This website is edited by Exclusive Partners, a simplified joint-stock company with a share capital of €833,300 whose headquarters are located at 124 boulevard Haussmann, 75008 Paris, France. Commercial and Companies Registry (RCS) PARIS – Business Identification Number (SIRET): 518 935 713 000 17 – Activity Code (APE): 7022Z EU VAT Numboer: FR 25 51 89 35 713 Legal representative of the website and Publication Manager: Philippe Brosse
Legislation and Hosting
The Website was designed in France and is also hosted in France by AIMS Informatique, 68, rue de la Croix de l’Orme, 78630 Morainvilliers (firstname.lastname@example.org). The hosting Conditions are governed by French legislation.
In the case of a dispute concerning the application or interpretation of the Conditions or more broadly concerning the use of the Website by any individual or legal entity, it is expressly agreed that the French courts shall have sole jurisdiction, even in proceedings involving multiple defendants or the introduction of third parties.
This website was developed by FinDiT Consulting.
Conditions for Access and Use
The Website is free and open. The Editor reserves the right however, to restrict access to all or part of this Website unilaterally and without prior notice. Access to the products and services presented on this website may be restricted in relation to certain persons or in certain countries. None of the products and/or services shall be provided by Exclusive Partners to a person if the laws of that person’s country of origin or any other country concerning that person prohibits this. However, it is up to all interested parties to check beforehand with their usual advisers that their legal and fiscal status allow them to subscribe to the products and/or services presented on the website.
The information, tools and content of the website are presented for illustrative purposes only. Exclusive Partners endeavors to regularly update the information contained on the website. However, the company shall in no case be held responsible for errors due to changes in legal, administrative or judicial provisions that may occur after publication on the website. The web user is solely responsible for the use made of the information gathered.
Exclusive Partners shall in no case be held responsible for the hypertext links to other websites or any other resource existing on the Internet from this Website.
Use of the Website and of the information contained therein is therefore the sole and entire responsibility of Users.
Consequently, the Editor, its partners, employees or any other party involved in the creation and exploitation of this Website shall not be held liable for any loss or damage, either direct or indirect, of whatever nature, resulting from the access, use (even partial), or interpretation of the information on this Website.
Data Protection Act and Protection of Personal Data
Exclusive Partners has set up a personal data protection policy and is committed to processing these data in such as way as to preserve their security, confidentiality and integrity, and to comply with the provisions of current regulations, with the General Data Protection Regulation (GDPR) and with the Data Protection Act (see our data policy)
Declaration to the French Data Protection Authority (CNIL)
In compliance with the Data Protection Act of 6 January 1978, Exclusive Partners has made a declaration to the CNIL regarding its possession of information collected on this website.
Collection of personal data
No personal data shall be collected or diffused on the Website without the User’s knowledge.
The User authorizes the Editor to install one or several cookies relative to the User’s browsing activities on the computer being used. These cookies are as follows :
- Website function cookies: the website cannot function without these.
- Visitor statistics cookies: these cookies measure how many visitors use the site and this allows us to improve our functionalities.
- Partner Portal connection cookie: this cookie allows the User to connect to their customized section.
The User can prevent the installation of cookies, namely in the functionalities proposed by the following navigators: Internet Explorer, Netscape Navigator, Mozilla Firefox and Opera.
The web user has the right to access, rectify and delete as well as to oppose the processing of data concerning them. To exercise this right, the user can send a letter to the company along with a photocopy of their ID card to the following address: Exclusive Partners, Data protection, 124 boulevard Haussmann, 75008 Paris. The user can also send an email to RGPD@exclusive-partners.com Under no circumstances shall the information collected on the website be sent to third parties.
Recordings of telephone conversations
For the purpose of transparency of the transactions carried out as part of approvals and authorizations issued to Exclusive Partners, telephone conversations with our services are recorded. In compliance with the General Data Protection Regulation, you have the right to access, rectify and oppose in relation to any of your personal data by sending a letter to the company along with a photocopy of your ID card to the following address: Exclusive Partners, Data protection, 124 boulevard Haussmann, 75008 Paris. You can also send an email to RGPD@exclusive-partners.com.
