WE PROTECT YOUR INVESTMENTS

Transcription

1 MIFID 2 WE PROTECT YOUR INVESTMENTS

2 MiFID 2 Brochure 2

3 Introduction 5 Information on services 6 Client classification 10 Profiling 11 Investment tests 14 Executing your orders 17 Continuing obligations 18 MiFID 2 Brochure 3

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5 INTRODUCTION Since 1 November 2007, the European MiFID Directive 1) (the "MiFID Directive") has provided a European framework for the protection of clients investing in financial products by defining various protection mechanisms implemented by European financial actors. The interest of the client is at the heart of this set of mechanisms, because markets and financial products are complex and entail risks inherent in any investment, although the level of these risks is variable. Ten years on, the MiFID Directive has been reviewed in light of the developments in financial markets and products, but also to take into account the lessons of the subprime crisis that erupted in In particular, the new provisions of the MiFID 2 Directive aim 2) to strengthen existing protection measures and create new ones, but also to ensure greater transparency in terms of both services provided and costs. The new provisions of this Directive came into force on 3 January In this brochure, we inform you of the main steps taken to provide you with an optimal level of protection for your investments, taking into account various factors such as your knowledge and experience of financial instruments and your investment objectives. Rather than give a purely theoretical summary of the contents of the MiFID 2 Directive, we have made this brochure instructive, explaining not only what these measures consist of but also how they provide effective protection. While it was not feasible to discuss each of the measures in detail, you will nevertheless find sufficient information below to understand their usefulness and the benefits you will derive from them. This brochure is intended for all clients of BGL BNP Paribas who invest in financial instruments. It contains additional information that is complementary to the contractual provisions contained in the General Terms and Conditions of the Bank and other agreements, but it never modifies or substitutes for them. The provisions of MiFID 2 apply mainly to securities investment services. In practice, you benefit from its application notably when you subscribe to discretionary investment management or advisory services, or an order receipt and transmission service (i.e. you manage your portfolio yourself by placing your orders directly at the bank without receiving any advice). 1) Markets in Financial Instruments Directive. 2) MiFID 2, through the MiFIR Regulation, also contains a large number of provisions aimed at reorganizing financial markets and their functioning. This point, however, goes beyond the purpose of this brochure. MiFID 2 Brochure 5

6 INFORMATION ON SERVICES The MiFID 2 Directive governs a range of financial services, most of which are provided by the bank. Discretionary management, investment advisory and order receipt and transmission services concern financial transactions performed on your account and in your securities portfolio. Each of these services corresponds to a particular offering whose characteristics are summarised below. If necessary, you will find additional information later in this brochure or in the contracts signed at the time of subscription to one of these offerings. Discretionary portfolio management What is this? Under the terms of a specific contract, you entrust management of your portfolio to the bank. Transactions are decided by the bank s specialists according to the management strategy that you have chosen in line with your investor profile. Who is responsible for investment decisions? The bank is committed to managing your portfolio in the most professional manner, based on a strategy you have chosen. However, it is not liable for changes in the price of financial products acquired and any other incident that may affect the value of an investment (e.g. bankruptcy of the issuer, fluctuation of exchange rates, etc.). We recommend that you check regularly to see if the strategy you have chosen is still right for you. To help you, you can contact your advisor at any time. In any case, it is essential that you read the management reports that are sent to you on a quarterly basis. What protection do you enjoy? The questionnaire concerning your knowledge and experience allows us to verify that you understand the characteristics and risks related to the asset classes of the financial products that may be used under the discretionary management agreement. When we find that you do not have the necessary knowledge and/or experience, we suggest providing you with all useful information relating to the characteristics of the products in question and the risks involved. In addition, we determine your investor profile via the answers you provide to the ad hoc questionnaire. Your profile then enables us to check that the management strategy is in line with your investment objectives, your ability to withstand potential losses and your tolerance for the risks related to the financial products in question. What information do you receive on costs and expenses? Before signing the discretionary management agreement, the bank provides you with an estimate of the discretionary management service fee and transaction fees based on a typical portfolio determined by the offer you have subscribed to and your investment profile. At least once a year, a summary of all these costs and expenses will be sent to you. How are your orders executed? All your orders are executed according to the bank's order execution policy, a summary of which can be found on our website MiFID 2 Brochure 6

