Report on brokerage fees for 2022
This report is intended to meet the requirements of Article 314-82 of the General Regulation of the Autorité des Marchés Financiers (French Financial Markets Authority).
As part of managing funds, Lazard Frères Gestion uses order execution services provided by service providers. The brokerage fees incurred by service providers were in excess of €500,000 and Lazard Frères Gestion is therefore required to report on the conditions under which it has used investment decision and order execution support services. It must also report on the breakdown between (1) brokerage fees relating to the reception and transmission service and the order reception service, and (2) brokerage fees relating to investment decision and order execution support services.
Use of investment decision and order execution support services (SADIE)
In the 2022 financial year, Lazard Frères Gestion used the services of investment service providers with which it had entered into a shared commission agreement.
The objective of our policy of best selection and control policy for SADIE providers is to use the best service providers in each speciality (geographical analysis, sector analysis, analysis by capitalisation size, arbitrage, etc.).
With this in mind, we may decide between analysis provided by a sell-side department of an execution broker and analysis available from an independent research firm.
The quality of service provided by SADIE providers will be monitored and assessed by the same committee that analyses and controls execution services provided by Brokers.
The monitoring of SADIE providers and any reallocation of resources between them are carried out using the methodology described below.
Allocation of brokerage fees
Brokerage fees relate to transactions involving equities, similar instruments and futures traded as part of discretionary management and fund management activities. Lazard Frères Gestion is authorised to receive and transmit orders. Brokerage fees are therefore intended to compensate providers of investment decision and order execution support services. 62.5% of the total fee is allocated to decision-making support and 37.5% to order execution support. Fees for investment decision and order execution support services paid to third-party service providers under shared commission agreements represented 11.4% of the total amount of brokerage fees in 2022.
Investment decision support and order execution service fees repaid to third-party services providers in the context of commission sharing agreements represented 11.4% of total intermediation fees paid in 2022.
Prevention of conflicts of interest
This report must also cover the measures put in place to prevent and deal with any conflicts of interest arising as a result of the choice of service providers.
At Lazard Frères Gestion, service providers are selected twice a year at meetings of the Broker Committee, attended by a manager, fund managers, traders, compliance staff and the head of the middle office. Brokers are selected via a transparent selection process based on:
- the quality and availability of research,
- the quality of prices and the execution of orders,
- administrative processing,
- the commercial relationship (relationship with issuers).
In addition, Lazard Frères Gestion does not receive soft commissions or kickbacks on brokerage fees from its service providers.
No conflicts were detected at Lazard Frères Gestion in the 2022 financial year.
ORDER EXECUTION AND INTERMEDIARY SELECTION POLICY
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APPLICATION OF THE DODD-FRANK ACT BY LAZARD FRERES GESTION
Lazard Frères Gestion SAS does not provide any investment service, directly or indirectly, to clients or investors categorised as "US persons” (as defined by Rule 902 of Regulation S under the United States Securities Act of 1933). In addition, Lazard Frères Gestion SAS will not accept potential clients or investors:
(i) who acquire financial instruments for or on behalf of a US person or
(ii) through whom an investment service is provided for or on behalf of a US person
COMPLAINT HANDLING PROCEDURE
LFG notifies its Clients that it has a complaint handling procedure in place. To be dealt with as effectively as possible, any complaint sent by post must be addressed to the Legal Department of Lazard Frères Gestion at 25, rue de Courcelles, 75008 Paris.
Lazard Frères Gestion undertakes to acknowledge receipt of the complaint within 10 business days of receipt, unless a response is provided within that period, and to respond within two months of receipt of the complaint unless there are specific duly justified circumstances. However, if the Client is not fully satisfied with the response provided by Lazard Frères Gestion, they may refer the matter to the AMF's Ombudsman in writing (Autorité des Marchés Financiers, Service Médiation - 17, place de la Bourse, 75082 PARIS-CEDEX 02) or by filling in an electronic form on the AMF's website http://www.amf-france.org (under the heading AMF Ombudsman). The AMF Ombudsman applies a mediation charter that is available on the aforementioned website.
