Petercam Institutional Asset Management (renamed “Degroof Petercam Asset Management”) was
incorporated as a private limited liability company in Brussels, Belgium, in October 2013. It is an asset
management company under the prudential supervision of the Financial Securities and Market
Regulation (FSMA), the regulatory body in charge of controlling the asset managers established in
Belgium.
Petercam Institutional Asset Management (renamed “Degroof Petercam Asset Management”) was
wholly-owned by its parent company Petercam SA (“Petercam”) until September 30, 2015. On
October, 1st 2015, Petercam and Bank Degroof SA (“Bank Degroof”), a credit institution incorporated
in Brussels, Belgium, merged. The merger occurred through the absorption of Petercam by Bank
Degroof, which is the surviving entity and which has been renamed “Bank Degroof Petercam”. As a
result of the merger, all assets and liabilities of Petercam, including its shares in Petercam
Institutional Asset Management (renamed “Degroof Petercam Asset Management) have been
transferred to Bank Degroof Petercam. Bank Degroof Petercam has therefore become the sole
shareholder of Degroof Petercam Asset Management.
On January, 4 2016, Petercam Institutional Asset Management merged with Degroof Fund
Management Company (“DFMC”), another management company wholly owned by Bank Degroof
Petercam. The merger occurred through the absorption of DFMC by Petercam Institutional Asset
Management, which is the surviving entity and which has been renamed “Degroof Petercam Asset
Management”.
As of December 31, 2018, Degroof Petercam Asset Management managed USD 8.080 billion
(including IPM) in client assets on a discretionary basis.
Degroof Petercam Asset Management is an active manager that specializes in a number of asset
classes as more fully described in Item 8. Its business covers asset management for institutional and
professional clients and the sale and distribution of the Degroof Petercam Asset Management foreign
investment funds to non-U.S. persons. Degroof Petercam Asset Management only receives
compensation for asset management activities. It does not receive any compensation for its sales
and distribution activities of investment funds.
Degroof Petercam Asset Management proceeded to a capital increase on 28 December 2017. Indeed,
Banque Degroof Petercam, the mother company of Degroof Petercam Asset Management,
contributed its institutional portfolio management activity to Degroof Petercam Asset Management.
As a result, the entire activity of individual portfolio management in Belgium is now performed by
Degroof Petercam Asset Management, who become the center of expertise of individual and
collective asset management of the Degroof Petercam group in Belgium for institutional clients. The
capital increase took effect on 1st January 2018.
Degroof Petercam Asset Management analyses, constructs, and manages customized investment
portfolios based on the particular goals of each client in a manner which takes into account income
needs, liquidity requirements, investment time horizons, rate of return objectives, tax
considerations, risk tolerance and existing investments.
Depending on the particular investment portfolio and/or investment strategy, Degroof Petercam
Asset Management employs a variety of security analysis methods, including active and quantitative
management. Degroof Petercam Asset Management also consults a wide range of information to
analyze and execute investment strategies in addition to our in-house research capabilities, such as:
third party research materials, annual reports, prospectuses, regulatory filings, press releases and the
internet.
Degroof Petercam Asset Management does not participate in wrap fee programs.
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Degroof Petercam Asset Management is currently compensated only on the basis of fees calculated
as a percentage of a client’s assets under management. Fees are generally charged quarterly in
arrears and calculated upon the average assets under management during such quarter, as agreed
with the client (and specifically stated in the Investment Management Agreement between Degroof
Petercam Asset Management and the client). In the case of segregated mandates (not investment
funds), clients receive a (quarterly) invoice after each period, which they can decide to pay from the
investment account or from a separate account.
As a general rule, Degroof Petercam Asset Management only charges management fees to its clients.
There are however certain exceptions when DPAM receives performance based fees. But if in the
future, clients would prefer to pay performance based fees, Degroof Petercam Asset Management
may be compensated with performance fees and will comply with Rule 205-3 under the Investment
Advisers Act if it charges any such performance fees.
