Regulatory information:
Procedure for selecting intermediaries and executing orders
Qantara Asset Management has defined a Best Selection and Best Execution Policy in the interests of its clients (policy for managing Best Execution and Best Selection obligations and reporting on intermediation fees). This policy takes place within the framework of Directive 2004/39/EC of 21 April 2004 "MIFID Directive" reinforced by Directive 2014/65/EC of the European Parliament and of the Council of 15 but 2014 "MIFID 2") and the deregulation of financial markets, putting an end to the obligation for financial intermediaries to imperatively transmit their clients' stock market orders on a regulated market.
Conflicts of interest management policy
In accordance with the regulations in force, Qantara Asset Management has established a (policy for the prevention and management of conflicts of interest) to ensure the protection and primacy of its clients' interests
A conflict of interest is any professional situation in which the independence or integrity of a person, company or organization may be influenced or impaired by personal considerations or by pressure from a third party.
Remuneration policy
You will find below the document concerning Qantara Asset Management's remuneration policy.
Voting policy
Although its investment strategies mainly involve interest rate products and index futures, Qantara Asset Management has drawn up a voting policy setting out the rules it intends to apply to its participation and voting at general meetings of portfolio companies.
In accordance with its voting policy, Qantara Asset Management did not exercise the voting rights attached to the shares it held during the 2022 financial year.
Claim
Qantara Asset Management has drawn up an information note on how to handle complaints.
What is a claim?
A claim is a statement of dissatisfaction made by a client to Qantara Asset Management.
A request for service, information, clarification or advice is not a claim.
Personal data policy
We are committed to respecting your privacy and protecting your personal data. This Policy informs you on the conditions under which Qantara Asset Management collects, processes, stores, archives and deletes the personal data of its prospects and clients. It also informs you on the rights you have with regard to your data.
What is personal data?
It is any information that directly or indirectly identifies a natural person (e.g. name, address, registration number, telephone number, photograph, date of birth, IP address, fingerprint, etc.).
What categories of personal data does Qantara Asset Management process?
The following categories of personal data are mainly processed as part of our contractual or commercial relationship:
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Declarative personal data: i.e. data that we may collect directly from you or indirectly from third parties with whom we have a contractual relationship;
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personal data from public information (public part of social networks for example) in compliance with regulations;
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personal data inferred or calculated by Qantara Asset Management
What are the purposes and grounds for collecting your personal data?
We process personal data for the purposes and on the grounds listed below:
Sales prospecting
We can only prospect you by electronic means if we have obtained your prior consent, except where authorized by law. However, you may exercise your right to object by sending an e-mail to the following address: service.clients@qantara-am.com
Who are personal data processed by Qantara Asset Management’s recipients?
We are bound by professional confidentiality with regard to personal data communicated to us. However, by sending us your personal information, you allow us to share the banking secrecy on this data, for the aforementioned purposes, for the benefit of Qantara Asset Management.
Thus, in the event of a transfer of funds and in accordance with EC regulation 1781 of 15 November 2006, some of your personal data may be transmitted to the beneficiary’s bank located in a country within or outside the European Union. In order to carry out transfer orders, technical requirements may lead to data being transferred outside the European Union, in particular to the United States, in the case of transactions using the SWIFT secure network. The holder may obtain any information concerning this transfer by consulting the "Information notice" available on the Fédération Bancaire Française’s website (www.fbf.fr).
We are not responsible for any processing of your personal data that you may have authorized with third parties and that is not shared with us, such as bank account aggregation applications or social networks. It is your responsibility to refer to the data protection policies of these third parties to check the conditions of the processing carried out or to exercise your rights in respect of such processing.
Which security measures have been implemented by Qantara Asset Management?
Financial market regulations require us to ensure a high level of security and confidentiality with regard to your personal data. In this respect, we consider that all data concerning you are confidential data subject to professional secrecy to which we are subject. This data may be transmitted, used or stored in accordance with the security framework described below.
Given the nature of personal data and the risks involved in processing it, we take technical (e.g. data encryption), physical (e.g. building access control) and organizational (e.g. dedicated teams trained in information security) measures necessary to preserve data’s security and prevent it from being distorted, damaged, made inaccessible or accessed by unauthorized third parties. To guarantee this level of security, additional security measures may be required, such as audit trails.
We make our employees aware of the importance of protecting personal data and ensure that they comply with the regulations in force and with our company's code of ethics.
We choose subcontractors or service providers who offer a high level of guarantees that they will implement appropriate technical and organizational measures so that the processing of your data meets the requirements of the applicable regulations on the protection of personal data.
If we become aware of an incident with an impact on personal data, we will, in accordance with the regulatory framework, notify the Commission Nationale Informatique et Libertés (CNIL) as soon as possible after becoming aware of the incident and inform the persons concerned.
How long is your personal data kept?
We have defined precise rules for personal data’s retention.
To determine these periods, we take into account the different purposes for which the data is collected, persons concerned by the collection, and compliance with legal, regulatory or professionally recognized obligations to which we are bound. These do not exceed what is strictly necessary for the processing’s proper performance.
What are your rights?
You have the right to access, rectify, object, limit, delete and port your personal data. You also have the right to define instructions concerning the conservation, deletion and communication of your personal data after your death. Finally, you have the right to complain to the Commission Nationale Informatique et Libertés (CNIL).
How can you exercise your rights?
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Permission to access
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Right of rectification
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Right to object (particularly to prospecting)
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Right to deletion (or the right to be forgotten)
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Right to portability
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Right to limitation (1)
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The right to define instructions on what should happen to your data after your death
(1) For this right, please indicate which processing is concerned and what is the reason for your request
By post to the following address:
Qantara asset management, 44 bis rue pasquier
75008 paris
or by e-mail at the following address: service.clients@qantara-am.com
When you exercise your right to portability, we will return declarative data, i.e. data that we may collect directly from you or data collected indirectly from third parties with whom Qantara Asset Management has a contractual relationship. Data relating to the operation of products and services, personal data obtained from public information and personal data inferred or calculated by Qantara Asset Management will not be returned.
If you wish to exercise your right to object, you may do so in the case of processing based on legitimate interests or on a mission of public interest, explaining specific reasons justifying your request. Please note that you may exercise your right to object to prospecting at any time without having to justify your request.
In certain circumstances, your request for the right to be forgotten may not be granted. For example, if you still have a contract with one of our establishments and data retention is necessary for the performance of that contract, or if we are required by law to retain your data beyond the duration of the contractual relationship.
Publication date: 31 March 2023