Best Selection and Execution Policy

Best Selection and Execution Policy

Conflicts of Interests Policy

In accordance with regulation, Eleva Capital has established a conflicts of interest policy to ensure that the Firm takes all reasonable measures necessary to prevent, detect and resolve conflicts of interest arising during the course of providing its business activities.

As a result of its size and the nature of its activities, a mapping of conflicts of interest has been drawn up. This mapping identifies the circumstances that give rise or may give rise to a conflict of interest.

This makes it possible for Eleva Capital to identify and, if necessary, fairly manage any conflicts of interest that may arise in the course of carrying out its services, between its own interests and those of its clients or between the interests of a number of clients.

In cases where Eleva Capital would consider that the deployed measures are not sufficient to guaranty, with a reasonable certainty that the risk of prejudice for its clients can be avoided, the company would inform in writing the affected customers about the nature or the source of the conflict of interests in order for these clients to be able to take their decision knowingly.

Additional information on our Conflicts of Interest Policy can be obtained upon request by Email to: info@elevacapital.com

In accordance with regulation, Eleva Capital has established a conflicts of interest policy to ensurethat the Firm takes all reasonable measures necessary to prevent, detect and resolve conflicts ofinterest arising during the course of providing its business activities.As a result of its size and the nature of its activities, a mapping of conflicts of interest has beendrawn up. This mapping identifies the circumstances that give rise or may give rise to a conflict ofinterest.This makes it possible for Eleva Capital to identify and, if necessary, fairly manage any conflicts ofinterest that may arise in the course of carrying out its services, between its own interests and thoseof its clients or between the interests of a number of clients.In cases where Eleva Capital would consider that the deployed measures are not sufficient toguaranty, with a reasonable certainty that the risk of prejudice for its clients can be avoided, thecompany would inform in writing the affected customers about the nature or the source of theconflict of interests in order for these clients to be able to take their decision knowingly.Additional information on our Conflicts of Interest Policy can be obtained upon request by Email to:info@elevacapital.com.

Conflicts of Interest Policy 

ELEVA Voting and Engagement Policy

ELEVA Capital Voting and Engagement policy  (the Policy) includes:

  • Exercise of Voting Rights Policy
  • Shareholder Engagement Policy
     

In accordance with regulation, ELEVA Capital has established and maintains an active process in governing its engagement and voting policies.

Under the provisions of the Policy, ELEVA Capital is committed to act in the best interests of its clients and to follow the established engagement and voting principles.

In some exceptional cases, we might abstain from voting proxies or engagement actions when it is determined that the cost of an operation highly exceeds its expected benefit to our clients or where voting or engagement would entail locking up securities for a long period, thereby restricting our freedom to act.

Generally, all proxies are evaluated and voted on a case-by-case basis, considering each of the relevant principles set in the Policy. ELEVA Capital, in all cases, will engage on the matters and will vote for the proposals that are believed to be most advantageous to our clients.

- Voting and Engagement Policy

Customer complaints management

Eleva Capital, in accordance with the regulation, has implemented and maintains an operational procedure to quickly and efficiently process complaints made by its clients. Any complaint may be referred to info@finos.ch or by regular mail at the following address: Finanzombudsstelle Schweiz (Finos) Talstrasse 20, 8001 Zürich, or by phone at +41-44 552 08 00. Finos will acknowledge receipt of the complaint within a maximum of ten working days from the date it was received, unless a response has been issued to the client in the intervening period. Except in duly justified exceptional circumstances, a response will be issued to the client within two months of receipt of the complaint. In the event of an ongoing dispute, the client may contact the AMF Ombudsman at the following address: Autorité des marchés financiers Médiateur de l'AMF 17 Place de la Bourse 75082 PARIS CEDEX 02 The AMF mediation request form and the Mediation Charter are available on the AMF website: - Mediation Charter - AMF mediation request form

Compensation Policy

In accordance with the UCITS Directive, Eleva Capital has implemented a Remuneration Policy compatible with sound and effective risk management applicable to categories of personnel whose professional activities have a material impact on the Risk profile of the UCITS it manages. This policy is available by clicking on the link below :

- Eleva Capital : Remuneration Policy

2022 Report on intermediary fees

In accordance with the article 321-122 of AMF Rulebook, when the management company uses Third Party Investment decision services, and when intermediary fees for the previous financial year are above EUR 500.000, a Report on intermediary fees should be issued and disclosed to investors.

a) Use of Third Party Investment decision services in 2022

Eleva Capital uses regularly Third Party Investment decision services which have been remunerated under commission sharing agreements.

b) Percentage of fees paid to third parties in 2022 under commission sharing agreements

The fees paid to third parties for investment decision services under commission sharing agreements represented 32.7% of all fees, of intermediary fees paid in 2022 on equities.

c) Breakdown on intermediary fees between order execution and investment decision support

Intermediary fees for receiving and sending and for executing orders : 67.3%

Intermediary fees for order execution and investment decision support : 32.7%

This breakdown covers assets traded and held in funds.

d) Measures taken to prevent or deal with potential conflicts of interest when selecting service providers

The selection of service providers and their assessment is duly governed by the best selection policy and the conflict of interest policy.

RTS28 Reporting

RTS28 Reporting