In the event an institutional client terminates its agreement with Degroof Petercam Asset
Management during a quarterly period, the fee for that period will be prorated based in the number
of days or months during the period in which Degroof Petercam Asset Management performed
services.
Since this Brochure shall be delivered only to clients who are “qualified purchasers,” as defined in
Section 2(a)(51)(A) under the Investment Company Act, a fee schedule has not been provided in this
Brochure but is available in each client’s Investment Management Agreement. In addition to paying
management fees, clients are typically subject to other investment expenses including, but not
limited to custodial charges, brokerage fees and commissions (as discussed further in Item 12),
interest expenses, and costs associated with foreign exchange transaction, as well as taxes and other
governmental charges. Neither Degroof Petercam Asset Management nor any of its supervised
persons accept compensation for the sale of securities or other investment products, including asset-
based sales charges or service fees from the sale of mutual funds.
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Performance-Based Fees
See also Item 5.
Side-by-Side Management
Degroof Petercam Asset Management does not participate in side-by-side management.
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Degroof Petercam Asset Management mainly provides sub-advisory services to non-affiliated SEC-
registered investment companies through sub-advisory arrangements. Concretely, institutional
clients typically include pension plans, insurance companies, charitable organizations, endowments
and other professional investors. Degroof Petercam Asset Management does not provide services to
individual investors.
Degroof Petercam Asset Management may also provide investment advisory services to U.S.
institutional clients, including state pension plans and ERISA plans. Besides sub-advisory services,
Degroof Petercam Asset Management may also provide recommendations and investment advice
regarding investment strategies to affiliated and unaffiliated entities.
Generally, there is no minimum account size. However, for institutional segregated mandates offered
to U.S. clients, the minimum size is $25 Million
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Methods of Analysis
Our buy-side analysts (equity and fixed income/credit) create proprietary research to support our
portfolio managers, who can also conduct their own investment research. Our portfolio management
professionals then implement our discretionary investment strategies.
Our investment professionals have experience investing in various types of securities and asset
classes, including common and preferred stocks, warrants and convertible securities, government
and corporate fixed income securities, currencies, and inflation-linked securities. We also have
experience investing in derivatives, including options, futures, swaps, forwards, credit default swaps
(“CDS”) and similar instruments. Most of our portfolios generally focus on ‘long’ trades, but may
utilize derivatives and CDS to hedge certain risks in portfolios.
In-house research is the main source of investment research, but we use many other external
sources such as annual reports, broker reports, Bloomberg, Datastream, reports from the IMF and
the World Bank and similar sources.
Although the focus is on fundamental, proprietary bottom-up research, quantitative analytics are
utilized in some of our investment activities to assist in the selection of securities, the management
of idiosyncratic risks, or for hedging purposes. Nonetheless, it should be noted that fundamental
research remains the most important factor for our investment decisions.
Investment Strategies
Equities
Our fundamental (bottom-up) long-only equity expertise includes the detection and exploitation of
market inefficiencies using in-house buy-side research. Through active portfolio management, we
strive to create risk-adjusted outperformance versus the market and competitors.
We offer expertise in European and global equity solutions as well as segregated institutional
mandates. Our approach is characterized by high-conviction security selection and the identification
of long-term trends and views.
A key differentiating factor is our focus on the mid-cap segment. Such companies often have an
unrecognized capacity to create value or an undervalued business franchise. Over time, they can
become market leaders.
The quantitative equity expertise consists of actively managed equity funds. The scope of our
quantitative equity expertise contains US behavioral value as well as EMU and Europe behavioral
value equity strategies.
Our indexation expertise manages several equity funds covering the entire MSCI developed and
emerging universe. Tracking the performance of the different indexes is done through full or quasi
full replication.
