Principal Owners
HSBC Global Asset Management (France) is around 93% directly owned by HSBC FRANCE, and indirectly owned 100% by HSBC Holdings plc (HSBC Group). HSBC Holdings Plc. is a publicly owned corporation based in London, UK, and trades on various stock exchanges around the world. HSBC Global Asset Management (France) is incorporated in France and was created in 1998.

On 30th of June 2011, HSBC Global Asset Management (France) merged with Sinopia Asset Management and succeeded to its advisory business.

Types of Advisory Services

HSBC Global Asset Management (France) provides investment advisory services which include fixed income, inflation, and currency based strategies. Clients may sign investment advisory agreements directly with HSBC Global Asset Management (France). HSBC Global Asset Management (France) may also provide investment advisory services through sub- advisory agreements with various affiliated companies and/or third parties.

Internationally, HSBC Global Asset Management (France) may manage accounts pursuant to sub-advisory agreements with affiliated entities whereby the affiliated entity manages funds in the geographic regions or area of specialty closest to the market within an investment mandate. In these relationships HSBC Global Asset Management (France) provides investment advisory services to clients who sign an Investment Advisory Agreement directly with HSBC Global Asset Management (France), or may act as sub-adviser for clients who sign Investment Advisory Agreements with other affiliated companies.

HSBC Global Asset Management (France) can delegate investment management responsibilities, through sub-advisory agreements, to other affiliated companies and vice versa. The client service relationship is generally maintained in the country where the client is located. HSBC Global Asset Management (France) does not currently offer its strategies to US clients.
Investment Restrictions
HSBC Global Asset Management (France) provides investment advisory services in accordance with the investment objectives, guidelines and restrictions agreed upon in advance with the client. Where HSBC Global Asset Management (France) is a sub-advisor to a mandate or an affiliate is a sub-advisor to a HSBC Global Asset Management (France) mandate, the responsibility of the investment manager is generally limited to the portion of the assets of the account under its management through the sub-advised agreement. Investment objectives and guidelines may be amended as agreed by both the client and HSBC Global Asset Management (France) from time to time. Wrap Fee Programs HSBC Global Asset Management (France) does not participate in any Wrap Fee Programs.
Assets Under Management
As of 31st of December 2019, the total assets under management for HSBC Global Asset Management (France), including US based and non-US based clients, were USD 78,373,074,787.

FEES AND COMPENSATION

Fee Schedules
Fees are generally charged and collected in accordance with the investment advisory agreement with the client.

There is currently no HSBC Global Asset Management (France)’ products offered to US clients.

Deduction of Fees Generally, unless otherwise specified by the client, fees are charged monthly, quarterly or annually in arrears. Fees are calculated based on the account’s average market value for the period. Average market value for the period is the average of the market values, or as of the first day of the period and the last day of each month within the period, as stated on the client’s custodian statement. Fees for the initial billing, at the inception of the account, are prorated accordingly. If, during a period, the client makes a contribution to or withdrawal from the portfolio, fees will be pro-rated accordingly. The value of securities in the client account is equal to the market value of the securities or in the absence of a market value, the fair market value as determined in good faith by the custodian.

In the event the client terminates an account, any fees owed to HSBC Global Asset Management (France) will be pro-rated accordingly.

Any fees that may have been prepaid previously by the client shall be refunded on a pro-rata basis based upon the number of calendar days remaining after the termination date in the period as to which fees may have been prepaid. The client or HSBC Global Asset Management (France) generally may terminate an investment advisory agreement at such time as mutually agreed upon in writing by HSBC Global Asset Management (France) and the client.
Other Fees and Expenses
Clients will pay brokerage and custody fees, see “Brokerage Practices.” Clients may elect to have their idle cash balances swept into money market funds including funds that are managed by HSBC Global Asset Management (France) or an affiliated company. In the cases where a money market fund is managed by HSBC Global Asset Management (France), HSBC Global Asset Management (France) may receive a management fee for its advisory services. As with all mutual funds, clients, through their investment in the money market fund are charged their pro-rata share of the fund’s fees and expenses. In addition, HSBC Global Asset Management (France), in its capacity as investment adviser, may invest client assets in mutual funds other than money market funds, advised by an affiliated company. Clients are given an appropriate fee adjustment for any holdings in the affiliated mutual funds that are not money market investments. The client is responsible for all other expenses and fees associated with an investment in the funds.

