incurred and reimbursements received under this policy will be reported in the CIUs Annual Reports.
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The Markets in Financial Instruments Directive (MiFID) entered into effect on Nov. 1, 2007. It is a legislative and regulatory framework designed to:
- harmonize the regulations which apply to providers of investment services;
- promote competition in order to ensure the best possible results when clients’ orders are executed; and
- strengthen investor protections.
Process for selecting service providers
The regulatory framework laid out by the Autorité des Marchés Financiers (AMF) to govern management companies’ usage of investment decision support and order execution services has evolved. These decision support services may include the production of financial analyses.
In view of this new regulatory framework, the selection policy for Mirova’s decision support service providers includes several elements:
- it formalizes the eligibility criteria for the service providers;
- it presents the criteria used by the management teams to assess the quality of the services provided and the financial analyses produced;
- it lays out the appeal process for the shared commissions mechanism which Mirova has put implemented.
Order execution policy
Mirova’s order execution policy explains the overall organization of the company and the basic principles concerning:
- selecting intermediaries and counterparties
- the review mechanisms used to ensure the best possible outcome for clients.
Preventing conflicts of interest
A conflict of interest is defined as a situation in which MIROVA, or one of its associates or representatives, acts in a way that could, if appropriate precautions are not taken, adversely affect clients’ interests.
At Mirova, identifying, preventing, and managing risks of conflicts of interest follows the process described in the document below.
Information on compensation, commissions, and benefits
The AMF’s (Autorité des Marchés Financiers) general regulations govern the compensation, commissions, and non-monetary benefits (the “benefits”) that Mirova, as an investment service provider, may pay and collect in connection with the investment services it provides.
A “benefit” is a type of compensation that a client can accept indirectly for services provided by an investment service provider.
Mirova informs its clients and prospective clients that it is likely to:
- receive “benefits” from third-party management companies for making their UCITSs available to clients;
- receive “benefits” from shared commission contracts related to investment decisions and the execution of orders (see report on intermediation costs);
- offer “benefits” to third-party management companies
- for making Mirova’s UCITSs available to their clients.
- to pay business providers and advisors “benefits” in return for referring clients or giving advice.
These “benefits” may be either a fixed sum or a percentage of Mirova or the third party’s earnings. Further details will be provided to clients and prospective clients upon request.