COMPLAINT MANAGEMENT
In accordance with the applicable regulations, PICTURE Asset Management has established and maintains an operational procedure designed to manage complaints from its clients quickly, effectively and transparently.
Any client or holder wishing to make a complaint to PICTURE Asset Management is invited to send a letter to the following address: PICTURE Asset Management – 59 Rue de Châteaudun – 75009 Paris
Complaints can also be sent to PICTURE Asset Management by email at the following address: contact@picture-realestate.com. The client or holder is asked to provide their contact details (postal address, email address, telephone number).
PICTURE Asset Management undertakes to acknowledge receipt of the complaint within ten working days of receipt of the complaint, unless the response itself is provided to the client within this period, and to respond to the client within two months of receipt of the complaint, unless specific circumstances arise and are duly justified.
If you are dissatisfied with the response to your complaint, you are invited to contact the mediator of the French Financial Markets Authority (AMF) at the following address:
Autorité des Marchés Financiers AMF Mediator
17 Place de la Bourse 75082 Paris Cedex 02
The AMF mediation request form and the mediation charter are available on the website: www.amf-france.org under “mediation”. You can also submit a request using the electronic form on the AMF website.
POLICY ON MANAGING CONFLICTS OF INTEREST
PICTURE Asset Management has implemented a system for managing conflicts of interest in compliance with AMF regulations. Within this framework, PICTURE Asset Management has established and maintains an effective policy for managing conflicts of interest, which is laid out in writing and appropriate to its size, organisation, nature and scale, as well as the complexity of its business.
This policy ensures that conflicts of interest are prevented, identified and managed in order to avoid adversely affecting the interests of clients and unitholders, thereby avoiding any reputational risks for the company.
To ensure that any proven conflicts of interest are detected quickly and effectively, PICTURE Asset Management employees are informed of the preventive measures in place, the internal rules with which they must comply, and the tools and support available to assist them in their duty of vigilance.
The procedure for identifying and managing conflicts of interest aims to identify situations that may lead, or are likely to lead, to a conflict of interest, in order to find a solution that upholds the preeminence of clients and unitholders and protects their interests.
PICTURE Asset Management has identified potential conflicts of interest of a general nature, as well as specific conflicts of interest connected to the organisation and the activities carried out.
Where the measures adopted are not sufficient to guarantee with reasonable certainty that the risk of harm to clients’ interests will be avoided, PICTURE Asset Management will clearly inform their clients, before acting on their behalf, of the general nature or source of such conflicts of interest.
Finally, PICTURE Asset Management maintains and regularly updates a register of the types of investment or related services, or other activities carried out by it or on its behalf, for which a conflict of interest involving a material risk of harm to the interests of one or more of its clients has arisen or, in the case of an ongoing service or activity, is likely to arise
Available on request
REMUNERATION POLICY
The remuneration policy defines the terms and scope of the remuneration rules that are applicable to the Management Company’s employees and management bodies. Notably, it takes into account the size and activities of the Management Company.
The employees covered by this policy qualify as “identified staff” within the meaning of the AIFM Directive. Identified staff represent a category of employees whose professional activities have a significant impact on the risk profile of the Management Company or on the risk profiles of the AIFs it manages.
The Management Company may grant its employees two types of remuneration:
- fixed remuneration, which corresponds to the employee’s salary, regardless of the level of performance achieved;
- variable remuneration, which corresponds to additional payments and benefits awarded to an employee based on the performance they have achieved in the course of their duties.
The Management Company may not pay an employee variable remuneration exceeding the upper limit of 30% of the fixed remuneration or €200,000. Variable remuneration must be justified and based on the employee’s performance.
Sustainability risk integration (Article 5 of the SFDR)
In terms of sustainability, specific roles and responsibilities have been defined for certain internal PICTURE Asset Management departments that are involved in this area, and specific objectives have been set for the teams and employees, where relevant. Every year, the achievement of these objectives is assessed, much like other objectives, during the annual appraisal interviews, which are an important factor in determining the variable remuneration allocated to employees. This allocation remains a discretionary process, which is standard practice in PICTURE Asset Management’s Remuneration Policy.
Available on request
BEST SELECTION POLICY
In accordance with the current regulations resulting from the transposition of the MiFID Directive into French law, PICTURE Asset Management has defined – as part of its duty to act in the best interests of its clients and the vehicles it manages – a policy for the selection of financial intermediaries and counterparties with whom orders for financial instruments are placed.
In accordance with current regulations, information on PICTURE Asset Management’s remuneration policy is published each year in the regular AIF reports.
Available on request
VOTING POLICY
Pursuant to article 319-21 of the AMF General Regulation, Portfolio Management Companies must draw up a document entitled “Voting Policy”, which is updated as necessary, to lay out the conditions under which they intend to exercise the voting rights attached to the securities held by the AIF when they are traded on a regulated market of a state that is party to the European Economic Area Agreement, or on a recognised foreign market.
As PICTURE Asset Management’s current investment scope only includes unlisted property assets, the regulatory obligations relating to the implementation of a voting policy and associated due diligence are not applicable.
Although not subject to the above provisions, when, as a result of the investments made, the AIFs managed by PICTURE Asset Management have the status of partner, joint owner, co-owner or an equivalent status under foreign law, PICTURE Asset Management will ensure that it is able to exercise all the rights of the AIFs in the interests of the shareholders/holders.
In the event of a change in its investment scope, PICTURE Asset Management will update its voting policy accordingly.
Available on request
COMPLIANCE & INTERNAL CONTROL
The Compliance and Internal Control department implements appropriate operational procedures and controls.
In accordance with the provisions of the General Regulation of the AMF, Nicolas Beurton is the Compliance and Internal Control Officer (Responsable Conformité et Contrôle Interne/RCCI) and manager.
In accordance with Articles 321-31 and 321-32 of the AMF General Regulation and Article 61(3)(a) of Commission Delegated Regulation (EU) no. 231/2013 of 19 December 2012, as a manager, he has the independence, authority, resources and expertise necessary to carry out his duties effectively.
As he also plays an operational role (Company Secretary), the work relating to the RCCI role is in practice outsourced to a service provider under his responsibility.
Compliance control, permanent 2nd level control, and periodic control activities are delegated to an external service provider, AGAMA Conseil, which reports directly to the RCCI.