Legal Informations



In accordance with the applicable regulatory requirements (see article 313-8 of the AMF RG) and for any specific request, do not hesitate to contact the following number +33 (0) 1 70 36 61 77, send an e-mail to the address or send a mail to the postal address 9, rue de Tehran, 75008 PARIS; The commercial team will acknowledge receipt of the complaint within ten working days and will make every effort to respond to your request as soon as possible and in any event, within a maximum of two months from receipt. your request.
We remind you that you can seize the mediator of the AMF, whose prerogatives are specified to you by following this link:


In accordance with the European MiFID (Financial Instrument Market) Directive, which entered into force on 1 November 2007, Ginjer AM has formalized a management of conflicts of interest and put in place specific provisions in terms of organization (means and procedures) and control in order to prevent, identify and manage situations of conflicts of interest that may affect the interests of its clients.

Recall of the definition

A conflict of interest may be defined as a situation in which Ginjer AM, one of its collaborators or one of its service providers may be suspected not to act independently in the interest of the holders.

Actors concerned

Ginjer AM attaches the utmost importance to the interests of its clients and takes all reasonable measures (within the meaning of section 313-18 of RG AMF) allowing it to detect conflict of interest situations:

• Either between itself, the persons concerned or any person directly or indirectly related to Ginjer by a control relationship, on the one hand, and its customers, on the other hand;

• Between two clients.

Conflict of interest situations

In order to detect situations of conflicts of interest that may harm clients, Ginjer AM takes into account at least the possibility that the persons mentioned above are in one of the following five situations listed in article 313-19 of the AMF RG:

  1. The claimant or this person is likely to make a financial gain or avoid a financial loss at the customer’s expense;
  2. The service provider or this person has an interest in the result of a service provided to the client or a transaction carried out on behalf of the client that is different from the client’s interest in the result;
  3. The claimant or this person is encouraged, for financial or other reasons, to favor the interests of another client or a group of clients in relation to the interests of the client to whom the service is provided;
  4. The provider or this person has the same professional activity as the client;
  5. The claimant or this person receives or receives from a person other than the client an advantage in relation to the service provided to the customer, in any form whatsoever, other than the commission or fees normally charged for this service.

The purpose of this policy is to identify the key measures to achieve this conflict of interest management objective. Nevertheless, if any conflicts of interest appear, they will be managed in the interest of the customer, that is to say in a fair way and by providing him with complete and adapted information.

Thus, Ginjer AM allows itself according to conflict of interest situations to:

  • carry out the activity or transaction to the extent that the organization adequately manages the potential conflict of interest situation,
  • inform the client in the event that certain conflicts of interest may remain and provide him with the necessary information on their nature and origin in accordance with the Conflict of Interest Management Procedure (ref: CCI_A_03_V …),
  • if need be, do not carry out the activity or the transaction causing a conflict of interest.

Ginjer AM must manage any conflict of interest, from detection to proper processing. As such, Ginjer AM has set up an organization to:

  • prevent the emergence of conflicts of interest, by raising the awareness of all its staff on the rules and codes of good internal conduct and place, and by setting up strict rules and procedures:

– setting up an internal control system,

– separation of functions that may give rise to potential conflicts of interest,

– always ensure that Ginjer AM ‘s offer fits well with the profile and expectations of its customers, and is never in conflict with their needs . Forced sales of products or services constitute malpractice from this point of view,

– recording of telephone conversations from Ginjer’s contractors AM ,

– prohibition of personal market transactions which do not comply with the rules laid down by the undertaking,

– training or raising awareness among all staff of good practice in the profession.

    • identify conflict of interest situations that may affect the interests of clients, by establishing a risk map of these conflicts of interest. This mapping specifies the types of activities for which a conflict of interest is likely to arise. to occur. Ginjer’s RCCI AM is responsible for updating this map.
    • Manage situations of potential conflicts of interest-   fully and objectively inform customers, refraining from using biased arguments while signaling the constraints and risks associated with certain products or operations, –   declare the gifts and benefits received at the RCCI according to rules set by Ginjer AM , –   declare, as soon as they occur, conflict situations; interests in which the collaborators may be, if any, in the RCCI, which will take care, with the persons concerned, of the resolution of such a conflict.



  • Voting Policy : document
  • Implementation of voting policy : document
  • Operational rules of the Ginjer AM voting policy : document



Ginjer AM has implemented strict selection and rating processes for financial intermediaries and counterparties, documented through a process.