These fees and expenses may include but are not limited to, advisory and custodial fees, and any sales load incurred with the purchase or sale of the funds. Expenses and fees vary with each fund. The client should read the fund’s prospectus for a complete description of the fund’s fee structure. please register to get more info

HSBC Global Asset Management (France) may charge performance fees based on a share of capital gains or capital appreciation of the assets. please register to get more info

HSBC Global Asset Management (France) provides investment advice to banks and thrift institutions, investment companies, pension and profit sharing plan, corporations, business entities and others not mentioned here. Client relationships vary in scope and length of service.
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General Description
HSBC Global Asset Management (France)’s approach to portfolio management is rigorous and consistent and integrates risk management principles at each stage of the process. The investment philosophy and process rest on three pillars: valuation methods, budgeting and disciplined portfolio implementation.

Portfolio management teams supported by research start by assessing the valuation of securities and asset classes. This is carried using quantitative tools which are supplemented by in depth qualitative work. HSBC Global Asset Management’s investment philosophy is that valuation discipline is the key to good long term investment outcomes. This work is then brought into the context of portfolio objectives. Risk budgeting tools are used to build portfolios within the relevant contractual guidelines. Risk Management is a key component of HSBC Global Asset Management (France)’s investment philosophy and process. On an ongoing basis, HSBC Global Asset Management (France)’s investment process incorporates the systematic monitoring of portfolio exposures, absolute or relative risk levels, as well as a strict control of operational risk. In practice, all teams contribute to risk assessment: from asset allocation analysis and decision (Research and Asset Management) to implementation (Asset management and Trading) and controls (Asset Management, Middle Office, Investment Risk and Business Risk and Control Management (“BRCM”)). The BRCM team of HSBC Global Asset Management (France) is responsible for monitoring the operational risk assessment and executing second level reviews in respect of the Internal Control plan established on an annual basis. The internal controls may be conducted through sampling or may consist of a check of the Company process. Where necessary, the review can focus on a particular type of portfolio or asset. The BRCM team reports to the Chief Executive Officer of HSBC Global Asset Management (France). The BRCM team has also functional connections with the Global functions of HSBC France (Operational Risk team - “OR”), HSBC Global Asset Management Limited (Global Business Risk) and to the Chief Operating Officer of HSBC Global Asset Management (France). In addition to the BRCM monitoring, the OR team ensures that the HSBC Global Asset Management (France) Business Units and BRCM control capabilities are adequate and provides an on-going oversight. Furthermore, the Internal Audit of HSBC Group carries out periodic reviews which enable to provide an independent assurance to the Group Senior Management that the key risks arising from the activities of the business are managed in an appropriate manner and in accordance with Group standards, and that the controls put in place by HSBC Global Asset Management (France) are efficient.

The Middle Office is specifically in charge of post market monitoring of all transactions implemented.

The dedicated Investment Risk Team is responsible for monitoring investment risk independently from the portfolio managers. The team reports to the Chief Risk Officer. Under the oversight of HSBC Global Asset Management (France)’s Risk Committee, the Investment Risk team defines risk policies and controls, selects appropriate risk measures (e.g., modified duration, tracking-error, Value-at-Risk, stress testing), implements market risk controls and analysis of the risk over all client accounts, and, when appropriate, conducts stress scenarios. They communicate the result of their control assessment and the potential risk that the portfolio managers could face to Senior Management. In order to ensure that internal guidelines and risk policies are well implemented, the Investment Risk team collaborates on a daily basis with the investment teams. They are in constant contact with portfolio managers and traders in order to assist in managing the risk in their portfolios, keeping a clear view on the market configuration and potential risks that could arise.
HSBC Global Asset Management (France) currently does not offer strategies to US
clients.
The strategies described below relate to a Canadian based mutual fund and a
Luxembourg based investment company for which there are restrictions on offers and
sales to U.S. Persons and for which HSBC Global Asset Management (France) does not
offer or solicit U.S. based clients. Nonetheless, as some U.S. persons have in the past
invested in these funds, the strategies are consequently disclosed in this Form ADV Part
2A:
European Equities:
HSBC European Fund
European Equities strategy seeks to achieve long-term capital growth by investing in a broad range of large European-based companies. These companies are primarily from the United Kingdom, France, Germany, Italy and other Developed European nations.

