It is strictly prohibited to copy the content of this website, totally or partially, by any means, without a formal authorisation by the Director of Publication, and is sanctionable under articles L335-2 and following of the French Intellectual Property Code.
Protection of personal data
In accordance with the law of January 6, 1978, that pertains to information technology, databases and civil liberties, the website has been declared to the Commission Nationale Informatique et Libertés (CNIL, the French National Agency regulating Data Protection). The users of this website are obliged to respect the IT law, the files and the liberties, the violation of which is liable to penalties. They shall, in particular, regarding the personal information to which they have access, abstain from any data collection, fraudulent use and, in general, any act that could harm people's private lives or reputations. You have the right to access, modify, rectify and delete any data concerning you (French Data Protection Act of January 6 1978).
Information regarding Equitim
Head office : Equitim, 121 rue d'Aguesseau - 92100 Boulogne-Billancourt
Société par Action Simplifiée with a share capital of 947 369 euros
SIRET number : 50093363500012
Intra-community VAT :
Director of Publication and In-charge of Content : Damien LECLAIR
Authorisation : Equitim was authorised on March 20th 2013 by the ACPR (Autorité de Contrôle Prudentiel et de Résolution, responsible for the supervision of the banking and insurance sectors) as an Investment Firm (« Entreprise d’Investissement ») under the number 11283P, and is also regulated by the AMF, the French Financial Markets Regulator.
Information regarding Equitim’s website
The information provided on the Equitim website is purely indicative and is provided for information purposes only.
Domain names have been registered by Equitim with AFNIC in accordance with current provisions.
The Equitim website is holted by CNSX
Design and construction
Agence Vu par... Digital
11 rue Paul Pélisson
Tel: 02 51 72 90 88
The official language of the website is French. It is subject to French law and the jurisdiction of French courts.
Website ownership and copyright
Copyright and intellectual property. According to the law of the 11th of March 1957 (art. 41) and the French intellectual property code of the 1st of July 1992, the entire Equitim website www.equitim.com (texts, graphs, photos etc.) is protected in France by the Intellectual Property Code, and abroad by international conventions applicable to copyrights.
The CNIL declaration n° 1500961 v 0, the CNIL being the French National Commission for Data Protection
Restrictions : it is strictly prohibited to publish, redistribute, retransmit or reproduce any information or data from the website to third parties, without prior written consent from Equitim. It is also prohibited to use any information recovery systems to collect financial data from this website.
Any reproduction or, more broadly, any unauthorised use of the site and of information presented therein becomes the responsibility of the user and can lead to the commencement of legal proceedings, particularly in respect of piracy offences.
Any representation of this site in full or in part by any means whatsoever is prohibited without the express permission of Equitim and would be considered as a piracy offence sanctioned by articles L.335-2 and following of the Intellectual Property Code. The user would thus be held responsible.
The « Equitim » brand its logo are trademarks of Equitim. It is strictly forbidden to reproduce, delete, re-use or modify these distinctive signs in any way when they appear on the pages of the site.
Access to the website
The user of this site acknowledges that he/she has the skills and resources necessary for accessing and using this website. Equitim cannot be held liable for elements beyond its control or for damage which may be caused to the technical environment of the user, especially his or her computers, software, network equipments or any other material used to access the services and the information on the website. As the security and integrity of electronic communications networks cannot be guaranteed, Equitim cannot be held responsible for any consequences arising from technical defaults on the website, especially any difficulty in accessing the website or any interruption in the information broadcasted.
In general, this website is reserved for « professional clients » as understood by the European financial regulation called MIF.
Access to products and serviced presented on this website may be subject to restrictions vis-à-vis certain persons
or in certain countries, either under general prohibitions or under marketing rules. None of the products or services presented on this website will be provided to a person whose country of origin prohibits it. In a broader sense, products and services presented on this website can only be subscribed to in jurisdictions where their marketing and promotion are authorised.
Equitim advises all interested users to ascertain if they are legally authorised to subscribe to products and/or services presented on this website, and if they are legally authorised to consult this website. In any case, users who are subject to restrictions which prohibit them from accessing information contained on this website, such as citizens of the United States of America and the United Kingdom, are not authorised to access information containted on this website and are requested to leave the website.
Updates and quality of information
Despite all reasonable efforts undertaken to ensure that the information on the website is accurante and updated, Equitim shall not be held responsible for the correctness, completeness and accuracy of the content as well as their coherence for any purposes.
Equitim is not liable for hyperlinks towards other websites, especially their content. These links have been placed only for information purposes.
It is strictly prohibited to use hyperlinks towards Equitim’s website without Equitim’s prior authorisation. For this, a request for authorisation may be sent to the management at 121 rue d'Aguesseau, 92100 BOULOGNE BILLANCOURT or on the following email address : email@example.com.
