General Statement – Regulatory Information
At Arvella Investments, we understand and respect the importance of your privacy. The Firm has implemented a data protection system and is compliant with the EU General Data Protection Regulation (2016/679). Arvella Investments Limited is compliant with the UK Data Protect Act 2018
All the content of the website is the property of Arvella Investments s.a.s. and Arvella Investments Limited, jointly referred to as Arvella Investments. The information displayed on this website could be updated and modified at any time. Any copy, reproduction, partial or complete dissemination, or any other use of the website’s content, regardless the processing, is not authorised, except with the prior written consent of Arvella Investments.
In accordance with the law n˚78-17 of 6 January 1978 relating to information technology, files and freedom, and the General Data Protection Regulation (Regulation n˚2016/679), you have the right to access, withdraw, rectify and erase all the data containing information on you. You can use your rights by contacting us at Arvella Investments, 50 rue de Monceau, Paris 75008.
Conflicts of Interest
Arvella Investments has a conflict of interest policy which describes the measures we take in order to detect and manage the situations that could give rise to a potential conflict of interest. For more information, please contact us at firstname.lastname@example.org.
Exercise of Voting Rights
Arvella Investments has a voting rights policy which describes the conditions regarding the exercise of voting rights attached to listed securities managed by Arvella Investments. For more information, please contact us at email@example.com.
Client Complaint Handling
Arvella Investments has put in place a procedure in order to address client complaints. A client complaint refers to an expression of dissatisfaction of a client against Arvella Investments.
Your complaint will be handled by Arvella Investments’ Chief Compliance Officer according to the following timeframes:
i) Acknowledgement of receipt of complaint no later than 10 working days from the day the complaint was received, unless the answer is already provided to you within this timeframe.
ii) Provision of an answer to you no later than two months after the reception of the complaint, unless exceptional circumstances justify extending this timeframe.
The handling of the complaint by Arvella Investments is free of charge. You will not incur any (administrative, research or other) fees in relation to the handling of the complaint. All claims must be addressed to Arvella Investments. You can also address your complaint to the Ombudsman of the Autorité des Marchés Financiers (AMF) in case of a disagreement relating to a product or service in her competence, at the following address: Le Médiateur – Autorité des Marchés Financiers, 17 place de la Bourse, 75082 Paris, France.
Client complaints in the UK should be made by contacting the Compliance Officer of Sapia Partners LLP at Paul.Cowland@iqeq.com or by writing to Paul Cowland, IQEQ, 4th Floor 3 More London Riverside, London, SE1 9RA. You may also be eligible to refer your complaint to the Financial Ombudsman Service free of charge.
Prohibition of Financing of Cluster Munitions
France is a signatory party of the Ottawa Convention of 3 December 1997 on the prohibition of the use, stockpiling, production and transfer of anti-personnel landmines, and of the Oslo Convention of 3 December 2008 on the elimination of cluster munitions. With regard to these conventions, in April 2013, the AFG (Association Française de Gestion Financière) issued its recommendations on the prohibition of financing of financing of anti-personnel landmines and cluster munitions, outlining that asset management companies have to implement a policy for the exclusion of companies involved in cluster munitions and anti-personnel mines. Arvella Investments respects the Conventions and the AFG recommendations, and excludes the companies involved in cluster munitions or anti-personnel mines through their development, production, use, maintenance, sale, distribution, importing or exporting, stockpiling or transportation.
Selection of Intermediaries
Arvella Investments has a best execution policy in place setting out the conditions for the selection and evaluation of financial intermediaries. For more information, please contact us at firstname.lastname@example.org.
Compliance with article 173 of French energy transition law
We take climate change into account in client mandates in the following ways:
• We measure the climate alignment of each fund and client’s portfolio. We developed a climate alignment metric with environmental engineers from I Care & Consult (see “Fighting Climate Change as a Global Equity Investor,” Journal of Asset Management, 2020 — https://link.springer.com/article/10.1057/s41260-020-00150-9). In addition, we analysed other climate data sources. In particular, we subscribed to the Carbon Disclosure Project’s climate dataset. We review available climate data each year to ensure we always use the most advanced metrics. We also analyse how exposed our portfolios are to financial losses related to climate change [Potential climate financial losses are related to but are different from climate alignment. Potential losses are how much an investor might lose if/when climate change materialises. Climate alignment is how much an investment contributes to climate change].
• In August 2020, we lent our methodology to seed a new climate-aligned global equity strategy managed by a third-party manager.
• Moreover, we stress Environmental criteria (alongside Social and Governance ones) when investing in index funds. We developed an analytical framework to assess how well index funds promote sustainable outcomes (see, “Promoting Sustainability using Passive Funds,” The Journal of Index Investing, 2019 —https://www.iijournalseprint.com/JII/ArvellaInv/Fall19PromotingSustainability30r/index.html).
• We developed a portfolio optimiser incorporating climate impact. Traditional portfolio optimisers help find the best trade-offs between financial risk and return. We developed portfolio optimisation tools that help find the best risk, return and climate impact trade-offs.
• We encourage investee managers to fight climate change. We also signed up to ShareAction’s Investor Decarbonisation Initiative. This initiative brings together institutional investors to encourage companies to set ambitious climate targets in line with goals of the Paris Agreement. The initiative delivers coordinated company engagement, promoting proactive emissions reductions at the rate required to avoid dangerous climate change.
In addition, we promote climate change in our government bond fund, the EUR Long-term Government Bond Portfolio. The fund invests in government bonds while promoting ESG. We select bonds from countries with the healthiest governance as reflected in low debt levels and better budget balances. We then favour green bonds over traditional ones when available.
Compliance with article 5 of the Sustainable Finance Disclosure Regulation
Under Article 5 of the Sustainable Finance Disclosure Regulation, Arvella Investments has incorporated criteria on the integration of sustainability risks into its Remuneration Policy. This involves assessing employees’ adherence to sustainability criteria when assessing any increases in remuneration and any variable remuneration to be awarded.
50 rue de Monceau
Authorised and regulated in France by the Autorité des Marchés Financiers (“AMF”)
Arvella Investments Limited
42 Brook Street
London W1K 5DB
Appointed Representative of Sapia Partners LLP, which is authorised and regulated in the UK by the Financial Conduct Authority (“FCA”).