This procedure details the process of selection and validation of financial intermediaries and authorized counterparties, formalizes the circuits and describes the monitoring and controls performed on transactions and brokerage.

Transactions with intermediaries and counterparties are made directly by Ginjer’s managers, excluding residual cash management. These transactions are carried out in the strict interest of the holders and investors, with the objective of a satisfactory distribution of volumes and brokerages according to the level of appreciation of the intermediaries and counterparties by the various Ginjer stakeholders. AM .

  1. Policy on the best selection of financial intermediaries

Ginjer AM , which does not execute market orders itself, has put in place a policy of better selection of its financial intermediaries from several criteria, mainly related to:

  • the total transaction cost as defined in article 314-71 of the AMF General Regulations, ie by considering the price of the financial instrument plus the various costs related to the execution of the the order, including commissions, site-specific costs, clearing and settlement fees and any other fees that may have been paid to third parties involved in the execution of the order;
  • the quality of the execution (size of the order, speed of execution);
  • the size and financial strength of financial intermediaries;
  • sectoral and geographical specializations;
  • the quality of the back office (availability, efficiency);
  • the quality of the research.

Ginjer AM assesses the performance of its financial intermediaries on a half-yearly basis and identifies the measures to be taken in order to obtain the best results on a regular basis possible for all of its customers. Evaluation methods are documented through a dedicated procedure.

It is stated that no shared brokerage commission (“CSA”) agreement was negotiated between Ginjer and its financial intermediaries. In addition, the management company is not bound to the financial intermediaries by any agreement which would have the effect of limiting its access to other counterparties or to obligations or incentives regarding the volume of business.

  1. Principles of best execution of orders

The Best Execution Policy aims to retain the modes and locations of execution to ensure the best possible outcome when executing orders.

Ginjer AM does not intervene directly in the markets for the execution of orders placed within the framework of the management of the portfolios. Indeed, the company systematically uses the services of its authorized financial intermediaries. In this context, the company is subject to the obligation of better selection (see “Selection and review procedure for intermediaries and counterparties”).

2.1.   List of best execution criteria for orders

In order to regularly obtain the best possible result in executing orders on behalf of the portfolios it manages, Ginjer AM is particularly relevant the following factors:

  • the negotiation price;
  • the transaction cost;
  • the speed of execution;
  • the probability of execution and settlement;
  • the size of the order;
  • the nature of the order;
  • any other consideration likely to influence the execution of the order (for example: country, type of financial instrument, other …).

In addition, Ginjer AM takes into account the following criteria to determine the relative importance of the factors referred to above:

  • the characteristics of the order concerned;
  • the characteristics of the financial instruments that are the subject of this order;
  • the characteristics of the execution venues to which this order can be forwarded;
  • where applicable, customer characteristics, including categorization.

2.2.   List of financial instruments processed

The financial instruments concerned are the following:

Convertible bonds

  • For convertible bonds, the priority execution factors are, if possible, the transaction price and the probability of execution.

Bonds and other debt obligations

  • For bonds and debt securities, including convertible bonds, priority execution factors are, if possible, the transaction price and the probability of execution • For bonds and government debt securities, the priority if possible, the transaction cost and the speed of execution.

Derivatives linked to securities, currencies, interest rates, stock indexes

  • For derivatives admitted to trading on a regulated market, priority execution factors are, if possible, the transaction cost and the speed of execution • If applicable, for over-the-counter derivative instruments and where the policy of best execution applies, the priority factors of execution are if possible the trading price and the probability of execution and settlement.

Money Market Instruments

  • Priority execution factors are, if possible, the transaction cost and the speed of execution.

Shares and other equivalent securities

  • For large capitalisations, the priority factors of execution are if possible the transaction cost and the speed of execution.
  • For medium capitalisations, the prime execution factors are if possible the trading price and the probability of execution of the total size and settlement.
  • For small-cap or emerging-country equities, the priority factors for execution are, if possible, the probability of execution and the size of the order.

2.3. List of places of execution

Ginjer AM has defined the places of execution which seem to him the best able to provide in most cases, on a consistent and consistent basis, the best possible result for executing the orders of the portfolios it manages.

