FUND MANAGEMENT AVOIDING ANY CONFLICT OF INTEREST
A Compliance Officer monitors employees' financial transactions and ensures that no conflict of interests exists due to the structure of the company and the measures adopted to ensure compliance with the good market conduct rules.
Twice a year an ad hoc committee examines the accuracy of intermediary ratings, issues a list of accreditations and assigns market share to them, which is monitored weekly by Internal Control.
All Covéa Finance employees sign an ethics commitment through which they undertake:
- to notify the Compliance Officer of their personal financial transactions,
- not to receive any benefit or remuneration likely to give rise to any conflict of interest,
- to comply with professional secrecy and refrain from using any privileged information,
- not to obstruct existing timestamping and telephone recording procedures.
ONGOING FIGHT AGAINST MONEY LAUNDERING
The latest version of the anti-money laundering procedures is made available to all of company employees.
A Tracfin correspondent centralises any internal suspicions in order to transfer them to Central Group Control, which is responsible for formal notification in accordance with legislation.
At the same time, and before any new relationship, the Company Secretary's office ensures proper understanding of all third parties (intermediaries, clients and partners) and ensures that they undertake to implement and comply with anti-money laundering mechanisms.
PERMANENT INTERNAL CONTROL SYSTEM
The control system, formally documented in the Covéa Finance Internal Control Charter, specifically includes:
- a permanent control function covering all the asset management company's business,
- a periodic control function provided by a special independent structure.
An initial level of control consists of permanent operational supervision carried out as part of transaction processing. It covers the processing and administration of intra-day transactions and the successful completion of transactions, including verification that they are correctly integrated into the accounting and end-of-day synopsis systems. Level 1 controls are carried out on a daily basis by all Covéa Finance employees.
Level 2 consists of controls not integrated within the "production processes", i.e. carried out subsequently and periodically or randomly by Internal Control, which does not have any operational involvement. Such checks represent fundamental controls of content and form, enabling compliance of the process to be checked against a transaction or a case file, and providing specific monitoring of the various associated risks.
DESCRIPTION OF THE INFORMATION SYSTEM
The main functionalities of the information system are designed to provide decision-making support for financial management activities while guaranteeing transaction security. To this end, Covéa Finance took the decision to procure systems recognised as benchmark products.
The degree of integration of information system components ensures the fluidity and traceability of financial transactions, from front to back, via tools for tracking positions and the placing of orders, through decision-making support services and a reporting suite dedicated to performance measurement and risk control.