Nature of the information
All the information on this website is purely indicative. This is not a transactional website. Information may be modified by Equitim without prior notice, especially in case of changes at the level of the company, its products and services.
Information published on this website does not constitute :
- an offer to buy, to sell or subscribe to any financial products and services, nor an offer of products or services that could be used in a public issue or as a sales pitch or an invitation to purchase or sell securities or any other management or investment products.
- recommendation or advice regarding a particular investment or arbitrage of financial instruments or any other management or investment product.
Equitim and its team cannot be held liable for the way the information on the website is used and its potential consequences, especially on the decisions made based on this information.
The automated processing of personal data on this website has been registered with the CNIL (the National Commission for Data Protection). According to law n° 78-17 of the 6th of January 1978 pertaning to Information Technology, Files and Civil Liberties, users have the right to oppose (art. 26 of the law), access (art. 34 to 38 of the law) and rectify their personal information. You may exercise these rights by writing to Equitim at 121 rue d'Aguesseau – 92100 Boulogne-Billancourt.
Users also have the right to opt-out from receiving marketing messages. You may exercise this right by sending us a letter to the address hereabove or by sending us an email. However, if you wish to receive information concerning Equitim in the future, kindly contact us.
Before making any investment decision, it is important that you understand that certain investments present important risks related to market fluctuations for instance. We thus strongly advise you :
- to consult regulatory information that Equitim can put at your disposal upon simple request,
- to get assistance from an expert if you feel that your technical knowledge is insufficient,
- to contact your financial consultant who will help you chose products and services that are adapted to your personal situation and will explain their availability and the contractual conditions.
The value of a share or of any financial instruments can be affected by fluctuations on listed markets as well as those of securities or specific financial instruments. All investments present a risk of loss of capital.
Procedure for selecting issuers within the framework of investment or of RTO
The present document pertains to the execution of article L533-18 II of the Monetary and Financial Code, especially the execution of Equitim’s obligations of best selection.
The term « issuer » in this procedure refers to an investment bank with which Equitim has signed a contract for brining new business : issuers referenced according to the corresponding procedure.
II. Regulatory obligations
Equitim is obliged to :
- make all reasonable efforts to obtain the best result possible for its clients (RGAMF, art. 314-75 IV). This obligation is fulfilled by using the procedure regarding entering into a business relation with a new issuer, bids sollicited upstream and through an annual monitoring of issuers.
- Draft a procedure of best selection and reference « authorised » issuers (RGAMF art. 314-75 V). This obligation is fulfilled by drafting the present document. The list of authorised issuers is attached in appendix 2 of the procedure pertaining to the « Referencing and evaluation of issuers ».
- Publish the present procedure on the website (RGAMF, art. 314-75 V).
- Examine once a year, or more if necessary, the current procedure and the quality of execution of the issuers (RGAMF, art. 314-75 VI, P-R AMF 2014-07 5.1, 5.2, 5.4). Equitim’s internal audit programme provides for updates in the procedure and in monitoring the issuers.
- Ensure that the issuers have an obligation of best execution (RGAMF, art. 314-75 V et P-R AMF 2014-07 4). This obligation is fulfilled since Equitim only works with authorised European establishments.
Equitim also informs you that orders that are transmitted are not executed on a regulated market or on a multilateral trading facility. Thus, there exists a counterparty risk in case the issuer defaults. This could result in a loss of the amount invested (P-R AMF 2014-07, 4.2).
III. Perimeter of the procedure
Equitim has to select an issuer in the following cases :
- in the framework of is activity pertaining to dedicated structured products : Equitim, after having designed a structured product upon a partner’s request, launches a bid sollicitation for selecting the issuer.
- In the framework of its activity pertaining to marketing its general products : Equitim, after having designed a structured product at its own initiative, launches a bid sollicitation for selecting the issuer.
- In the framework of its activity pertaining to the intermediation of products on the secondary market : Equitim, after having researched on the different structured products that are available, selects the issuer and transmits the order.
4.1. Activity pertaining to dedicated structured products
4.1.1 Bid sollicitation
Prior to each bid sollicitation, Equitim undertakes a pre-selection of referenced issuers that are likely to respond, according to the following criteria :
- The issuer’s capacity to respond to fixed restrictions
- The type of product
- Equitim’s knowledge of the issuer
- Whether the issuer is referenced with certain insurers or not
- The fact that issuers are more or less competitive in certain types of products.
The partner’s account manager at Equitim :
- drafts the bid sollicitation based on the model attached in the appendix,
- sends it to pre-selected issuers and
- gathers all the bids.
The issuer is selected by the account manager amongst those having responded to the bid sollicitation according to the following criteria :
- The bid (return / protection)
- The quality of the issuer (S&P, Moody’s and Fitch ratings, and CDS levels).
