UBP Asset Management (France)

We are authorised to offer the following services and carry out the following activities:

• Managing UCITS funds
• Managing alternative investment funds (AIF)
• Managing assets through mandates
• Providing investment advice
• Marketing collective investment instruments managed or promoted by the Group
• Providing advice on investments and civil mandates in real estate

Our role within the UBP Group

• We have been the UBP Group’s asset-management company in France since 1998.
• We are the Group’s centre of expertise for convertible bond management and real estate investment advisory services*.

*and as such we hold professional civil liability insurance in accordance with applicable regulations

• We handle the marketing of the UBP Group’s products and expertise in France*, in particular the Luxembourg SICAV called “UBAM”.
• We bring together a management structure and skill set that respond to the unique requirements of French institutional investors thanks to our team of around twenty people who are dedicated to institutional asset management.
• We are well established in France with around 100 institutional clients worth a total of some EUR 2.7 billion, and with some EUR 2.2 billion** in assets under management.
• In 2021 we joined the Forum pour l’investissement responsable (FIR), a founding member of the Eurosif network.

* This business may generate retrocessions on part of the fees charged by the UCITS.
** As at 31 December 2023.

Responsible Investment at the UBP Group

The UBP Group signed up to the United Nations Principles for Responsible Investment (UNPRI) in March 2012. Its first Responsible Investment Policy (RI Policy) was published in 2014 and considerably broadened in 2018. Since then UBP has been gradually developing the policy to encourage and strengthen the incorporation of environmental, social and governance (ESG) criteria into its investing.

In particular, at UBP Asset Management (France) we manage convertible bond strategies according to proprietary responsible investment principles. Investors are also provided with ESG reporting as per regulations and specifically in application of Article 29 of the French energy & climate law.

Scope of application

As per the UBP Group’s internal directives, its RI Policy (including exclusion lists and controversy monitoring) applies to all the convertible bond strategies of the UBAM SICAV. In addition to the Group’s RI Policy, funds can opt to apply specific, stricter, exclusion and inclusion criteria.

Other collective investment schemes our French entity manages are (i) reserved funds, for which the RI Policy must be approved by the investors, or (ii) funds whose management we have delegated, in which case the investment policy that applies is that of the third-party manager.

Voting policy

As per applicable regulations and UBP’s internal directives, we have implemented a voting policy suited to our activities. This policy stipulates the circumstances in which we intend to exercise the voting rights that come with ownership of shares in the UCITS we manage.

• Voting policy
• Implementation of the Shareholder Rights Directive 2

The report on the exercise of voting rights for funds managed by us is also available upon request.

The EU’s Sustainable Finance Disclosure Regulation (2019/2088)

With ambitions climate-protection and energy-transition targets, the European Union has issued the Regulation on Sustainability‐Related Disclosures in the Financial Services Sector (known as SFDR).

Sustainability risk

Sustainability risk is defined in the SFDR as “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.” When providing our services and products, we assess all the relevant financial risks, including sustainability risks. Click here for more details on UBP’s sustainability risk management framework.

Impact of sustainable finance regulations on remuneration

Our remuneration structure discourages excessive risk-taking with respect to sustainability by being linked to risk-adjusted performance.

In this respect, the Bank’s objective is to provide more transparency, in both qualitative and quantitative terms, on these factors and to promote sound and effective sustainability practices and sustainability risk management. To ensure that employees take into account sustainability risks and opportunities, the Group has incorporated into its remuneration policy certain sustainability objectives which aim to promote responsible investment and corporate social responsibility (CSR).

The Remuneration Policy is available in the regulatory information below.

Principal adverse impacts

UBP acknowledges the responsibility of the financial industry to limit the adverse impacts on sustainability factors, such as the environment, social and employee matters, human rights, and matters of anti-corruption and anti-bribery, resulting from specific investment decisions.

In acknowledging this, UBP’s EU-based asset management entities (herein UBP AM*) seek to consider and manage the adverse sustainability impacts of their investment decisions, in line with EU regulation 2019/2088, or Sustainable Finance Disclosure Regulation (SFDR).

UBP AM* primarily relies on its Responsible Investment Policy, which outlines the key principles applicable to all our funds and mandates** (subject to the end investor’s approval), to assess and manage these adverse sustainability impact.

These principles include the negative screening of controversial activities and practices, the promotion of ESG integration in investment processes, as well as active ownership through engagement and voting. Alongside our Responsible Investment Policy, UBP AM* actively considers all principle adverse impacts (PAI) from Table 1 of Annex I of Regulation (EU) 2019/2088 (SFDR) – so called “mandatory” PAIs – as well as two additional “voluntary” PAIs (one from Table 2 and one from Table 3 of Annex I of Regulation (EU) 2019/2088 (SFDR).

Below are some examples of the intersection of our PAI commitment and our policies.

