Legal Notices

Investment policy and ESG (Environmental, Social and Governance) criteria

Article 173 of the French Energy Transition Act asks asset management companies to publish information on how Environmental, Social and Governance (ESG) criteria are taken into account in investment and risk management policies.

The investment policies followed by Delubac Asset Management’s directly managed equity and fixed income funds and its indirectly managed (multi-manager) funds do not simultaneously and automatically take account of the three areas – Environmental, Social and Governance – that make up a Socially Responsible Investing (SRI)approach. This is because the external research available on ESG criteria is not sufficient to cover the entire investment universe at Delubac Asset Management, in particular for its global diversified multi-manager funds, which invest across all categories of assets.

Furthermore, as each of the funds managed by Delubac Asset Management has assets under management of less than €500 million, the management company is not required to publish a report for these funds that outlines how ESG information is taken into account.

However, in view of investors’ growing interest in Socially Responsible Investment, Delubac Asset Management periodically appoints an external provider with expertise in this area to analyse its two directly managed funds. All investments in these portfolios are rated in each of the three areas and an overall ESG quality rating is given to the investments made. This rating is communicated directly to investors in the monthly fund reports and the ESG non-financial rating reports are available upon request for investors who have expressed an interest in this measurement of the ESG quality of fund management.

Independently of French regulations on ESG criteria, Delubac Asset Management has been a signatory to the UN Principles for Responsible Investment (PRI) since December 2021.

Voting rights:

In accordance with the regulations in force (General Regulation of the Autorité des Marchés Financiers - AMF), Delubac Asset Management has established a voting policy that sets out how intends to exercise the voting rights attached to the securities held by the UCITS it manages.

Voting policy:

Download the Voting Policy document 

Report on the conditions for exercising voting rights:

Download the 2020 report on the exercise of voting rights

Policy for managing conflicts of interest:

A conflict of interest is a situation in which, in the performance of its activities, the interests of Delubac Asset Management and/or its employees and/or its clients who are principals or hold securities are in direct or indirect competition.

In accordance with the regulations in force, Delubac Asset Management has a conflict of interest management policy in order to take all necessary measures and procedures to detect and manage conflicts of interest in the context of its business.
To this end, in view of its size, its organisation and the nature of its business, Delubac Asset Management has mapped conflicts of interest to ensure the protection and primacy of the interests of clients as well as a respect for market integrity.

However, in cases where it is impossible for Delubac Asset Management to manage a conflict of interest, Clients will be informed immediately before any action is taken on their behalf.
Clients may obtain additional information on Delubac Asset Management’s policy for managing conflicts of interest by submitting a request to its advisor.

Register of conflicts of interest:

Conflicts of interest that have occurred or may occur are recorded in a register in accordance with the provisions of the AMF General Regulation.

Best execution and best selection policy:

Pursuant to the European Markets in Financial Instruments Directive (MiFID), this document sets out Delubac Asset Management’s policy on order execution and the selection of market intermediaries.

Download the Best Execution/Selection Policy document

“RTS” report:

The “RTS 28” report sets out the expected requirements to increase the quality and transparency of information available for professional and non-professional investors regarding orders transmitted or executed. 

Download the “RTS 28” report

Remuneration policy:

Download the Delubac Asset Management remuneration policy 


Delubac Asset Management is committed to providing you with the best quality service at all times. However, you may occasionally experience difficulties in the operation of your account or in using the services provided to you.
In the event of a complaint, you can contact our Quality Department at the Banque Delubac & Cie Group free of charge:
- at the following email address: [email protected]
- by calling +33 (0)4 75 29 49 88 (non-premium number)
- or by sending a letter to the following address: Banque Delubac & Cie - Service Qualité - 16 place Saléon Terras, 07160 Le Cheylard, FRANCE

If the dispute cannot be resolved and if it falls within its jurisdiction, you may refer the matter to the AMF Ombudsman free of charge by:
- Completing the mediation request form on the website />- Or by sending your request by post to the following address:

Autorité des Marchés Financiers
La médiation
17, place de la Bourse
75082 Paris cedex 02, FRANCE