HGIF European Equity
European Equities strategy seeks long term capital growth by investing primarily in a diversified portfolio of investments in equity and equity equivalent securities of companies which have their registered office in, and with an official listing on a major stock exchange or other Regulated Market of any developed European country. The portfolio is diversified by sector and individual stock exposure.

The strategies described in this Brochure should not be considered as an exhaustive list
of the strategies of HSBC Global Asset Management (France), but rather represent the
strategies into which certain investors have been identified as being U.S. Persons.

Material Risks for Investment Strategies:

General investment risks:
The information included in this brochure does not include every potential risk associated with each investment strategy.

Investing in securities involves risk that clients should be prepared to bear. Set out below are material risks for HSBC Global Asset Management (France)’s strategies and how HSBC Global Asset Management (France) seeks to mitigate those risks.
Performance Risk
Definition: the risk that the portfolio doesn’t reach its performance and/or risk target.

HSBC Global Asset Management (France)’s investment risk program is designed to manage this risk. It involves both ex-post and ex-ante risk monitoring. Alert levels on ex-post risk indicators (e.g. volatility, tracking-error) identify if performance risk require specific action to be taken. Prior to this, alerts on ex-ante risk indicators observe a priori this kind of risk.
Market Risk
Definition: risk brought about by changes in market prices (interest rates, stocks, foreign exchange rate, inflation, volatility, correlations, etc.) The main risk faced by HSBC Global Asset Management (France)’s investment strategies is market risk. We seek to mitigate this risk using the following techniques: Portfolios are explicitly built taking into account the trade-off between expected returns and risk levels In-house optimization tools based on a forward-looking approach to risk Consistent allocation decisions through the investment strategies and time Portfolio exposures are controlled on a daily basis Portfolio investment risks are frequently monitored and controlled
Model Risk
Definition: the risk of financial loss linked to the use of an inappropriate or incorrect model for the valuation (mark-to-model) or the calculation of risk indicators.

In addition to standard checking put in place for avoiding valuation risk, HSBC Global Asset Management (France) has put in place specific actions to constantly manage the risk linked to the models driving its investment decisions: Investment research team frequently updates model results HSBC Global Asset Management (France)’s investment process allows for a “Judgmental Overlay” in which fund managers can propose to modify model recommendations: o active positions derived from risk-adjusted expected returns may be altered o model proposed allocation can only be reduced or neutralized, never reversed Performance attribution monitors the results of investment decisions and evaluates risk- adjusted returns

Liquidity Risk
Definition: Asset liquidity risk : to be unable to sell an asset at its price. Funding liquidity risk : risk that a portfolio fail to pay (redemptions, margin calls, etc.)

HSBC Global Asset Management (France)’s strategies look for generating alpha through tactical asset allocation on the most liquid markets and not through investing in more illiquid markets or “niches”.

HSBC Global Asset Management (France)’s strategies systematically implement Efficient Portfolio Management (EPM), favoring liquid derivatives (primarily futures) that reduce trading costs HSBC Global Asset Management (France)’s strategies are designed to deliver daily NAV. The Investment Risk team is regularly checking independently from fund managers funding liquidity risk.
Counterparty Risk
Definition: the risk of loss in a fund brought about by a default of the company with which the fund is contractually involved (through IRS for example). OTC instruments are marked to market under established Collateral Swap Agreements. HSBC Global Asset Management (France)’s Risk Committee sets the counterparty policy, reports and the Brokers Committee approves all counterparties in accordance with the Markets in Financial Instruments Directive (“MIFID II”) requirements.
Material Risks for Significant Types of Securities
HSBC Global Asset Management (France) does not recommend primarily a particular type of security.
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There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of or the integrity of HSBC Global Asset Management (France) or its management persons. HSBC Global Asset Management (France) has not been subject to any public sanctions or enforcement actions for which the regulators have estimated necessary to disclose the details to the public. please register to get more info

