Policies and disclosures.
We appreciate your interest in our website and our company. We make every effort to protect your personal data when it is collected, processed and used during your visit of our website. Your data is protected in accordance with statutory requirements, including the General Data Protection Regulation (EU) 2016/679, whose implementation is described in the personal data protection policy below.
Personal data is collected and processed on our website as far as you have actively provided such data by registering yourself. Walnut may collect different categories of personal data such as, in particular: last Name, first Name, email, profession, company, phone number, job title, country.
Walnut is also likely to collect IP addresses, cookies, and information about your browser in order to perform security or statistical analysis-related processing on an anonymous basis.
The purpose of the personal data use is to enable the carrying out of statistical analysis operations in order to improve the services offered and to enhance the security of the website. This information also allows the provision, if any, of data relating to collective investment vehicles managed by Walnut.
Personal data is disclosed to service providers in order for them to carry out the services specifically dedicated to Walnut’s scope of activity.
Walnut outsources some of its processing and might in this instance transfer data outside of the European Union. In such a case, Walnut is committed to have the service providers contractually agree to adequate data protection.
Walnut is committed to storing your personal data no longer than necessary for the purpose for which it was processed. Furthermore, Walnut stores your personal data in accordance with the retention period imposed by current regulations.
2. Best selection and execution policy
Walnut has an obligation to act in the best interests of its clients and of the funds it manages or sub-manages. To this end, the company is subject to an obligation of best selection and best execution and applies a dedicated procedure.
Best Selection: under the supervision of Walnut’s investment committee, financial intermediaries & brokers are selected based on the following criteria:
- Intermediation / brokerage costs
- Quality and reliability of execution
- Capacity to deal with large orders
- Quality of confirmation flows and back office processes
The fund managers are required to monitor that actual execution flows are in line with the above. Quality is assessed globally and not deal by deal. Failure to execute, confirm and settle orders within Walnut’s quality standards is reported to Walnut’s management and investment committee.
Best execution: when selecting a new broker, Walnut requires that such broker provides its own best execution policy.
3. Conflicts of interest policy
Walnut has drawn up an official policy for the management of conflicts of interest and introduced specific provisions in organisational terms (means and procedures) and monitoring in order to prevent, identify and manage situations of conflict of interest which may harm the interests of its customers.
Nevertheless, if any conflicts of interest appear, the latter will be managed in the interest of the customer, that’s to say in a fair manner, and providing them with complete and relevant information.
So, in relation to situations of conflict of interest Walnut will permit itself to:
- Carry out the activity or transaction insofar as the organisation allows the potential situation of conflict of interest to be managed appropriately;
- Inform the customer should certain conflicts of interest exist and give them the necessary information on their type and origin;
- Where applicable, not carry out the activity or transaction which leads to a conflict of interest.
It must be reiterated that Walnut is a company managed independently of any banking or financial group. The internal control of the company is adapted to its size and its activity. The aim of this policy is to indicate the main measures which allow us to achieve this objective of managing conflicts of interest. In this regard:
- The agreements concluded with investment vehicle or managed or consulted portfolio providers will remind them of their obligations with regard to the duty to advise, which should prevent any situation of conflict of interests at their level;
- Walnut has drawn up guidelines and procedures for personal transactions;
- Walnut does not benefit from any retrocession of turnover fees from the depositary or other forms of retrocession from financial intermediaries selected to negotiate orders;
- There is no soft commission with these different partners;
- Walnut is totally independent of the financial intermediaries it selects;
- Walnut has drawn up guidelines and procedures on gifts and benefits.
Walnut has a duty to manage all conflicts of interest, from their detection to appropriate management. In this regard, Walnut has established an organisation which will:
1°. Avert the appearance of conflicts of interest, by raising awareness of the rules and codes of good in-house practice amongst all its staff, and by the introduction of strict rules and procedures:
- The setting up of an in-house control system;
- The separation of duties which may generate conflicts;
- Permanently ensuring that the offer of products and services which Walnut offers its customers clearly matches their profile and expectations, and is never in conflict with their interests;
- Prohibition of transactions of a personal nature which do not comply with the rules set by the company:
- Training for all staff and raising of their awareness of good professional practice;
- Prohibition of the use of the services of service providers or connected companies, unless this is declared;
- Formalisation of these rules in relation to operational procedures and normative documentation: code of ethics, procedures;
2°. Ensure that staff comply with the professional obligations to which they are subject in the exercise of their activities and comply with the regulatory provisions applicable to the latter. In this connection, organisational measures and procedural rules have been put in place to prevent conflicts of interest, in particular:
- Ethical rules which impose an obligation of discretion and confidentiality for any information collected during transactions with customers and aiming to guarantee the fairness and loyalty required in relationships with customers;
- Identification and monitoring of payments received or paid by branches when transactions are carried out with customers;
- Monitoring of personal transactions for the staff concerned;
- Transparency in relation to staff payments;
- Transparency in relation to gifts or benefits received in relation to professional activities;
- Transparency of corporate powers exercised by the heads of branches or their employees in connection with their professional duties or in a private capacity;
- Monitoring and control of the quality and legality of commitments and services provided by external service providers.
3°. Identify situations of conflict of interests which may damage the interests of customers, by drawing up a risk map of these conflicts of interests. This map will specify the activities or transactions in which a conflict of interest is likely to occur. The RCCI (Internal Control Compliance Manager) of Walnut has a duty to ensure that this mapping is kept up-to-date;
4°. Manage potential situations of conflict of interest:
- By giving customers complete and objective information, refraining from using biased arguments while indicating restrictions and risks associated with certain products or transactions;
- By requiring employees to declare the gifts and benefits they have received to the Internal Control Compliance Manager in accordance with the rules set by Walnut and, as soon as they occur, any situations of conflict of interest in which they find themselves, where applicable (the Internal Control Compliance Manager will then take charge, with the people concerned, of resolving this conflict).