As a subsidiary of Banque Fédérative du Crédit Mutuel (the main shareholder), Crédit Mutuel Asset Management benefits from this affiliation to the resources and financial strength of Crédit Mutuel Alliance Fédérale, a mutualist group committed to respect for its values and ethics.

Crédit Mutuel Asset Management establishes its remuneration policy within the framework of Crédit Mutuel Alliance Fédérale principles (see the Banque Fédérative du Crédit Mutuel website, in the Investor Relation section, subsection Regulated / Financial Information), while respecting regulatory requirements. Crédit Mutuel Alliance Fédérale has set up a single remuneration committee, whose scope extends to all of its subsidiaries.

As a reminder, the remuneration policy applicable to investment fund managers is governed by Directives 2014/91/EU of 23 July 2014 (UCITS V) and 2011/61/EU of 8 June 2011 known as the AIFM Directive and their transposition texts.

A - Operational Process

The Caisse Fédérale de Crédit Mutuel's Board of Directors is responsible for approving and respecting the remuneration policy and overseeing its implementation. The Board of Directors adopts and regularly reviews the general principles of the remuneration policy presented to it by the Remuneration Committee.

Caisse Fédérale de Crédit Mutuel's Remuneration Committee conducts an annual review of the remuneration policy principles and expresses its opinion on the executive management's proposals drawn up after consultation with the Risk and Compliance Department. It is composed of six directors, including one employee director. In addition, representatives of the General Secretariat, the Human Resources Department and the Risk Department of Crédit Mutuel Alliance Fédérale.

The remuneration policy aims to comply with the economic strategy, objectives, values and interests of the assets under management and those of the investors, and includes measures to avoid conflicts of interest. Therefore, this policy does not encourage inadequate risk taking with regard to the guidelines of the management company and the expectations of investors. The identified staff are subject to specific responsibilities with regard to compliance with risk rules and compliance, in particular, in the implementation of sustainability risk integration policies (see the policy on the Crédit Mutuel Asset Management website).

For 2022, Crédit Mutuel Asset Management monitors the following components relating to its Remuneration Policy:

  • Compliance with Sectoral exclusion policies (coal, defence and security),
  • Compliance with the exclusion of controversial securities.

Not complying with these obligations could bring about a reduction in the allocation of individual variable remuneration.

The remuneration rules are documented including the decision-making process, the determination of identified personnel, and the measures used to avoid conflicts of interest. These remunerations are based in particular on the following criteria: the performance of the fund(s) managed by the employee, the individual's contribution to the company's activities and compliance with risk and compliance rules.

Crédit Mutuel Asset Management's investment and risk monitoring processes are also governed by ad hoc committees. Accordingly, all management functions operate on the principle of Investment Committees. The latter meet with differing frequencies and their purpose is to define, under management, the permitted allocation of assets. Their management activity is supervised by first-level control, particularly by their hierarchy both in terms of investment (including the Policy for integrating sustainability risk) and compliance with ratios. In addition, risk control, as well as permanent control and compliance, ensure the monitoring of positions taken and compliance with internal procedures and the regulatory framework.

Therefore, this operational framework only allows managers to take limited risk. Furthermore, Crédit Mutuel Asset Management does not engage in any speculative management for its own account and requires immediate liquidation of the positions in the event of an error.

B - Identified personnel

Crédit Mutuel Asset Management has identified risk takers according to two criteria:

  • Role and responsibility of those involved in order to determine risk takers at the level of the Management Company and the UCITS/AIFs managed,
  • Remunerations in order to determine the personnel that, given their remuneration, should be considered as risk takers.

Identified personnel include:

  • the Chief Executive Officer, the Deputy Chief Executive Officer, the Chief Investment Officer, and the managers responsible respectively for: the Management division, the Responsible and Sustainable Finance division, the Legal & Finance Department, the Distributor Relations Department, the Risk Department, the Support Services Department, the Human Resources Department and the Compliance and Internal Control Officer (Responsable de la Conformité et du Contrôle Interne, RCCI),
  • the employees assigned to the collective management of Crédit Mutuel Asset Management: the portfolio managers.

C - Remuneration

Among the identified personnel of Crédit Mutuel Asset Management, some employees receive discretionary bonuses in addition to their fixed remuneration. These are primarily portfolio managers and executive management. To limit risk taking, the discretionary remuneration arrangements should allow for performance and risk to be taken into account. In any event, risk management, ethical compliance and the interests of the client should outweigh financial performance.

Crédit Mutuel Asset Management may decide not to grant such discretionary bonuses if circumstances so justify. In particular, these individual bonuses may be reduced or brought to zero under certain circumstances, particularly in the event of damage to the interests of clients or a confirmed violation of ethics. The payment of a guaranteed bonus is exceptional and applies only in the case of hiring a new staff member and is limited to the first year.

Discretionary bonuses are paid in March of the year (n+1) when visibility for year (n) is available.

These bonuses are limited to a unit annual amount of €100,000 and are not subject to deferral. In the event of a revision of the remuneration policy allowing for the payment of discretionary bonuses in excess of €100,000, Crédit Mutuel Asset Management would inform the AMF in advance and bring its remuneration policy into compliance with the UCITS V and AIFM directives, in particular by providing for the conditions for the spreading of bonuses over a minimum period of three years.