Fixed Income
Our investment process combines top-down and bottom-up elements. On the one hand, we build
exposure to relevant factors such as interest rates, yield curve, credit risk and country allocation. On
the other hand, we select individual securities based on fundamental research and relative value
analysis. We have the flexibility to be opportunistic when the consensus is priced in by the markets.
Our fixed income expertise is focused on government bonds, corporate investment grade debt,
corporate high yield debt, emerging market debt, global inflation linked, global unconstrained
strategies and money market instruments.
Global Balanced Management
Our Global Balanced Management team manages our expertise in asset allocation, which shows our
expertise in combining different asset classes (mainly cash, fixed income & equities).
This approach is based on different approaches & inputs coming from our macroeconomic, equities
& fixed income views.
Our global asset allocation is mainly oriented towards a long term Value approach.
Responsible Investment
Degroof Petercam Asset Management believes that integrating extra-financial data on how
companies or countries react to these challenges will add value to the investment process and will
thus benefit to the end investor and society as a whole. Degroof Petercam Asset Management is also
convinced that incorporating sustainable issues in its analysis improves the risk-reward relationship
of its investments. We offer 11 dedicated Responsible Investment strategies:
- DPAM INVEST B Equities Europe Sustainable,
- DPAM INVEST B Equities World Sustainable
- DPAM L Bonds Government Sustainable,
- DPAM L Bonds Emerging Markets Sustainable
- DPAM L Bonds EUR Quality Sustainable
- DPAM Equities L EMU SRI MSCI Index
- DPAM Equities L US SRI MSCI Index
- DPAM Equities L World SRI MSCI Index
- DPAM Global Strategy L Conservative Balanced Sustainable
- DPAM Invest B Equities Sustainable Food Trends
- DPAM Invest B Equities NewGems Sustainable
Risk of Loss
Investing in Degroof Petercam Asset Management’s investment solutions involves a number of risks
that clients should be prepared to bear.
It should be noted the following list is not exhaustive.
General Investment Risks
Market Risk: Security prices are volatile and are affected by the real or perceived impacts of such
factors as economic conditions and political events. Financial markets tend to be cyclical, with
periods when stock prices generally rise and periods when stock prices generally decline. Any given
stock market segment may remain out of favor with investors for a short or long period of time, and
stocks as an asset class may underperform bonds or other asset classes during some periods.
Currency Risk: To the extent that a client invests directly in foreign currencies or in securities
denominated in or that trade in foreign (non-U.S.) currencies, it is subject to the risk that those
currencies will decline in value relative to the U.S. dollar or, in the case of hedging positions, that the
U.S. dollar will decline in value relative to the currency being hedged.
Foreign Investments: Investing in foreign (non-U.S.) securities may result in more rapid and extreme
changes in value than an investment exclusively in securities of U.S. companies, due to smaller
markets, differing reporting, accounting and auditing standards, and nationalization, expropriation or
confiscatory taxation, foreign currency fluctuations, currency blockage, political changes or
diplomatic developments, or changes in foreign exchange regulations.
Market Capitalization: Stocks fall into three broad market capitalization categories - large, mid and
small. Investing primarily in one category carries the risk that, due to current market conditions, that
category may be out of favor with investors. If valuations of large-capitalization companies appear to
be greatly out of proportion to the valuations of mid- or small-capitalization companies, investors
may migrate to the stock of mid- and small-sized companies causing an investment in these
companies to increase in value more rapidly than an investment in larger, fully-valued companies.
Investing in mid- and small-capitalization companies may be subject to special risks associated with
narrower product lines, more limited financial resources, smaller management groups, and a more
limited trading market for their stock as compared with larger companies. As a result, stock of mid-
and small-capitalization companies may decline significantly in market downturns.
Liquidity and Concentration Risk: These elements of potential risk are followed on a consolidated
basis as well as on a portfolio or fund specific level.
Counterparty Risk: For counterparties, there is an internal rating system in place with three quality
levels (superior, prime, and non-prime) based on ratings agencies notations and CDS spreads.
