Legal information

Please be advised that www.comgest.com is Comgest's only official website.
The contents of our website do not constitute an offer of services, a recommendation or a solicitation to purchase or sell.
Comgest can not be held responsible for any decision made on the basis of the information contained in this website or for the consequences of its use by third parties. This material is in no case an offer for people living in a specific jurisdiction which does not authorize the distribution of the funds mentioned herein. It is the investor's responsibility, before any investment decision is made, to seek guidance from their own advisers as to whether our products are subject or not to any restriction regarding their legal status, and especially that the investor does not come from a country where the laws prohibit or regulate access to certain products. Comgest does not provide tax or legal advice to its clients.
Before making any investment decision, investors are advised to check the investment horizon and category of the fund in relation to any objectives or constraints they may have.
Investors shall undertake to respect the legal, regulatory and deontological measures relative to the fight against money laundering, as well as the texts that govern their application, and if modified investors shall ensure compliance with the applicable texts.
Performance figures are provided net of all fees and are calculated on a time-weighted, total return basis.
Past investment results are not necessarily indicative of future investment results.
Past performance is no guarantee of future results.
The value of all investments and the income derived therefrom can decrease as well as increase. This may be partly due to exchange rate fluctuations in investments that have an exposure to currencies other than the base currency of the fund.
Reference to market indices or other measures of relative market performance over a specified period of time are provided for your information only. Reference to an index does not imply that the portfolio will achieve returns, volatility or other results similar to the index. Funds which specialise in a particular region or market sector may entail higher risks than those which hold a very broad spread of investments. The composition of the index will not reflect the manner in which a portfolio is constructed.
The information and any opinions contained herein have been obtained from or are based on sources believed to be reliable, but accuracy can not be guaranteed.
Investors' attention is drawn to the fact that the operating and supervisory circumstances of certain markets may differ from the standards that prevail in the large international markets.
All opinions and estimates constitute our judgement as of the date the website was updated and are subject to change without notice.
Investors must read the latest fund prospectus, available at our offices and on our website www.comgest.com
The investment professionals listed in this document are employed either by Comgest S.A., Comgest Asset Management International Limited, Comgest Far East Limited or Nippon Comgest Inc.


Report on intermediary fees for the 2009 financial year

As the intermediary fees for the 2009 financial year totalled more than EUR 500,000, Comgest SA has prepared this report in accordance with the provisions of Article 314-82 of the General Regulations of the French financial markets authority (Autorité des Marchés Financiers - AMF).

 
Comgest SA used external research services to supplement the research carried out by its own staff. The services used consisted, in particular, of financial analysis projects, arranging meetings with the management of listed companies and introducing our managers to other specialists.
 
For equities transactions, Comgest SA used investment decision-making and order execution services, in particular those involving financial analysis projects.
Comgest signed brokerage commission sharing arrangements with a number of brokers. These agreements provided for separation of costs covering charges and fees linked to execution services and charges and fees paid to third parties in connection with research services.
With regard to other financial instruments, no intermediary fees relating to investment decision-making and order execution services were invoiced to the Fund and/or to discretionary portfolios managed by Comgest SA.
 
 
The breakdown between order execution fees and fees for investment decision-making services during the 2009 financial year is as follows:
  • Intermediary fees relating to “decision-making and order execution services” (or research services) represented 48.71% of the total volume of fees paid to the brokers selected.
  • Intermediary fees relating to order sending and receiving and the order execution service together represented 51.29 % of the total volume of fees paid to the brokers.
 
Of the total intermediary fees paid during the previous financial year, fees corresponding to investment decision-making services paid to third parties pursuant to commission sharing agreements in accordance with the AMF’s General Regulations represented 17.20%.
 
Shared commissions break down as follows:
  • 53% corresponds to fees relating to the execution of orders
  • 47% corresponds to fees relating to investment decision-making services.
 
Comgest SA confirms that pursuant to the commission sharing agreements and in accordance with AMF Circular no. 2007-02, it did not receive the following services:
  • Portfolio valuation services;
  • Computer purchase or leasing;
  • Payment of communication services such as digital networks and dedicated telephone lines;
  • Registration for seminars;
  • Book and magazine subscriptions;
  • Payment for travel or leisure activities;
  • Payment for software, and in particular order management systems and administrative software  such as word processors or accounting programs;
  • Membership of professional associations;
  • Office purchase or leasing;
  • Payment of employees’ salaries;
  • Supply of public information;
  • Direct cash payments;
  • Financial instrument custody or administration services.
 
 
Conflicts of interest relating to choice of service provider
In accordance with the regulatory framework governing the selection of brokers, Comgest SA has put in place a procedure that takes the following objective criteria into account:
 
  • quality of research and advice
  • quality of order execution and information coming from the market
  • quality of confirmation and payment-versus-delivery operations.
 
The list of intermediaries is reviewed every six months by the departments responsible for investment management, placing orders, middle office and by the Head of Internal Control and Compliance.




If you require any further information please contact Comgest.


Comgest S.A.
17, square Edouard VII
75009 Paris
France
Tel.: +33 1 44 94 19 00
Mail: info@comgest.com