Other Material Relationships
HSBC Global Asset Management (France) acts as investment sub-adviser to affiliated investment advisers, which provide discretionary investment advisory services to certain of its clients as previously noted. HSBC Global Asset Management (France) renders continuous investment advice for the portions of the portfolios for which it acts as sub-adviser, and has investment discretion with respect thereto, subject to review and supervision by the affiliated advisers. HSBC Global Asset Management (France)'s compensation from the affiliated advisers for these services is generally 50% of the fees collected by the affiliated adviser for which it acts as sub-adviser, paid in arrears.

As a member of the HSBC Group, HSBC Global Asset Management (France) has implemented procedures and arrangements that are designed to identify which recognize and manage actual or potential conflicts of interest. The organizational and administrative arrangements which have been put in place to safeguard the interests of clients are documented in the Conflicts of Interest Policy and procedure as stated in the paragraphs below. Each member of the HSBC Group maintains a conflict of interest policy and register in relation to their particular business. In the event of a potential or actual conflict of interest between members of the Group, this will be escalated for information and resolution up the relevant compliance reporting line. Furthermore, physical and electronic information barriers have been implemented to restrict the flow of confidential information.
Receipt of Compensation from Investment Advisers
HSBC Global Asset Management (France) does not recommend or select, for the strategies it proposes to US clients, other investment advisors from whom compensation is received directly or indirectly.


CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING

Code of Ethics
HSBC Global Asset Management (France) has adopted:  A Code of Ethics, applicable to HSBC Global Asset Management (France)’s employees, including those who manage funds registered under the United States Investment Company Act of 1940 (the “Access Persons”).  Staff Dealing Policies and Procedure.

HSBC Global Asset Management (France) will provide a copy of its code of ethics to any U.S. client or U.S. prospective client upon request.

The Code of Ethics incorporates, among other items, the rules and restrictions in relation to personal securities transactions of employees.

All employees are subject to the Code of Ethics and, for various financial instruments prior approval by their manager and the regulatory compliance function is required. This includes transactions on financial instruments in the context of an initial public offering and private placement.

Are also encompassed transactions on Financial Instruments carried out on behalf of an employee or by the employee for the benefit of a close person (i.e. a person with whom the employee has family ties, close ties or a significant interest in the result of the transaction), All employees are subject to a minimum 30-calendar days holding period of their personal security holdings. Certain employees have additional restrictions in respect of personal transactions because of their duties within the company. Employees in regular or permanent contact with issuers or issuers’ operations and/or that have access to confidential information about customers or transactions concluded with or on behalf of customers or that are involved in activities liable to generate conflicts of interest are subject to additional restrictions which follow the general principles below: For the investment management team, trading ban on Financial Instruments For the sales team, ban to deal on Financial Instruments of issuers which are HSBC Global Asset Management (France)’s clients. Waivers, exceptions may be granted or provided by the Compliance function. The HSBC Global Asset Management (France) Code of Ethics is available to all employees.

In addition, HSBC Global Asset Management (France) requires that all employees submit initial and annual holding reports, brokers’ statements and attest their compliance with the applicable rules for personal account dealings.
Participation or Interest in Client Transactions

Management of potential and actual conflicts of interest
In accordance with the HSBC Global principles, policies and procedures and applicable regulations issued by the French Financial Markets Authority (Autorité des Marchés Financiers (“AMF”)), the French securities regulator, HSBC Global Asset Management (France) has established procedures and policies that are designed to identify the circumstances which may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more clients, or to the Group's reputation.

Internal procedures and policies, notably the Conflicts of Interest Policy have been established specifying the procedures to be followed and measures to be adopted in order to identify and manage conflicts effectively. HSBC Global Asset Management (France) maintains a register of identified and potential circumstances that may give rise to a conflict of interest.

In the circumstances where the procedures and controls implemented by HSBC Global Asset Management (France) may not be sufficient to ensure that a potential conflict of interest does not damage a client’s interests, the company will disclose the potential conflict to the client.