Regarding counterparty risk for cash deposits, there are limitations in terms of concentrations
depending on the internal rating. For equities, our Dealing Desk only works with a number of brokers
which are regularly evaluated. Twice a year, the list of brokers is first reviewed through a survey,
which ranks the brokers on several criteria, and then through an execution vote, which puts forward
the quality of execution of the broker.
Business Continuity Risk: Business Continuity and Disaster Recovery are responsibilities of Bank
Degroof Petercam’s Operational Risk Management which defines the scope and objectives of the
tests in collaboration with all business units and the ICT department, and is responsible for their
realization. The Risk Management department monitors the results of the tests. The BCP (Business
Continuity Plan) is reviewed and validated every year by the Crisis Committee. Besides the Business
Continuity Plan, Degroof Petercam Asset Management makes daily backups of all its data files, which
are held by an off-site external specialized company.
Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
Investment Strategy Risks
In addition to the risks involved with various instruments and markets noted above, various
investment strategies also may entail unique risks. Several of these are described below. In all cases,
a client should review applicable offering documents and/or other materials, which will generally
have more detailed information about relevant risks.
Equities: Several of our investment strategies focus mainly or in part on equities. Equities can be of
various types, such as common stock or preferred stock, and generally are subject to market,
company-specific and liquidity risks.
Fixed Income: Many of our investment strategies focus mainly or in part on fixed income securities,
which can include a wide array of debt instruments, including investment grade debt, government
securities, corporate debt, money market instruments, mortgage-backed securities, non-investment
grade (or “high yield”) debt, credit-linked notes, structured securities, emerging market debt, and
others. To varying degrees—and depending on the particular instruments—fixed income securities
are subject to interest rate, credit, liquidity, counterparty, and geopolitical risks among others.
Emerging Markets: Degroof Petercam Asset Management has a number of strategies that invest in
emerging market debt or equity. These markets are often in developing countries and tend to be
more volatile and risky than more established trading markets. In addition, the instruments and
investments of emerging markets might often carry higher credit, company, liquidity, and geopolitical
risks.
Please note that there are various other circumstances not described here that could adversely affect
a client’s investment and prevent its portfolio from reaching its objective.
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Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of the adviser or the integrity of the
adviser’s management.
While no sanctions were imposed on Degroof Petercam Asset Management, the Commission de
Surveillance du Secteur Financier in Luxembourg (“CSSF”) brought a regulatory action against
Degroof Petercam Asset Management (formerly “Petercam Institutional Asset Management”) in
October 2011. The CSSF alleged that certain of the assets held by a mutual fund client were not
eligible to be held by the mutual fund according to the mutual fund’s prospectus. Degroof Petercam
Asset Management (formerly “Petercam Institutional Asset Management”) voluntarily proposed a
settlement, and the matter was settled in March 2012. Pursuant to the settlement, Degroof
Petercam Asset Management (formerly “Petercam Institutional Asset Management”) paid a
settlement amount to the investors in the mutual fund. Additionally, as disclosed in our Form ADV -
Part 1A, there have been Seven civil judicial actions brought by private plaintiffs against Bank
Degroof Petercam. Four of the actions were settled and three are currently pending. Further
information concerning these matters is disclosed in Item 11 of Form ADV – Part 1A, available at
“www.advisorinfo.sec.gov”.
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Neither Degroof Petercam Asset Management nor any of its management personnel are registered,
or have an application pending to register, as a broker-dealer or a registered representative of a
broker-dealer.
Neither Degroof Petercam Asset Management nor any of its management personnel are registered,
or have an application pending to register, as a future commission merchant, commodity pool
operator, a commodity trading adviser, or as an associated person of any of the foregoing.
Some non-executive directors of Degroof Petercam Asset Management are responsible for
departments of Bank Degroof Petercam or affiliates of the group, such as Investment Banking or
Private Banking, whose interests may conflict with those of Degroof Petercam Asset Management.
