In accordance with Article L.533-10 of the Monetary and Financial Code, the management company must take all reasonable measures to prevent conflicts of interest from affecting the interests of its clients. If these measures are not sufficient to guarantee, with reasonable certainty, that the risk of harming the interests of the client will be avoided, EuroTitrisation must inform them clearly, before acting on their behalf, of the general nature or source of these conflicts.
The prevention of conflicts of interest passes through their identification as such. To this end, EuroTitrisation has put in place a cartography listing all the situations which, to its knowledge, are likely to present a risk of conflicts of interest. This mapping was done with regard to the activity and the size of the company.
In view of the potential conflict situations thus identified, EuroTitrisation has taken measures to prevent the appearance of conflicts of interest, by raising the awareness of all its staff of the rules and codes of good internal conduct and of place, and by the establishment of strict rules and procedures including:
- Setting up an internal control system,
- Independence of the management company vis-à-vis its shareholders,
- Separation of functions that can generate possible conflicts,
- Clear and precise definition of the characteristics of the securitised receivables and the investment policy,
- Clear and precise definition of the roles and responsibilities of each stakeholder,
- Policy of prevention and management of conflicts of interest,
- Clear and frequent information from investors,
- Opportunity to consult investors on certain decisions,
- Training or raising awareness among all staff of the best practices of the profession,
- Declaration of gifts and benefits offered or received at RCCI / Internal Control and Compliance Officer .
The management of conflicts of interest involves the obligation of all employees to declare situations, potential or apparent conflicts of interest of which they are aware. The Management Group is then in charge of handling the conflict thus identified and informing it in the register provided for this purpose.
If necessary, EuroTitrisation will inform the customers concerned by the conflict of interest thus identified.
For any further information on this conflict of interest management policy, please write to:
12 rue James Watt