Best Selection and Execution Policy

All investment service providers should act in the best interest of their clients when executing orders resulting from investment decisions related to portfolio management.

To this end, in its capacity as an investment manager, Eleva Capital is required to take all reasonable measures to select the intermediaries to which orders are transmitted for execution (brokers and financial counterparties) and whose execution policies guarantee the best possible result when executing orders sent on behalf of the Funds it manages.

In accordance with regulation, Eleva Capital has put in place an Execution Policy. We aim to consistently deliver Best Execution, by executing transactions at the most favourable terms for our clients, after evaluating various execution factors. 

Subject to any specific instructions that may be given by clients, when executing orders, we take all reasonable steps to obtain the best possible result taking into account the Execution Factors listed below. We determine the relative importance of these Execution Factors by using our commercial judgment and experience in light of market information available and taking into account our Execution Criteria.

  • Price (generally the most significant factor);
  • Size and nature of the order;
  • Potential market impact;
  • Cost of execution commissions;
  • Speed at which we can trade
  • Liquidity of the market on which we are trading;
  • Likelihood of execution and settlement;
  • Financial status and responsibility of the counterparty.

Eleva Capital selects counterparties who can deliver Best Execution on the trading venues to which we require access. We constantly monitor the performance of these counterparties, and formally evaluate them every six months. This formal review is based on performance in four key areas:

  • Understanding our execution objectives and helping us to reach them.
  • Providing timely market information which adds value to our execution performance.
  • Sourcing or providing liquidity.
  • Adding long-term value to our execution process beyond day-to-day trading (for example advising us regarding regulatory or technological developments).

We also evaluate our counterparties for post-trade efficiency, from the confirmation of trades to settlement. Poor performance in these areas could lead us to suspend trading with them until renewed satisfactory performance can be guaranteed.

The list of key trading counterparties with whom we transact is maintained by the Head of Trading at Eleva Capital and is available to our clients on request. Any new brokers must be approved by Eleva’s Chief Compliance Officer (“CCO”) and added to the list of approved brokers before we can place a trade with them.

Both the Best Selection and Execution Policy are available upon request by Email to: info@elevacapital.com

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 Interests Policy

ELEVA Voting and Engagement Policy

Active Ownership Policy

ELEVA Capital Active Ownership 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.

 

Conflicts of interest prevention

ELEVA Internal Code of Ethics and Conflict of interests’ Policy define, for all employees, the cases where a conflict of interest situation may arise.

In accordance with Article 321-133 of the RG AMF a voting and engagement report is published once a year along with the full version of the Policy; these documents are also available upon request by Email to: info@elevacapital.com

 

ELEVA 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@elevacapital.com or by regular mail at the following address: Eleva Capital SAS Attn. RCCI 32 rue de Monceau 75008 Paris Eleva Capital 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

Integration of ESG criteria

In accordance with article L.533-22-1 of the French “Code Monétaire et Financier”, Eleva Capital shall inform investors of the integration of Social, Environmental and Corporate Governance criteria within the investment policy of the company.

As a signatory of the UN Principles for Responsible Investment, the Firm commits to integrating ESG criteria in the investment process. Although the Firm does not manage any dedicated E.S.G Funds the investment team use ESG research by Sustainalytics, RepRisk and others for detailed analysis on issuers’ corporate governance as well as social and environmental risks and opportunities as part of the investment process. ELEVA Capital's commitment to ESG Integration is also reflected in its Active Ownership policy (Engagement and Voting).

The report of ELEVA Capital in response to the requirements of Article 173-VI of the French Law on Energy Transition for Green Growth is available by clicking on the link below:

- ELEVA Capital: ESG information and Carbon Footprints related to our investment managements activities.

Integration of ESG criteria

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 can be made available upon request by Email to info@elevacapital.com

2019 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 2019

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 2019 under commission sharing agreements

The fees paid to third parties for investment decisison services under commission sharing agreements represented 15,81% of intermediary fees paid in 2019 on equities.

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

Intermediary fees for receiving and sending and for executing orders : 70.5%

Intermediary fees for order execution and investment decision support : 29.5%

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.