Moreover, some executive directors of Degroof Petercam Asset Management are members of the
Board of the investment funds managed and promoted by Degroof Petercam Asset Management.
Measures have been taken by both Degroof Petercam Asset Management and its affiliated
companies in order to manage conflicts which may arise from this combination of mandates, in
particular to ensure the independence and objectivity of investment research and investment
decisions, and to ensure the confidentiality of the information.
Furthermore, when they have an interest that conflicts with a decision or transaction taken by the
management body to which they belong, the members of the Management Board or the Board of
Directors of Degroof Petercam Asset Management will report this to the other members of the
Management Board or the Board of Directors prior to the deliberation and will make sure that they
do not take part in the voting related to that decision or transaction.
Conflicts of interests with business (clients or partners): Members of the Board of Directors of
Degroof Petercam Asset Management will either not accept Board memberships with external clients
or will withhold/refrain from all decisions related to Bank Degroof Petercam or its affiliates or
Degroof Petercam Asset Management.
Regardless of the circumstances, the members of the Management Board or the Board of Directors
of Degroof Petercam Asset Management will adhere to the requirements of Belgian corporate law in
terms of disclosing conflicts of interest.
Degroof Petercam Asset Management and its related companies have extensive policies in place
regarding the prevention of conflict of interest, in order to avoid any decision or transaction that
would harm the legitimate rights of the clients in any way.
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Employee Personal Trading Code of Ethics
All Degroof Petercam Asset Management employees and the Board of Directors are required to
follow our Code of Conduct. The Code of Conduct of Degroof Petercam Asset Management is based
in part on the BEAMA (Belgian Association of Asset Managers) Code of Conduct and is consistent
with the requirements of Rule 204A-1 of the U.S. Investment Advisers Act of 1940, as amended (the
“Advisers Act”). It applies to the activities of our company with regard to the management and
administration of UCIs (Units of Collective Investment) and portfolio management for our clients. A
copy of the Code of Conduct can be obtained by any client or prospective client upon request.
The Code of Conduct is based on the principles of good governance relevant within the context of
institutional asset management. These principles are in turn specified on the basis of best practices
and meet the requirements of the European, Belgian and United States legal and regulatory
frameworks for the sound organization of portfolio management in the broader sense and industry
standards, as well as the Advisers Act and the guidelines of the European Fund and Asset
Management Association (“EFAMA”, the representative association for the European Investment
Management Industry) recommended at the European level and the high-level principles of the
EFAMA Code of Conduct for the European Investment Management Industry.
Through this Code of Conduct, the aim of Degroof Petercam Asset Management is not only to anchor
the high standards set for asset management, but also to define guidelines that are consistent with
the legal framework in force and applicable to individual and collective portfolio management.
The Degroof Petercam Asset Management Compliance department conducts regular ex-ante and ex-
post checks.
Participation of Interest in Client Transactions
Degroof Petercam Asset Management does not have any Participation of Interest in any Client
Transactions.
Employee Personal Trading
Personal securities transactions by an employee or Director of Degroof Petercam Asset Management
or an investment adviser may raise a potential conflict of interest when that employee owns or
trades in a security that is owned or considered for purchase or sale by a client, or recommended for
purchase or sale by an employee to a client.
Degroof Petercam Asset Management has a separate Personal Account Dealing Policy intended to
define the rules and provisions governing the operations of the employees and the Board of
Directors of Degroof Petercam Asset Management when they carry out transactions involving
financial instruments privately, whether within the Bank Degroof Petercam group or outside it. The
Personal Account Dealing Policy also tackles subjects such as training, restrictions, holding periods
and penalties for not observing these rules.
As they concern the conclusion of business, the employees and the Board of Directors assume full
responsibility for the operations they carry out for their own account, and therefore bear the
consequences of the risks involved.