In this context, the type of order and / or the financial instrument concerned may help to determine the place of execution to be used to execute the order. In this context it is possible that for certain types of financial instruments or specific orders, only one financial intermediary is possible.

As a result, orders initiated on behalf of mandates and UCIs managed by Ginjer AM may be executed at the following execution venues:

  • Regulated markets
  • Multilateral Trading Platforms (MTF)
  • Other sources of liquidity: – Electronic trading platforms not having the status of MTF or regulated market – Market makers
  1. Review and follow up of the existing system

The Semi-Annual Committee of Intermediaries and Counterparties, in which RCCI participates, conducts a review of the effectiveness of the selection and rating process of Ginjer’s authorized financial intermediaries and counterparties AM to identify and, if necessary, correct any deficiencies.

In addition, the RCCI proceeds as soon as necessary and / or ad minima annually to a review of the procedure of best execution / selection. This document is therefore subject to change if new events are likely to affect Ginjer’s ability to select the most appropriate provider to provide. the best execution.

Finally, the RCCI may be required to carry out, either unexpectedly or in accordance with the periodicity provided for in the RCCI’s annual control plan, any checks to ensure that Ginjer AM complies with its obligations to regularly obtain the best possible result in executing orders on behalf of its managed portfolios.

Compensation Policy

This paragraph is intended to clarify the Compensation Policy of GINJER AM .

In accordance with the provisions of Directives 2011/61 / EU and 2014/91 / EU of the European Parliament and the Councils of 8 June 2011 and 23 July 2014 concerning securities fund managers (hereinafter referred to as the “UCITS V Directive”) and Alternative Investment Fund Managers (hereinafter referred to as the “AIFM Directive”), GINJER AM is committed to establishing, implementing and maintaining policies, procedures and compensation practices consistent with sound and effective management of risks incurred by the Company.

Since the creation of GINJER AM , the remuneration policy (hereinafter referred to as “the Policy”) has been defined by the Executive Management in accordance with the economic strategy, objectives and values ​​of the Company. It promotes sound and effective risk management and does not encourage risk taking that would be incompatible with the risk profiles, the regulations and the constituent documents of the UCITS or AIFs managed by the Management Company.
In particular, it is determined in such a way as to avoid situations of conflict of interest and to prevent taking risks that are inconsiderate and / or incompatible with the interests of the Company’s customers.

The scheme applies to all employees of the Management Company.
1.Application of the Principle of Proportionality

The criteria set out in the UCITS V Directive for invoking the principle of proportionality are the size of the Company, the size of the UCITS and mandates it manages, its internal organization and the nature, scope and complexity of its activities. .
The management company GINJER AM verifies its criteria since:

• The number of employees within the Company is 8 (well below the threshold of 50 employees).
• The Company is not present abroad; it does not have branches or subsidiaries.
• The Company manages only one UCITS, a diversified fund, which does not have a high degree of complexity. It does not use complex underlyings or leverage effects that are difficult to understand.
• The Company manages assets under the 1.25 billion euro threshold.

The profile of the GINJER AM Management Company therefore justifies the application of the proportionality principle in order to implement its Remuneration policy.
In accordance with the regulations, GINJER AM invokes the principle of proportionality.
The device described below was therefore developed on the basis of the application of this principle.

2.Compensation Governance

In accordance with the regulations and pursuant to the principle of proportionality, GINJER AM has not opted for the constitution of an ad-hoc remuneration committee.
Nevertheless, the remuneration policy, and its implementation, are presented each year in detail to the Board of Directors of the Company for validation.
In this sense, the Board of Directors has a joint supervisory function with the General Management of GINJER AM . As part of this joint function, they ensure that the internal control systems ensure that the principles of the Policy comply with regulations and professional standards.
The personnel of the Company is composed of employees in the category of “identified” personnel (hereinafter referred to as “Identified Personnel”) as well as employees whose functions and level of remuneration do not justify their being qualified as such.
In fact, the Identified Personnel includes, among the employees of the Management Company, the members of the General Management of the Company, the “risk takers”, the persons exercising a control function, as well as any collaborator who, in the light of of its total remuneration is in the same remuneration bracket as the Company’s General Management and the “risk takers”, and whose professional activities have a substantial impact on the risk profile of the Management Company or the investment profiles. risk of the UCITS or AIFs it manages.