In relation to our brokerage activities, investors may send complaints directly to LFG Courtage by calling 01 44 13 01 11 or by sending an email to LFG.JURIDIQUE@LAZARD.FR. LFG Courtage undertakes to acknowledge receipt of the complaint within 10 business days of receipt, unless a response is provided within that period, and to respond within two months of receipt of the complaint unless there are specific duly justified circumstances. If the policyholder disagrees with LFG Courtage, they may refer the matter to the mediator at La Médiation de l’Assurance by writing to La Médiation de l’Assurance TSA 50110 – 75441 Paris Cedex 09 - France.
EXERCISE OF VOTING RIGHTS
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OWNERSHIP OF THE WEBSITE
This website and the data contained herein, such as trademarks, logos, graphics and photographs, are protected under intellectual property laws. The data may not be reproduced, disclosed to third parties, or used in whole or in part for commercial or non-commercial purposes, without the prior written authorisation of Lazard Frères Gestion. However, pages and sections of the site may be downloaded or printed on paper solely for personal use, provided that you do not delete copyright or intellectual property notices.
The name of Lazard Frères Gestion and its associated logo constitute trademarks registered by the Lazard Group. If you reproduce, delete, reuse or modify such trademarks, infringement proceedings may be brought against you.
CONFIDENCE IN THE DIGITAL ECONOMY
Lazard Frères Gestion SAS is an asset management company approved by the Autorité des Marchés Financiers (French Financial Markets Authority) under number GP 04 000068.
- Address of the establishment/registered office: 25, rue de Courcelles 75008 Paris
- Trade and Companies Register no.: PARIS B 352 213 599
- Amount of share capital: €14,487,500
- Intra-Community VAT number: FR21352213599
- Person responsible for publication: François-Marc Durand
- Website host: Lazard Frères Gestion
- Reference to the simplified CNIL declaration in the event that clients’ data is collected: no information about clients is collected via websites
In accordance with the AMF Position 2004-07, Lazard Frères Gestion SAS informs its UCITS’ unitholders and/or shareholders that it might have to communicate the portfolio composition of its UCITS to some institutional investors so that they are in compliance with their regulatory requirements regarding the Directive 2009/138/EC (“Solvency II”).
INTEGRITY AND TECHNICAL FAILINGS
The security and integrity of communications via the Internet cannot be guaranteed. Lazard Frères Gestion does not therefore accept any liability in the event of any technical failings, particularly in the event of issues encountered in accessing the website or interrupting the publication of the website.
Information about the fixed and variable compensation paid by the management company to its employees, in proportion to the investment made in the management of funds, excluding discretionary management, may be obtained by post from Lazard Frères Gestion fund legal department.
The aggregate amount of variable compensation is set by the Lazard Group based on various criteria, including the financial performance of the Lazard Group over the past year, and takes account of Lazard Frères Gestion's results.
The Executive Management team decides on the total amount of compensation to be split between fixed and variable compensation, in accordance with the principle that the fixed component of compensation is absolutely separate from the variable component.
The aggregate amount of variable compensation must not be such that it prevents the Lazard Group and Lazard Frères Gestion from strengthening its capital position when necessary.
All risks and conflicts of interest are factored into the calculation of the aggregate amount of variable compensation.
The amount of variable compensation is then individually calculated and is, in part, based on the performance of each Identified Employee.
The Executive Management team supervises the calculation of individual compensation amounts via an individual assessment form, which is used in the annual appraisal interview.
The annual individual assessment criteria are used to determine the suitability of Identified Employees for the positions they hold, to take their expertise into consideration and to assess their reliability and autonomy.
This assessment is used to report on the achievement of targets over the past year and to accordingly set future targets.
The compensation policy encourages rigorous and effective risk management in the area of sustainable development. As such, the assessment of Identified Employees takes account of both financial risks and also sustainability risks.
The compensation policy is reviewed each year.
Each year, Lazard Frères Gestion's the committee responsible for monitoring compliance with the compensation policy, made up of two members independent of the management company, is responsible for issuing an opinion on the application of the compensation policy and on its compliance with applicable laws.