The Degroof Petercam Asset Management Compliance department conducts regular ex-ante and ex-
post checks. Transactions by an employee or a director on an account with Bank Degroof Petercam
are reviewed every day.
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Degroof Petercam Asset Management has outsourced its Dealing Desk to its parent company Bank
Degroof Petercam (“
Bank Degroof Petercam”) under certain specific exceptions (FX and other
derivative contracts). The conditions, rights and obligations are described in a Service Level
Agreement signed between Degroof Petercam Asset Management and Bank Degroof Petercam.
Selection of Brokers
Bank Degroof Petercam has established and implemented arrangements with a view to providing
clients with the best possible result on a consistent basis. Bank Degroof Petercam strives to obtain
"best execution" by taking all reasonable steps to obtain, when executing or receiving and
transmitting orders, the best possible result for their clients taking into account price, costs, speed,
likelihood of execution and settlement, size, nature or any other consideration relevant to the
execution of the order.
Based on the assessment of the services provided by the Dealing Desk of Bank Degroof Petercam and
on the review of its Order Execution Policy, Degroof Petercam Asset Management uses the Dealing
Desk of Bank Degroof Petercam for the transfer and execution of the trades generated within the
framework of its activities. At least on an annual basis, Bank Degroof Petercam’s Dealing Desk
assesses the quality of services provided by independent brokers and reviews whether a better
service from other brokers could be obtained. The Brokerage department of Bank Degroof Petercam
is one of the (external) brokers; a client can (specifically) ask not to use Bank Degroof Petercam as a
broker for his mandate.
Selection of Execution Brokers
Bank Degroof Petercam selects executing brokers based on their execution policy and ensures that
these selected entities comply with the overarching best execution requirement when placing or
transmitting an order to those for execution. One of these executing brokers may occasionally be the
Brokerage department of Bank Degroof Petercam.
To this end, Bank Degroof Petercam does not duplicate the efforts of execution brokers, but
conducts an in-depth review of their execution arrangements prior to their selection.
Bank Degroof Petercam selects executing brokers using the following criteria:
- Structure and level of trading fees;
- Financial solidity;
- Business reputation;
- Global relationship;
- Connectivity;
- Quality of middle-office/back-office support; and
- Client/back-office/middle-office feedback.
The process of selecting the executing brokers is primarily defined by the legal and regulatory
constraints that Bank Degroof Petercam is required to comply with, especially the MiFid or fund
legislation best execution framework. This process and its results are documented and are subject to
be reviewed and controlled by internal and external bodies.
Bank Degroof Petercam’s Order Execution Policy, as well as the procedure for choosing brokers, is
reviewed by the Compliance department of Degroof Petercam Asset Management. The Compliance
department monitors annually that the brokers' list has been reviewed.
The Broker Committee of Bank Degroof Petercam is in charge of the selection and review of
execution brokers.
At least annually, the Broker Committee conducts an in-depth review of execution brokers based on
quantitative and qualitative input and selects the execution brokers for the next period.
Best Execution Factors
The execution methodology of Bank Degroof Petercam takes into account the following best
execution factors:
- Price;
- Cost;
- Speed;
- Likelihood of execution and settlement;
- Size and nature of order; and
- Any other consideration relevant to the efficient execution of orders.
Ordinarily price will merit a high relative importance in obtaining the best possible result for the
client. Bank Degroof Petercam will determine the relative importance of each factor on an order-by-
order basis, taking into account criteria such as the characteristics of the client, the order, the
financial instrument and the execution broker used.
Bank Degroof Petercam will monitor the effectiveness of its Order Execution Policy to identify and,
where appropriate, correct any deficiencies. Bank Degroof Petercam will monitor particular
transactions by sampling and verifying whether the execution of the order has complied with the
Order Execution Policy and whether the resulting transaction has delivered the best possible result
for the client.
Bank Degroof Petercam will review the Order Execution Policy at least annually or whenever a
material change occurs that affects its ability to obtain the best result for the execution of its client
orders.