Ownership of the Website and its Content
Protection of the website content
All intellectual property rights on the Website and its content (hereinafter referred to as ‘Content’) which is mainly made up of texts, databases, software, applications, slides, logos, images, drawings and graphics are the property of the Editor or of third parties having authorized to Editor to exploit them.
All of this Content is therefore protected by French and international legislation in particular and this may include copyright, protection of drawings and models, of brands and of databases.
The names and brands mentioned on the Website are trademarks registered by the Editor or its rights-holders. Any reproduction, imitation and more generally exploitation of these brands is forbidden.
Use of the Website
This Website is for the exclusive personal and private use of the User. The Editor therefore only grants the User authorization to view the Website. The User can however, retrieve or print on paper some pages and/or parts of the Website, strictly for their own personal use, provided that they do not delete any references to copyright or intellectual property rights.
Any other use (particularly any reproduction, representation, modification, adaptation, distribution for commercial purposes, whether or not for profit) is strictly forbidden unless they receive the prior written agreement of the Editor.
As the Editor is the producer and owner of all or part of the databases present or used on the Website, it is strictly forbidden, for example, to extract and use all or part of the database content featuring on the Website.
Legal Status – Regulatory Information
Exclusive Partners is an Investment Service Provider (ISP) under French law approved on 15 January 2010 by the French Prudential Supervision and Resolution Authority (ACPR) to provide services in Investment Consultancy under the number 19173. Under the MiFID II directive, Exclusive Partners has chosen to provide a ‘non-independent’ investment consultancy service and on this basis may receive retrocession fees or any other monetary and non-monetary benefit from financial instrument providers under the conditions provided for in Article L.533-12-4 of the French Monetary and Financial Code.
Since 18 April 2012, this approval has been extended to the RTO department. Exclusive Partners is under the joint supervision of the ACPR and the Financial Markets Authority (AMF), whose respective addresses are as follows :
Autorité de Contrôle Prudentiel et de Résolution
Postal address: 4 Place de Budapest CS 92459, 75436 Paris, France
Autorité des Marchés Financiers
Postal address: 17 place de la Bourse, 75082 Paris Cedex 02, France
Exclusive Partners is member of the French Financial Markets Association (AMAFI).
Exclusive Partners is registered with the Single Register of Insurance, Banking and Finance Intermediaries under the registration number 13002792, as a Banking Transactions and Payment Services Non-Exclusive Representative (MOBSP) and an Insurance or Reinsurance Broker (COA).
Exclusive Partners uses the services of Tied Agents duly registered with the Single Register of Insurance, Banking and Finance Intermediaries (formerly registered in the Tied Agents file of the Banque de France).
Exclusive Partners also uses the services of Banking Transactions and Payment Services Intermediary Representatives (MIOBSPs) and of Insurance Intermediary Representatives (MIAs) according to the service provided. These intermediaries are duly registered with the Single Register of Insurance, Banking and Finance Intermediaries.
Single Register of Insurance, Banking and Finance Intermediaries (Orias)
Postal address: 1 rue Jules Lefebvre, 75331 Paris cedex 09, France.
Management of Conflicts of Interest
To ensure complete transparency, Exclusive Partners draws attention to potential subscribers of the fact that the financial products it has selected and for which it provides an investment consultancy service may constitute a situation of conflict of interest.
The financial product in question is :
- FCT FINEXKAP CREANCES CO N°1 managed by the asset management firm Finexkap AM: one of the shareholders of EXP is a minority shareholder with this company.
This situation is regulated by established procedures within the company Exclusive Partners. In particular, the shareholder concerned does not intervene in the company’s study and decision-making phase in selecting the products managed by the asset management firm Finexkap AM of which he is a shareholder. Likewise, he does not intervene in the asset management firm in an operational manner.