Furthermore, HSBC Global Asset Management (France) may decline to act in any circumstance where there is residual risk of damage to the interests of any client.
Participation or Interest in Personal Trading – Client Recommendations
Policy regarding personal account trading
The policy implemented to address the conflicts that arise in connection with personal trading is outlined in the Code of Ethics. In addition to the above section on Code of Ethics of HSBC Global Asset Management (France), according to such Code of Ethics, the employees are not permitted to effect personal transactions based on inside information about an issuer or an issuer’s plans or operations on their own account or on behalf of anyone that they have family ties or close ties with or where they have a significant interest in the result of the transaction. In the context of their personal transactions, employees must refrain from: -Providing privileged information to other people outside the normal scope of their work or for any purpose other than that for which the information was provided to them; - Recommending that another person purchase or sell or having another person purchase or sell, on the basis of privileged information, the financial instruments to which the information relates or related financial instruments; - Carrying out transactions or issuing orders that give or are likely to give false or misleading information concerning offer, demand, or the price of financial instruments; - Unlawfully using information concerning managers’ orders pending; - Deliberately providing or circulating information that gives or is likely to give false, inaccurate, or misleading information on financial instruments (including by spreading rumors) whereas they knew or should have known that the information was inaccurate or misleading.
Participation or Interest in Personal Trading – Client Trading
HSBC Global Asset Management (France) does not engage in proprietary trading, and consequently there are no potential conflicts of interest between orders placed on behalf of clients and orders placed on behalf of proprietary accounts. For proprietary trading by staff, see paragraph above “Participation or Interest in Personal Trading – Client Recommendations”.

HSBC Global Asset Management (France) may perform purchase and sale between portfolios on the condition that it complies with various obligations, such as those imposed by the AMF and guidance issued by the Association Française de Gestion financière (“AFG”), or the rules established at HSBC Group level.

Only purchase / sale transactions between portfolios managed within the same asset management company are authorized. Regularization transactions between a portfolio managed by an asset management company and the error account of the latter within the framework of managing incidents linked to errors in the assignment of transactions are authorized. Any purchase/sale transaction must be subject to a prior validation by the Chief Investment Officer, Risk Management and the Compliance team. After approval by the CIO and verification by Risk Management regarding the consistency of the price with the market and based on information related to the contributors’ price, issued by the trading team, Compliance team will ensure that the transaction is compliant before validating the purchase/sale transaction between portfolios. Purchase/sale orders must be handled systematically by a broker. Purchase/sale transactions must comply with the prospectus or the investment management agreement and be conducted in the interests of the shareholders. Any transaction which is not in compliance with these principles is prohibited. Similarly, the arbitrage of positions among managed portfolios, conducted solely to ensure the liquidity of one or the other is also prohibited. BROKERAGE PRACTICES
Broker-Dealer Selection
HSBC Global Asset Management (France) will take all sufficient steps to achieve the best possible result (“best execution”) when transmitting orders for execution to intermediaries for and on behalf of, as well as in the best interest of, its clients or funds.

HSBC Global Asset Management (France) has an internal procedure for selecting such intermediaries covering all financial instruments.

The best execution and selection policy covers all types of clients: eligible counterparties, professional clients, non-professional clients.

HSBC Global Asset Management (France) has drawn up a best execution policy taking the following criteria in particular into consideration: (1) The characteristics of the execution venues where orders may be executed: - Regulated markets - Multilateral trading systems - Systematic internalisers - Market makers - Liquidity providers - Entities that perform similar tasks in a country that is not party to the European Economic Area.