Any material change to the Order Execution Policy will be updated on the website of Bank Degroof
Petercam or be at the disposal of its clients in its offices.
Research
With full unbundling under MiFID II and the decision of DPAM to procure research & related services
via its own P&L, the execution relationship and business with trading counterparties suffer from no
influence or interference with the potential research component.
DPAM sets the ex-ante research budget and conducts the selection and review of research providers
according to its own procedures.
Methodology of Order Execution
The Dealing Desk (Bank Degroof Petercam) will not execute orders directly, but merely transmits
them to an executing broker and/or to the brokerage department of Bank Degroof Petercam for
execution if a financial instrument trades on a liquid trading and/or its liquidity is shared among
execution venues. This generally is the approach chosen for equities, some fixed income products,
and listed derivatives. The Dealing Desk (Bank Degroof Petercam) will choose to execute orders
directly if a financial instrument primarily does not trade, or is not listed, on a securities exchange, or
in other words trades OTC This generally is the approach for Eurobonds, other fixed income products
and structured products.
Brokerage for Client Referrals
Degroof Petercam Asset Management does not currently receive any client referrals from any
broker-dealers that it uses.
Directed Brokerage
Degroof Petercam Asset Management does not permit, recommend or require clients to use directed
brokerage.
Aggregation and Allocation Practices
Client orders are executed in a prompt, fair and expeditious manner and in the order that they are
received by Bank Degroof Petercam taking into account the channel through which the order is
received. Comparable orders are executed sequentially unless the characteristics of the order or
prevailing market conditions make this impossible, or the interest of the client requires otherwise.
When aggregating client orders, Bank Degroof Petercam establishes a pre-allocation grid that will
enable a fair allocation of aggregated orders and transactions covering both volume and price
aspects. When an aggregated order is partially executed, Bank Degroof Petercam allocates the
related trades in accordance with the pre-allocation grid, and if a reallocation occurs, this may not be
detrimental to the client interest.
Bank Degroof Petercam warns that if an order is aggregated with other client orders, the effect of
aggregation may not necessarily work to the advantage of a client in comparison to an individual
order.
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Degroof Petercam Asset Management reviews and evaluates client accounts for compliance with
each client’s investment objectives, policies and restrictions. There are two levels of investment
compliance controls which are executed and monitored by different departments within the
company, with different frequencies, and covering a different scope of restrictions:
Firstly, pre-trade compliance controls are implemented in a compliance module linked directly to the
front office tool G2. This is done before the execution of the trade.
Secondly, on a daily basis post-trade compliance controls are performed through the G2 front office
tool based on the end-of-day positions of every mandate.
The frequency of the reports is determined at client discretion and depends on the individual client
contract. It can be done as frequently as daily. The content of these reports also depends on client
requirements and needs. Content and characteristics are validated prior to signing of the contract by
Degroof Petercam Asset Management mandate acceptance committee.
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Degroof Petercam Asset Management has a code of conduct that requires all dealings to be in the
best interest of our clients.
Degroof Petercam Asset Management may enter into an agreement with another registered
investment adviser where the parties recognize that a synergy exists between the services offered by
both parties and that those clients of one firm could benefit from services rendered by the other
firm. Services rendered by Degroof Petercam Asset Management include advisory or consulting
services on investment assets.
If a client of the other firm enters into an agreement with Degroof Petercam Asset Management to
perform such services, then Degroof Petercam Asset Management will pay the referring investment
adviser firm a fee agreed to by both parties. Prior to the client entering into an advisory agreement
with Degroof Petercam Asset Management, a complete disclosure will be made to the client by the
referring adviser, and a signed disclosure form will be required from the client. Fees paid to the
referring entity are included in the fee paid to Degroof Petercam Asset Management by the client
and it is generally expected that the client will not incur any additional costs related to this
relationship. However, if such costs arise, they will be fully disclosed and consented to by the client
prior to the client entering into an advisory agreement with us.