The procedure to manage conflicts of interest is available, by simple request at the following email address: email@example.com.
Best Selection Policy
This policy addresses the principles of best selection established by Exclusive Partners within the framework of subscriptions received for the products marketed and for short-term cash investments.
In compliance with current regulations, Exclusive Partners has defined its best selection policy in order to guarantee its clients the best selection of intermediaries carrying out these operations.
1- General Provisions
In compliance with the provisions of Articles 314-69 et seq. of the General Regulations of the AMF, investment service providers must take all reasonable measures to obtain the best possible result for their clients, when executing orders, in view of certain criteria. This is the principle of best execution requiring the implementation of an execution policy. Investment service providers such as Exclusive Partners, who transmit orders received from their clients for execution with other entities, as part of their RTO services, must comply with the obligation to act in their clients’ best interests. The principle of best execution therefore takes the form here of best selection, which consists in selecting the entities to which the orders are transmitted for execution, for each category of financial instrument dealt with.
2- Consequences on its obligations in terms of best execution/best selection
Exclusive Partners is subject to the obligation of best selection which stems from the obligation of best execution. More precisely, Exclusive Partners guarantees the best execution of orders received from its clients as part of its RTO service, by integrating qualitative and quantitative best execution criteria into its selection process. These include:
- The price of the financial instrument negotiated,
- The cost of execution,
- The speed of execution,
- The liquidity of the order execution venue,
- The size and nature of the order,
- The likelihood of execution and of settlement/delivery of the order.
Internal procedures guarantee the prompt and fair execution of orders in the clients’ best interests. These procedures provide notably that orders are recorded and processed promptly and with precision by Exclusive Partners. Exclusive Partners endeavors in particular to select market intermediaries that ensure the security of its clients’ transactions. The settlement/delivery criteria and total cost are more often the most important factors. In the specific case of orders for subscription or redemption of UCIs, the notion of ‘best possible result’ is limited to the fact that the subscription and redemption of UCI units and shares is carried out according to the conditions mentioned in the prospectus of each UCI. Concerning structured products, the notion of ‘best possible result’ is limited to the fact that the investment is made according to the terms and conditions mentioned in the product term sheet. Furthermore, Exclusive Partners regularly monitors the effectiveness of its mechanism in terms of order execution in order to detect any possible shortcomings and to remedy them, as the case may be. The company shall inform its clients of any major changes in its best execution/best selection policy, namely via the company Website. Assessment of market intermediaries gives rise to a report and may lead to the de-referencing of an intermediary and/or the referencing of new intermediaries.
In the case of complaints, of reporting any type of abuse or violation of intellectual property rights, please phone +33(0)172285471 or send a letter to this address: 124 boulevard Haussmann, 75008 Paris, France.
Exclusive Partners will do everything in its power to respond to your request as quickly as possible and within a maximum of two months from receipt of your request, save in duly justified exceptional circumstances.
If you are not satisfied with the response you receive for your complaint and if your complaint concerns any financial instrument, investment service or more generally any matter coming within the scope of the Financial Markets Authority (AMF), you can contact the AMF mediator free of charge (by post at: 17, place de la Bourse, 75082 Paris cedex 02, France, or via an electronic form accessible on the AMF website: www.amf-france.org).
If you are dissatisfied regarding the action taken in response to your complaint in the banking or insurance domain, you may wish to send a copy of your complaint to the ACPR, inform them of any difficulty encountered or ask a question. You can contact the ACPR free of charge (by letter to the following address: Autorité de contrôle prudentiel et de résolution, Direction du contrôle des pratiques commerciales, 4 Place de Budapest CS 92459, 75436 Paris or electronically: (https://acpr.banque-france.fr/proteger-la-clientele/grandpublic-vous-etes-un-particulier/formuler-une-reclamation-vis-vis-dun-professionnel).