(2) The following execution factors (not in any order of priority): - Price at which the order could be executed - Cost paid once the order has been executed - Order execution and settlement speed - Likelihood of order execution and settlement - Market liquidity and the order’s impact on a volatile market - Order size - Order type All other considerations relating to the order’s execution. (3) The fund-specific investment policies, objectives and risks, as indicated in the prospectuses and client mandates. (4) Lastly, the following types of financial instruments: - Equities, trackers and related securities - Fixed-income products - Listed derivatives - OTC financial derivatives - Foreign exchange transactions - Money-market products.
Intermediary / Counterparty Selection Policy
For each category of instruments, HSBC Global Asset Management (France) has in place a number of internal policies and processes to select the intermediaries and counterparties to which orders are transmitted for execution. HSBC Global Asset Management (France) keeps a list of authorised intermediaries and counterparties for each type of financial instrument. This dedicated list is used for all clients/funds. However, in exceptional cases, a more restrictive sub-list may apply for a particular mandate in order to meet that client’s specific requirements. The authorised intermediaries have order execution mechanisms designed to enable HSBC Global Asset Management (France) to fulfil its obligations to ensure the best possible result. In this context, HSBC Global Asset Management (France) not only oversees the execution policy applied by its intermediaries, but also ensures that the entities selected have sufficient access to the various execution venues (regulated markets, multilateral trading systems, multilateral trading platforms, etc.). HSBC Global Asset Management (France) has expressly authorised its intermediaries and counterparties to use these various execution venues. When HSBC Global Asset Management (France) transmits orders on behalf of a non- professional client to intermediaries for execution, the most important of all the criteria set out above is the total cost (price of the financial instrument and order execution cost relating to this instrument).
Client Specific Instructions
Whenever a client provides specific instructions (primarily transmitted by an institutional client under an individual management mandate and relating in particular to the organisation or choice of an intermediary, or to certain parts or aspects of the order) to HSBC Global Asset Management (France), the latter will transmit its client’s order in accordance with those instructions, but will not be able to guarantee the application of its best execution policy (price of the financial instrument and order execution cost relating to this instrument). In such cases, the order's execution will therefore be considered to be compliant with its best selection obligations for the part or aspect of the order covered by the specific instructions.
Monitoring and archiving
HSBC Global Asset Management (France) regularly monitors the effectiveness of its best execution and selection policy (through “Brokers” committee meetings and reports) and, more specifically, the execution quality of the intermediaries selected under this policy in order to identify and carry out any necessary corrective measures. HSBC Global Asset Management (France) performs a review prior to the approval of each counterparty, in addition to a half-yearly review of the effectiveness of its process for selecting and rating its intermediaries with a view to identifying and, if necessary, addressing any shortcomings. Before an intermediary is added to the list of counterparties, HSBC Global Asset Management (France) assesses the intermediary in question with emphasis on the following elements: - Spreads and fee rates - Market access - Reputation and financial stability - Supervisory authority penalties - Other For the half-yearly review, HSBC Global Asset Management (France) assesses the intermediary in question with emphasis on the following elements: - Execution speed - Past order execution history - Settlement capacity - Execution quality of service - Other

Transaction records are archived for at least five years or longer, depending on the local regulations concerned.
Research and Other Soft Dollar Benefits
In accordance with French regulation, HSBC Global Asset Management (France) cannot participate in or apply any soft dollar arrangements.

Since the entry into force of MIFID II on January 3rd, 2018, HSBC Global Asset Management (France) does not pay its research providers through Commissions Sharing Agreements anymore. These services are now covered by research supply agreements entered into by HSBC Global Asset Management (France). As a consequence, the research is now paid directly by HSBC Global Asset Management (France).
Brokerage for Client Referrals

Not applicable to HSBC Global Asset Management (France)

Directed Brokerage

When the orders are executed, HSBC Global Asset Management (France) takes all reasonable steps to obtain the best possible type of execution for its clients in terms of price, cost, speed, likelihood of performance and settlement, size, nature of the order, or any other considerations concerning execution of the order. Nevertheless, whenever a client provides specific instructions to use a specific broker, HSBC Global Asset Management (France) will transmit the client’s order in accordance with those instructions, but will not be able to guarantee the application of its best execution policy As noted above, in such cases, the order's execution will therefore be considered to be compliant with its best selection obligations for the part or aspect of the order covered by the specific instructions. In terms of brokerage allocation, procedures have been adopted in order to reasonably ensure that transactions in the same security are fair and equitable to all client types with no group being favoured or disfavoured over any other group.
Aggregation of Trades
HSBC Global Asset Management (France) may follow the practice of grouping orders of various clients for execution in order to get the benefit of lower commission rates. Even though the orders are aggregated they are pre-allocated to each concerned account before their aggregation. In certain cases, where the aggregate order may be executed in a series of transactions at various prices, each participating client's proportionate share of such order will reflect the average price paid or received with respect to the total order.