As a minimum standard, UBP AM identifies and mitigates principal adverse impacts through the application of its Exclusion List. The list covers activity-based exclusions with a high occurrence of adverse impacts such as controversial weapons (mandatory PAI n° 14).

Additionally, we monitor companies that violate the UN Global Compact and OECD Guidelines for Multinational Enterprises (mandatory PAI n° 10) and manage them through various approaches such as exclusion or systematic engagement via a third-party service, based on the product’s strategy.

To align with our values, we also reduce exposure to certain fossil fuels, applying revenue thresholds on companies highly involved in coal or unconventional oil & gas (depending on the product appetite for sustainability), which can notably help to mitigate the adverse impacts of greenhouse gas emissions (Table 1, PAI 1-5).

For example, as a result of our exclusion policy, all of our funds exclude companies heavily involved in coal extraction and some products commit to offer a lower carbon footprint that their investment universe. These actions help manage our impact in terms of greenhouse gas emissions, which correlates to mandatory (mandatory PAI n° 1-5). More details on criteria and scope are available in UBP’s RI Policy.

Furthermore, this focus is complemented by our being a signatory of Net Zero Asset Managers Initiative, in which UBP AM is committed to reducing the carbon emissions of its portfolios and to encouraging investments in climate solutions to reach net zero emissions by 2050 or sooner.

Our biodiversity approach also aims to help our investment teams identify and manage the potential adverse impact of their investments on nature and ecosystem services, such as those resulting from activities negatively affecting biodiversity-sensitive areas (mandatory PAI n°7).

Furthermore, we consider voluntary PAI based on their potential applicability to a majority of issuers rather than specific sectors, and the availability and quality of data. Taking these factors into consideration, we have opted to concentrate on PAI 7 from Table 2 (companies lacking water management policies) and PAI 9 from Table 3 (companies without human rights policies) due to their broad coverage and universal relevance across investment universes.

We acknowledge that some PAIs are still lacking in terms of data coverage and/or data quality. This would be the case for instance for mandatory PAI 6 (Energy consumption intensity per impact sector), PAI 8 (Emission to water) or PAI 12 (Unadjusted gender pay gap) among others. For those, PAI consideration will have more indirect impact on investment decision as it will be conducted through wider ESG analysis and integration, as well as controversy monitoring and management. The expansion of non-financial reporting requirements should lead to the disclosure of more information on this indicator in the coming years. Therefore, we will continue to monitor these PAIs to eventually be able to consider them direct when data becomes more widely available.

Furthermore, our article 8 and 9 product range apply even stricter ESG considerations. They focus on reducing exposure to environmentally or socially harmful activities whilst also favouring companies with sound ESG practices or those providing solutions to environmental and social challenges.

UBP also consider PAIs through its stewardship activities. As an active investor, UBP exercises its voting rights and promotes sustainability principles through its proxy voting policy, which, for instance, promotes Board gender diversity (PAI 13). Moreover, we engage either collaboratively or directly with investee issuers to address environmental or social concerns and encourage companies to improve their ESG practices.

UBP AM also believes that the financial sector should work together with other stakeholders such as investors, the corporate world, NGOs, or academia to tackle the world’s sustainability challenges. Accordingly, UBP has partnered with, is a signatory to, or supports an array of global and local initiatives and associations and adheres to various international standards promoting sustainability, including the UN Principles for Responsible Investing (UN PRI) and the UN Global Compact (UNGC).

We are conscious that the consideration and mitigation of the principal adverse impact of our investment decisions is a long-term objective as it may initially be constrained by the limited availability of data on some of these PAI indicators.

UBP AM* thus commits to putting every effort into obtaining the necessary information from its investee companies as well as from external data providers and to enhance its PAI consideration approach over time.

Finally, in line with the SFDR, UBP AM* is committed to report annually on the principal adverse impacts resulting from its investment decisions as well as on actions taken and planned to mitigate such impacts.

Further details can be found in the Responsible Investment Policy.

*The present statement is the consolidated principal adverse sustainability impacts statement of UBP Asset Management (Europe) S.A. and UBP Asset Management (France).
** Applies only to UBP Asset Management (France).

Regulatory information

Intermediation Cost Report 2023 (not applicable as intermediation costs were below EUR 500 000 in 2023)

Fraudulent Website Notification

Union Bancaire Privée, UBP SA ("UBP" or “the Bank”) would like to alert all clients and the public to fraudulent websites detected by UBP listed below. UBP would like to advise that these websites have no affiliation or connection whatsoever with the Bank.

UBP has taken action deemed necessary and appropriate to protect the interests of its customers, the general public and the Bank. Any clients who have provided personal information or have conducted any financial transactions through these websites, are kindly requested to immediately report to the local Police and to contact their UBP relationship manager or Union Bancaire Privée, UBP SA at +41 58 819 21 11.

*AMF