Prevention policy and conflict of interest management

Aqua Asset Management has a policy for managing conflicts of interest which is operational and formalised in writing, to prevent, detect and, where necessary, deal equitably with conflicts of interest that may arise in the context of the provision of its services, between its own interests and those of its clients or between the interests of several clients.

Situations that may generate conflicts of interest include but are not limited to the following:

  • situations concerning the granting or accepting of benefits or gifts,
  • situations concerning the variable remuneration conditions of the management company,
  • situations concerning the existence of privileged relationships,
  • situations concerning the simultaneous performance of duties with diverging interests (management of mutual funds together with the management of own accounts by the same investment director, subscription in funds managed by the persons concerned)
  • situations concerning access to privileged information,
  • situations concerning financial dependence within the context of a contractual relationship.

As part of the implementation of provisions of the AMF General Regulations, Aqua Asset Management has identified situations that may reveal conflicts of interest, taking into account the size and organisation of the management company, and the nature and complexity of activities. Risk mapping for conflicts of interest is updated periodically, at least annually, to incorporate developments and changes in Aqua Asset Management’s activities.

Conflict of interest management is based on the fundamental principle of primacy of the clients’ interests. If there is no solution that complies with the principle stated above, Aqua Asset Management will refrain from carrying out the proposed operation.

The practical implementation of these principles is the responsibility of every employee, and managers of the management company under the control of the Head of Compliance and Internal Control (RCCI).

Conflict of interest management should be organised as follows:

  • The emergence of the conflict must be notified to the RCCI by the employee concerned,
  • The RCCI records the conflict that has occurred in a specific register,
  • The RCCI must propose a solution to deal with the conflict in the interest of unitholders.

If, despite the measures taken, a conflict of interest has been proved which might seriously undermine the interests of clients, Aqua Asset Management will notify affected clients. Clients will then make an informed decision on the provision of the investment service.

Policy for selecting financial intermediaries

Aqua Asset Management is committed to acting in the best interests of its clients to execute orders resulting from investment decisions on portfolios.

Aqua Asset Management therefore selects intermediaries whose execution policy ensures the best possible result when executing orders sent on behalf of its clients. Aqua Asset Management has formalised a policy for selecting financial intermediaries (brokers), with whom it negotiates listed financial investments. Intermediaries are selected primarily according to the criterion of total cost of the financial instrument (price of financial instrument + cost of execution), as well as on criteria such as reputation, quality of execution and responsiveness of their back office.

To maintain the quality of services offered, all intermediaries used are evaluated every six months on an Investment Committee by all investment directors of the management company.

Voting Policy

In accordance with the General Regulations of the Financial Markets Authority, the Aqua Asset Management’s investment directors, or any persons authorised under management, are responsible for analysing resolutions put forward at the General Meeting, on the decision to vote for the securities they hold in the portfolio.

ESG standards

Aqua Asset Management does not routinely and simultaneously incorporate environmental, social and quality of governance (ESG) criteria into its investment policy.

Handling complaints

For Aqua Asset Management, the principle of primacy of client interests is paramount. The management company has set up a client complaint management system that aims to treat all client complaints effectively, transparently and with the same degree of attention.

For any complaint, please contact us:

  • By letter sent to the following address: Aqua Asset Management - 6 square de l’Opéra Louis Jouvet - 75009 Paris
  • By email:

Aqua Asset Management will acknowledge your request within 10 business days of receipt of your complaint, and undertakes to respond to your request within one month of receiving your complaint. If, due to special circumstances, Aqua Asset Management is not able to comply with these deadlines, it will inform you of the reason for the delay.

If the content of the response is not to your satisfaction, you will be able, free of charge, to refer the matter to the AMF Ombudsman at the following address: Médiateur de l’AMF, Autorité des marchés financiers, 17 place de la Bourse, 75082 PARIS CEDEX 02 or by filling in the electronic form available on AMF website at /le médiateur

A mediation application form is available on the AMF website:

Regulatory information

Periodic regulatory information is available on request from Aqua Asset Management.

Risk factors

Whatever the solutions, investment in unlisted assets carries risks and constraints inherent to their characteristics.

The main risk factors affecting the investor are:

  • a risk of total loss of capital, inherent to any investment in equities.
  • a performance risk insofar as planned investments can yield highly variable results as they are dependent on multiple factors within financed companies, as well as external factors (market conditions in particular).
  • liquidity risk, insofar as the relevant securities are not listed on a regulated market. And by their nature, the investment horizon will still be long and cannot offer any predefined liquidity horizon.
  • risk relating to asset management and allocation. Fund performance depends both on the companies selected and the allocation of assets. There is a risk that the funds do not select the best performing securities and that the allocation between different markets is not optimal.

The list of risk factors indicated above is not exhaustive.

It is reminded that past performance is no guarantee of future performance and is not constant over time.