When HSBC Global Asset Management (France) or its related persons determine that it would be appropriate for one or more of its clients to participate in an investment opportunity, HSBC Global Asset Management (France) seeks to execute orders for all of the participating clients on an equitable basis.

Similarly, if an order on behalf of more than one client cannot be fully executed under prevailing market conditions, HSBC Global Asset Management (France) will allocate the securities traded among the different clients pro rata based on each such Fund's capital available for investment or, if for any reason this would not result in a position size that is economically reasonable, by any other basis which it considers equitable. In these circumstances, each client would pay, in connection with the acquisition of securities by more than one client, the average price per unit acquired, which may be higher or lower than if each individual client had acted alone, and HSBC Global Asset Management (France) may not be able to execute an investment decision as effectively as it could have if it had acted for one client only.

Instances may also arise where HSBC Global Asset Management (France) determines an investment opportunity to be suitable for more than one client, but where the market is too illiquid to enable each client to participate to the extent advisable. In the above situations, or in other situations in which conflicts arise, HSBC Global Asset Management (France) will endeavor to allocate investment opportunities fairly.
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Factors Triggering a Review

HSBC Global Asset Management (France) performs a continuous and on-going monitoring of its clients’s investment portfolios to ensure that each security or asset allocation is suitable based on the information provided by the clients. All the investment portfolios are reviewed regularly by the Investment Managers and the Investment Risk. The Investment Manager or his designee is responsible for approval of the valuation of the portfolios managed. An independent Investment Regulatory Restrictions team collaborates with investment teams daily to make sure that internal guidelines, risk policies investment policies and guidelines are well implemented. In this way, the Investment Risk team informs the investment managers daily of any breaches that may have occurred on their funds. The Risk Officer also inquires what remedial action the Investment manager intends taking. Main breaches are escalated to Senior Executives. More frequent reviews will be triggered by material changes in variables including but not limited to client’s individual circumstances, product underperformance, style change, and market conditions. At least annually, HSBC Global Asset Management (France) may request in writing that clients update with any changes to their financial status, investment objectives, risk tolerance or other important information.

Other conditions that may trigger a review are changes in the securities laws, new investment information, and changes in clients own situation. Moreover, the BRCM performs second level controls in relation to the investment management activities, as part of its permanent supervisory tasks.

Client Reports
Clients will receive periodic reports on a regular basis according to the requirements decided with the clients or at least as required by the law and regulation. These written reports include, but are not limited to, details of trades, portfolio performance, contributions and withdrawals, and fees and charges. These reports will differ in presentation and type of information presented, but should be consistent in regards to assets, contributions and withdrawals. please register to get more info

Other Compensation
HSBC Global Asset Management (France) may be selected by consultants to participate in requests for proposals, which in the event of selection may bring compensation to be paid by HSBC Global Asset Management (France) to the consultants.

In order to address potential conflicts of interests linked with this practice, a process is in place to ensure that the consultants do not receive gifts or other inducements from HSBC Global Asset Management (France).

The Local Compliance Officers are required to provide prior authorization for gifts received as well as provided.

Before entering into a relationship with a consultant, a bribery risk assessment and due diligence is performed. Following the completion of a satisfactory due diligence, contract negotiations can proceed. The contract must be in writing and include anti-bribery representations and warranties and where appropriate, termination provisions. Ongoing monitoring and review of the relationship is required. The fees payable have to reflect the services rendered and/or to be in line with market rates. please register to get more info

All clients assets are held by independent qualified custodians. HSBC Global Asset Management (France) does not have custody of U.S. clients’ funds or securities nor custody of non-U.S. clients funds or securities in its books. please register to get more info

Discretionary authority to manage securities accounts on behalf of clients is formalized through the clear mandate of an executed investment advisory agreement where the legal framework, the conditions, the responsibilities, the limitations, investment policy guidelines, advisory fees and reporting requirements are detailed. Prior investigation is made to ensure the investment management process complies with the local regulation ruling the account. please register to get more info