In the scenario where these criteria seem insufficient, Equitim will also take into account the quality of the after sales service : reporting, availability.
Exceptions made to the bid sollicitation procedure have to be documented (the account manager drafts a summary of the issue by email) and approved by one of the directors prior to issue so as to ensure that the selection responds to Equitim’s obligation to act honestly, fairly and professionally.
Once the selection is made, Equitim asks the partner for approval.
4.2 Activity pertaining to marketing general products
In this case, the entire selection process is handled by Damien Leclair.
4.2.1 The bid sollicitation
The bid sollicitation is realised using the same procedure as detailed in the previous point.
4.2.2 The selection
The selection is made using the same procedure as detailed in the previous point.
No approval is required from the partner in this case.
4.3 Activity pertaining to the intermediation of products on the secondary market
The product and the issuer (or issuers) are chosen after a thorough analysis of the characteristics of the product in relation to the price proposed by the issuer, taking the following criteria into account :
- Share price variation compared to the initial share price
- Price variation compared to the initial price
- Due date for accrued coupon
- Distance with the knock-in level
- Size that can be purchased
Equitim can suggest several issuers to the client and the latter may choose from the list. The partner’s approval is formalised by sending the subscription documents signed by the client.
V. Compliance control
A compliance control is done on one bid sollicitation per quarter.
VI. Regulatory sources
Code Monétaire et Financier (the French Monetary and Financial Code)
- Art. L533-11
- Art. L533-18
Règlement Général de l’AMF (the AMF General Regulation)
- Art. 314-3 et 314-75
AMF Recommendation 2014-07 dated 05/08/2014 : Guide for Best Execution
This procedure is drafted in application of article 26.1 of European Regulation 2017-56: "Investment firms shall establish, implement and keep operational transparent procedures and procedures for handling complaints with a view to the rapid processing of complaints sent by customers or potential customers… The complaints management policy provides clear, precise and up-to-date information on the complaints handling process. "
I. Receipt of a complaint
A complaint (or complaint) is any message from an existing or potential customer indicating dissatisfaction. In order to ensure the clarity and traceability of the request, complaints must be made in writing via the site contact form or by email to the customer's usual contact person. A complaint is filed at no cost to the customer or potential customer.
II. Processing a complaint
All complaints are immediately forwarded to the President of Equitim, responsible for handling complaints. It is he who handles the treatment. In order to ensure the equal and harmonized treatment of complaints, complaints are processed in order of receipt, except in emergencies. Equitim communicates with the client or potential client in a clear, simple and easy-to-understand manner, and responds to the complaint as soon as possible. If the processing time exceeds 2 months, Equitim informs the customer by email. The client can contact the AMF if Equitim's response does not suit him: https://www.amf-france.org/fr/le-mediateur-de-lamf/votre-dossier-de-mediation/vous-voulez-deposer-une-demande-de-mediation
III. Complaints follow-up
Equitim keeps a register of complaints (Rgt 2017-565, art. 26.1), containing in particular the following information: Date of complaint Employee who received the complaint Nature of the complaint and identified dysfunctions Measures taken to resolve the complaint Date and content of the response to the client Corrective action taken: device, procedure, control, etc.
Level 1 and 2 controls are included in the control plan.
V. Dissemination of the procedure
This procedure is posted on the Equitim website (Rgt 2017-565, art. 26.2).
Règlement 2017-565, art. 26
1.Investment firms establish, implement and keep operational transparent complaints management policies and procedures with a view to the prompt handling of complaints from clients or potential clients. Investment firms keep a register of complaints received and steps taken to resolve them. The complaints management policy provides clear, precise and up-to-date information on the complaints handling process. This policy is validated by the company's management body.
2.Investment firms publish details of the process for dealing with a complaint. These details include information on the complaints handling policy and contact details of the complaints handling function. Companies communicate this information to customers or potential customers, at their request or by acknowledging receipt of a complaint. Investment firms allow their clients and potential clients to file a complaint free of charge.
3.Investment firms establish a complaints management function to investigate complaints. This function can be performed by the compliance check function..
4.In the course of handling a complaint, investment firms communicate with the client or potential client in a clear, simple and easy-to-understand manner and respond to the complaint as soon as possible.
5.Investment firms inform the client or potential client of the firm's position with regard to the complaint lodged and of the options available to it, and in particular that the client or potential client can transfer the complaint to an entity. out-of-court settlement of disputes within the meaning of Article 4 (h) of Directive 2013/11 / EU of the European Parliament and of the Council (21) on out-of-court settlement of consumer disputes, or may bring a civil action.
6.Investment firms provide information on complaints and the handling of complaints to the relevant competent authorities and, if applicable under national law, to an ADR body.
7.Investment firms' compliance review function analyzes complaint data and complaint handling to ensure it identifies and addresses any risks or issues.
Conception, Design, Technical Development.
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