In accordance with its Code Of Conduct, Degroof Petercam Asset Management is acting in an honest,
fair and professional manner that best serves the interests of a client when, in connection with the
provision of an individual management service to this client, it pays or receives a remuneration or
commission or provides or receives a non-monetary benefit.
The remuneration, commission or non-monetary benefit paid or provided to a third party or to a
person acting on behalf of this third party or by this person, meet the following conditions:
i) the client is clearly informed of the existence, nature and amount of the remuneration,
commission or benefit or, where this amount cannot be determined, of its method of
calculation. This information is provided in a complete, accurate and understandable form
before the investment or auxiliary service in question is provided; and
ii) the payment of the remuneration or commission, or the granting of the non-monetary
benefit, improves the quality of the service provided to the client and does not affect the
company’s obligation to act in the best interests of the client.
Appropriate remunerations that allow the investment services concerned to be provided or are
necessary for this purpose, such as custody fees, foreign exchange and settlement commissions, legal
contributions and legal fees, do not lead to a conflict with the obligation the company has to act in an
honest, fair and professional manner towards its clients that best serves their interests.
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All assets owned by clients are physically held by external custodians, selected and chosen by our
clients, either held at Bank Degroof Petercam or another group entity. Clients usually receive
monthly and quarterly statements from custodian. Clients do receive, on a monthly and quarterly
basis, reporting from Degroof Petercam Asset Management regarding their segregated mandate, and
specific reporting regarding the investment guidelines (eg. Risk management reports).
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Degroof Petercam Asset Management has generally discretion over the selection and amount of
securities to be bought or sold in client accounts without obtaining prior consent or approval from
the client. However, these purchases or sales may be subject to specified investment objectives,
guidelines, or limitations previously set forth by the client and agreed to by Degroof Petercam Asset
Management in the applicable Investment Management Agreement. Discretionary authority will only
be authorized upon full disclosure to the client. The granting of such authority will be evidenced by
the client's execution of an Investment Management Agreement containing all applicable limitations
to such authority. All discretionary trades made by Degroof Petercam Asset Management will be in
accordance with each client's investment objectives and goals.
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Degroof Petercam Asset Management, as a registered investment adviser that exercises proxy voting
authority over client securities, has a fiduciary duty to vote proxies in a timely manner and make
voting decisions that are in our clients’ best interests.
Our Shareholder’s responsibility is reflected in our Proxy Voting Policy, which may be obtained on
request and free of charge by contactin
g [email protected].
Voting activity allows us to make our voice heard for the companies we invest in, thus exercising
influence to stimulate best practices in terms of corporate responsibility. We make sure the rights of
shareholders are respected, but also those of other stakeholders. We fully disclose our vision on
corporate governance within listed companies, our expectations as well as our approach as a
responsible investor. Through the United Nations-supported Principles for Responsible Investment
(PRI) Initiative, DPAM is participating in collaborative engagement initiative on the prevention of
corruption. The four principles below that govern our Voting Policy are revised on an annual basis in
order to optimally address legal and regulatory changes as well as international best practices in
terms of corporate governance:
1. Protection of shareholders aimed at creating long-term value and the equal treatment of
shareholders in accordance with the "one share, one vote, one dividend" principle and the protection
of minority shareholders.
2. Good corporate governance, which necessitates an effective and independent system of
management and control.
3. Transparency and integrity of information, which must be reliable, clear, complete and
communicated at the right time.
4. Social and environmental responsibility, which is key to the responsibility and sustainability
of companies that place their human capital at the heart of their interests and which respect, in its
totality, the environment in which they act.
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Degroof Petercam Asset Management has no financial commitment that impairs its ability to meet
contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy
proceeding.
Financial statements of Degroof Petercam Asset Management are publicly disclosed and available on
the National Bank of Belgium’s websit
e www.nbb.be .
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