As per equities portfolios, HSBC Global Asset Management (France) has set up a Corporate Governance Committee responsible for determining and monitoring the voting policy at General Meetings. Managers and analysts make voting decisions based on the principles defined by this Committee. The Middle Office department is responsible for implementation and for the operational process of exercising voting rights at General Meetings. HSBC Global Asset Management (France) uses the services of ISS, a world leader in supplying corporate governance services, particularly when it comes to managing voting rights. HSBC Global Asset Management (France) has defined guidelines or voting criteria which include the recommendations of the AFG, the OECD, AFEP/MEDEF and the UK Corporate Governance Code.
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HSBC Global Asset Management (France) is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has it been the subject of a bankruptcy petition at any time during the past ten years.


OTHER INFORMATION

BUSINESS CONTINUITY PLAN
General HSBC Global Asset Management (France) maintains electronic and hardcopy information assets which are essential to performing services for its clients. Disasters The Business Continuity Plan covers natural disasters and man-made disasters such as communications line outage, Internet outage, electronic files are backed up daily and archived offsite. The plan is tested every year. Alternate Offices We maintain alternate offices to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients promptly if a disaster forces us to move operations to an alternate location. We also maintain a separate IT backup site in case the main IT operation centers becomes unavailable. Loss of Key Personnel In the event of a loss of key personnel, we will contact all affected clients and will determine promptly who the appropriate replacement person - internal or external - should be. For that purpose, we are maintaining a confidential succession plan for key positions.

INFORMATION SECURITY PROGRAMM
Information Security HSBC Global Asset Management (France) maintains a strict information security program to reduce the risk that your personal and confidential information may be breached, in accordance with HSBC group policies. It employs the use of firewalls, virus scanners and other methods of securitization to ensure that your information is protected.

Privacy Notice HSBC Global Asset Management (France) is committed to maintaining “non-public personal information” (as defined in the SEC’s Regulation S-P) of its clients in a responsible manner. The confidential data processed by HSBC Group within the framework hereof including the Personal Data may be communicated to, and used by, HSBC Group entities or third parties (authorities, subcontracting companies, consultants, etc.), for the purposes hereof or for commercial actions of the Bank and HSBC Group companies. HSBC Global Asset Management (France) may also communicate Personal Data in order to meet legal, tax or regulatory requirements. HSBC Global Asset Management (France) may also transfer and disclose Personal Data to a member of the HSBC Group, which are necessary for the purpose of combatting Financial Crime within the HSBC Group. In all these cases, HSBC Global Asset Management (France) will then be released from its obligation of professional secrecy. HSBC Global Asset Management (France) has established and maintains a number of procedures for the Protection and Prevention of the Misuse of Non-Public Information about Clients. Collection and Gathering of Information: HSBC Global Asset Management (France) limits the use of the information gathered from clients to the minimum requirements set forth by regulatory obligations, and what is required to service the accounts of clients with the highest standards. Those information might be subject to an automated treatment whose systems might be located abroad. Protection of Your Information: HSBC Global Asset Management (France) employees are committed and required to protect the confidentiality of client information. They may access your information only when necessary to perform their job functions. HSBC Global Asset Management (France) also maintains physical, electronic and procedural safeguards to help protect your information.

Disclosure of Information: As a general policy, HSBC Global Asset Management (France) will not disclose personal financial information about any client to affiliated and non-affiliated parties, except as necessary to establish and manage the client’s account(s), or as required by law. To the extent permissible by applicable law, HSBC and other members of the HSBC Group may collect, use and share client’s information (including relevant information about the Client, the Client’s transactions, the Client’s use of HSBC’s products and services, and the Client’s relationships with the HSBC Group). Clients’ Information may be requested from the Client (or a person acting on the Client’s behalf), or may also be collected by or on behalf of HSBC, from other sources (including from publically available information), generated or combined with other information available to HSBC or any member of the HSBC Group. Clients’ information may be disclosed in such circumstances as regulatory audits, attorneys or judges as part of a litigation, or law enforcement or other government agencies to help prevent, among other things, fraud bribery, and money laundering. please register to get more info