3.Principles for determining and remunerating the remuneration of all staff

The remuneration of the staff is composed of at least a fixed part which remunerates the competence, the level of experience and the level of responsibility of each one.
The fixed compensation of an employee may be supplemented by a variable portion which aims to recognize his individual performance, his contributions and behavior, the performance of the operating unit to which he belongs and the results of the Management Company in his together. In any case, the fixed part of the remuneration represents a sufficiently high share of the total remuneration so that a fully flexible policy can be exercised in terms of variable compensation, including the possibility of not paying any variable part. The compensation base for all employees of the Company is fixed compensation.
The overall amount of variable remuneration is determined based on the achievement of an operating profit target for year “n” validated by the Board of Directors at the beginning of year “n”.
As part of this envelope, the variable compensation of an employee is calculated on the basis of a balance between the application of qualitative and quantitative criteria specific to each function; it is validated by the Board of Directors and is paid in the form of a discretionary bonus.
This system is designed in such a way that it does not constitute an obstacle to the reinforcement of the Management Company’s own funds and that variable remuneration can be significantly reduced from one year to the next, particularly in the event of fiscal year with the possibility of not paying any variable part.
The granting of a guaranteed bonus to a new employee of the Company is exceptional and may only concern the first year of the said employee’s entry into service.

4.Principles relating to the determination and remunerations of the identified staff

All of the Management Company’s employees are part of the compensation process described in the paragraph above.
However, in accordance with the regulations, and in order to maintain a prudent balance between sound financial position, attractiveness of the company and allocation, payment or acquisition of variable compensation for the Identified Personnel, the Management Company has put in place a specific device. to the variable remuneration part of the identified staff members.
For the members of the Identified Personnel, the mechanism applicable to their variable remuneration part is as follows:

• Variable remuneration below a minimum threshold ((€ 100k) or 30% of the fixed salary) are paid in cash without being deferred.
• In the case where the variable remuneration of an employee is higher than the minimum threshold ((€ 100k) or 30% of his fixed salary):

– 50% of this sum is paid immediately in cash,
– 10% is paid immediately in the form of provisions indexed on the downside performance only of the fund GINJER ACTIF 360 (the only UCITS managed by the company), with a retention period of one year (subject to an effective non-termination of his duties in GINJER AM for whatever reason),
– 40% would be deferred in the form of performance-indexed provisions only on the basis of the fund GINJER ACTIF 360 (the only UCITS managed by the company) and released in equal installments over the next 3 years. The number of shares allocated to the beneficiary will be calculated taking into account the net asset values at the time of the allocation (and not taking into account those at the time of the payments).

• The deferred part of the variable part of the compensation is definitively acquired to the employee only at the date of its actual payment and can not be perceived by the employee before the said payment.
This deferred part would be canceled if GINJER AM ceases to hold office for any reason whatsoever and could be reduced or canceled (notion of penalty) depending on the evolution of quantitative and qualitative criteria. in the following years among which:

– evidence of fraudulent behavior or a serious error by the staff member,
– a significant change in the overall financial position of the Company,
– non-compliance with internal regulations and procedures,
– the fact that the UCITS and / or the Management Company and / or the operating unit in which the member of staff works undergo a significant reduction in their financial performance,
– the fact that the UCITS and / or the Management Company and / or the operating unit in which the employee works is subject to a serious insufficiency of risk management.

5.Non-circumvention of the Policy

Each employee is required to undertake not to use hedging strategies or insurances related to deferred variable compensation or liability in order to counteract the impact of alignment with the holders and the Management Company on the risk incorporated in its compensation agreements.

The Management Company will not pay any variable compensation to the employees concerned by means of instruments or methods that facilitate the circumvention of the requirements of the UCITS V and AIFM directives.

6.Control device

Throughout the year, the RCCI carries out, through GINJER CENTER, the individual assessment of the risk behaviors of the Identified Personnel. It communicates to senior management, prior to the compensation campaign, risky behavior.

The remuneration policy, and its implementation, are presented each year in detail to the Board of Directors of the Company for validation.
In this sense, the Board of Directors performs a joint supervisory function with the General Management of GINJER AM . As part of this joint function, they ensure that the internal control systems ensure that the principles of the Policy comply with regulations and professional standards.
The RCCI annually reviews the impact of the compensation structure on the Company’s risk profile and compliance with legal and regulatory requirements.


