Our regulatory commitments

To find the documents on order execution and the exclusion of controversial weapons, click below.

Order executionWeapons exclusion

Control mechanisms

The protection of financial operations is a major preoccupation of Groupama AM, and so  the company has established a rigorous organizational structure, with an Audit department reporting directly to the CEO, and two other departments, the Financial Risks and Performance department and the Control and Legal department reporting to the Deputy CEO.

The Financial Risks and Performance department is responsible for monitoring and managing investment risks (financial management of UCI portfolios and asset management mandates) It is divided into two complementary entities, management control (compliance with the regulatory limits on investment considered as specifically applicable to the company) and risk management (control of financial management risks).

The Control and Legal department, for its part, oversees three complementary entities:

  1. The Compliance team handles the regulatory and legal risks and the risks relating to reputation.
  2. The Internal Control team assesses and manages the operational risk.
  3. Finally, the CISO (chief information security officer) is responsible for managing the security risks relating to the information systems.

To ensure perfect application of the internal procedures and to cover the different types of risk, three committees have also been established:

  1. Monthly risk committee: handles the risks relating to the financial management of investment portfolios. Every quarter, this committee also takes on a highly strategic dimension with the participation of the CEO, the heads of the three operational departments of Groupama AM (Development, Management and Support Activities) and the Heads of the Audit and Control and Legal departments;
  2. Internal control committee: ensures the cohesion and efficiency of the entire internal control system;
  3. Audit committee: receives and examines the annual accounts, the evaluation report on the internal control system and the activities of internal audit, internal control, compliance and the CISO.

This structured organization provides protection to operations and a clear view of the exposure of clients to risk.

Optimized policy for order execution

The execution of  each client  order is subject to extremely strict in-house controls at Groupama Asset Management, with the aim of safeguarding and maximizing the results. The optimization policy is based on precise commitments:

  • Implementation of procedures to obtain the best result possible;
  • Communication of the specific information (equities, capital, performance, investment, economy, profitability etc.) that is relevant and of practical use to each client;
  • Appropriate application of the execution policy, with respect to the different categories of clients, financial instruments and transactions;
  • Demonstration to clients that the orders executed on their behalf were executed in accordance with this policy;
  • Revision of the order execution policy at regular intervals and with every significant change on the markets covered.

This approach complies with the Markets in Financial Instruments Directive (MFID), which has been applicable since 1 November 2007.


See our documentation on order execution

Selection and execution policy 2023

Reporting RTS 2018 – PDF

Report on brokerage fees 2019

Systematic exclusion of controversial weapons

With effect from May 2009, Groupama AM has established a policy that strictly excludes investment in companies known to be implicated in activities relating to controversial weapons. The activities concerned are the production, storage, distribution and sale of cluster bombs, as defined by the Oslo Treaty of 2008, anti-personnel mines, as defined by the Ottowa Convention of 1997 and depleted uranium weapons, which are banned by certain national legislations.

  • Since 2008, Groupama AM has been part of a working group that brings together the main French asset management companies. This working group meets at least once a year with the “analysis service provider” to share expert assessments and to exchange ideas on the methodology applied by the service provider for identifying controversial companies.
  • The analysis service provider is an independent firm that has been mandated to identify the companies implicated in controversial activities. Its analysis is based on the definitions contained in the relevant international legal texts. At Groupama AM, this analysis is the basis for classifying companies into three lists – red, orange and green. We regularly update our in-house list of the companies excluded on the basis of this research, whether these companies are publicly quoted or not.

This policy of exclusion of controversial weapons applies to all the portfolios under management. Every time our internal list is updated, the update is communicated to all our management teams, to the risk teams for verifying effective exclusion and to the Compliance department.

Exclusion Policy Controversial weapons 2019