CONSIDERING ESG CRITERIA and those relating to the energy and environmental transition in Ginjer’s investment policy Assets 360

As part of its investment policy, Ginjer AM chose not to simultaneously take into account environmental, social and governance quality criteria (ESG) and those relating to the energy and ecological transition. This last choice results from an analysis of the data coming from different suppliers which, at this stage do not seem to us homogeneous and reliable for all the instruments (actions, sovereign bonds, …).

However, Ginjer Assets 360 as a diversified fund uses all of these instruments, making a possible result calculated at this stage of little relevance.

Ginjer AM continues to analyze the different methods to find homogeneous data in order to provide reliable indicators representing a better reality of the problem.

Management implemented through mandated portfolios or UCIs is therefore not dictated or restricted by these principles.

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The site   is a site with exclusively informative purpose whose objective is to present the Ginjer Portfolio Management Activity AM


This site is not a transactional site. Any information may be changed without notice by Ginjer AM . The information published on the site is not constitutive:

– an offer of products or services that may be treated as a public offering or any solicitation or solicitation activity for the purchase or sale of securities or any other management product or investment.

– nor any inducement or advice for any investment or arbitrage of securities or any other management or investment product.

Ginjer AM and its contributors decline any responsibility for the use that might be made of this information and the consequences that might result, particularly at the level of decisions that could be taken or actions that could be undertaken from this information.


Prospectuses and KIIDs (Key Investor Information Document) of each UCITS approved and / or approved by the Autorité des Marchés Financiers (France) are available on the website. Any subscription to a UCITS or a product must be done after having read the regulatory documents in force.

The other regulatory documents are available from Ginjer, located at 9, rue de Tehran, Paris (75008). Investment in financial instruments may result in risk and the value of a mutual fund or unit share reflecting the value of the securities and the assets held is subject to changes in the stock markets.

Past performance does not prejudge future performance and is not consistent over time.

The site’s official language is French.

Assignment of results: Ginjer’s UCITS AM are capitalization UCITS (dividends reinvested) in accordance with KIIDs (Key Investor Information Document) and prospectus.


– Quotations: Index data is provided by third parties who are the exclusive owners. The published index is the closing index.


The information on products and services on this website is only for people residing in France.

Access to the products and services presented on the site may be subject to restrictions with respect to certain persons or countries, and in particular with respect to investors from the United States and the United Kingdom who are subject to specific legislation.

In particular, it is specified that UCITS have not been and will not be registered with the US Securities and Exchange Commission as provided for by the Investment Company Act of 1940, and amendments or other securities regulations. No prospectus published on this site may therefore be introduced, transmitted or distributed in the United States of America or in their territories or possessions or delivered to US institutional residents or companies, associations or other entities created or governed by laws United States (all of which constitutes a “US person” within the meaning of Regulation S under the United States Securities Act 1993). In addition, UCITS may not be offered or sold to US investors.

More generally, the products and services presented on this site can be subscribed only in the jurisdictions in which their marketing and promotion are authorized.

Ginjer AM advises all interested parties to make sure beforehand that they are legally authorized to subscribe to products and / or services presented on the site.

None of the products or services presented here will be provided to a person if the law of his country of origin, or any other country that concerns him, prohibits it. The reader of this message is requested to ensure that he is legally authorized to connect to this site in the country from which the connection is established.

The establishment of hypertext links by anyone to the site, unbeknownst to Ginjer AM , is not permitted. Before you set up any of these links, it is your responsibility to make a request to Ginjer AM . Your request should be addressed to the Sales Department at 9, rue de Tehran – 75008 Paris.


The site as well as all the elements composing it and in particular: texts, still or moving images, sound compositions, graphic charter, databases, etc … are the exclusive property of Ginjer AM and are protected under the provisions of the Intellectual Property Code.

By exception, certain contents (data, images) are the property of their respective authors.

Consequently, any reproduction or total or partial representation of this site or one of its elements without the express and prior authorization of Ginjer AM is forbidden and would constitute an infringement punishable under the provisions of the Code of Intellectual Property and the Penal Code.

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S.A.S with the share capital of & nbsp; 301,200 euros registered in the Paris Trade and Companies Register under the number 533 638 961

Portfolio management company (AMF approval ( )   n °   GP-11000032 27/09/2011).

9 rue de Tehran – 75008 Paris -Tel: +33 1 70 36 61 78

Publication Director : Léonard Cohen.


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