7 What does the bank do with any distribution commission received? The bank receives from some fund managers a commission, called a distribution commission, as remuneration for its role as distributor of these funds. This commission is deducted from the fund s price (the Net Asset Value - NAV) and is subsequently transferred to the bank according to specific conditions agreed between the fund and the bank. All these distribution commissions received by the bank for management of your portfolio will be fully repaid to you and the total amount will be indicated to you. How can you know your portfolio's value? You can know the value of your portfolio at any time by logging into your secure online client space or by contacting your advisor. Each quarter, the bank sends you a management statement detailing at least the assets held in your portfolio, their valuation and the transactions carried out during the period in question. Each year, a summary of all the costs and expenses related to the management of your portfolio and their impact on its performance is also sent to you. In addition, the bank will inform you specifically if your portfolio were to fall in value by 10% or more over a given period. Investment advisory services What is this? Under the terms of a specific contract, the bank provides, at your request or spontaneously, personalized recommendations relating to one or more transactions involving financial instruments, in accordance with your investor profile. The bank only advises non-independently as specified in the contracts. Who is responsible for investment decisions? Based on your advisor's recommendations and information, you decide to instruct the bank to buy, sell or hold financial products in your portfolio. So you remain responsible for choosing your investments and monitoring your portfolio but you can contact your advisor at any time to ask for their opinion. What protection do you enjoy? The questionnaire concerning your knowledge and experience allows us to verify that you understand the characteristics and risks related to the asset classes of the financial products that you may acquire. If you are a client who is not a finance professional, when we find that you do not have the necessary knowledge and/or experience, we suggest providing you with all relevant information about the characteristics of the product you are considering buying and the risks entailed, allowing you to make your investment decision on a fully informed basis. In addition, we determine your investor profile via the answers you provide to the ad hoc questionnaire. Your profile then enables us to check that the advice provided is in line with your investment objectives, your ability to withstand potential losses and your tolerance for the risks related to the financial products in question. The advice provided by the bank is confirmed by a specific document entitled "Statement of Suitability" communicated before the confirmation of your instructions, allowing you to adapt your decisions if necessary. MiFID 2 Brochure 7

8 What information do you receive on costs and expenses? Before signing the advisory agreement, the bank provides you with an estimate of the advisory service fee and the transaction fees based on a typical portfolio determined by the offer you have subscribed to and your investment profile. Before the execution of each of your transactions, you will receive an estimate of the costs and expenses (including possible distribution commissions, see below) entailed by the proposed transaction and an illustration of their impact on the expected return. This estimate is indicated to you before the confirmation of your instructions. At least once a year, a summary of all these costs and expenses will be sent to you. How are your orders executed? What does the bank do with any distribution commission received? All your orders are executed according to the bank's order execution policy, a summary of which can be found on our website The bank receives from some fund managers a commission, called a distribution commission, as remuneration for its role as distributor of these funds. This commission is deducted from the fund s price (the Net Asset Value - NAV) and is subsequently transferred to the bank according to specific conditions agreed between the fund and the bank. Depending on the service offer subscribed to, the amount of these distribution commissions received is either retained by the bank or transferred to your account. In either case, the amount of the bank's commission is shown in the estimated costs and expenses (see above). How can you know your portfolio's value? You can know the value of your portfolio at any time by logging into your secure online client space or by contacting your advisor. At least once a year, the bank sends you a statement detailing at least the assets held in your portfolio and their valuation. In addition, each year, the bank tells you whether your portfolio matches your investor profile, and indicates all costs and expenses related to the management of your portfolio and their impact on its performance. Order Receipt and Transmission What is this? Who is responsible for investment decisions? The bank receives your instructions for buying and selling financial instruments and transmits them to a partner to ensure their execution. The bank can give you information about the products you plan to buy or sell, but the law prohibits any investment advisory relationship. You remain responsible for choosing your investments and monitoring your portfolio. What protection do you enjoy? The questionnaire concerning your knowledge and experience ensures that you understand the characteristics and risks related to the asset classes of the financial products that you may acquire. If you are a non-finance-professional client, when we find that you do not have the necessary knowledge and/or experience, we suggest providing you with all relevant information about the characteristics of the product you are considering buying and the risks entailed, allowing you to make your investment decision on a fully informed basis. MiFID 2 Brochure 8

9 What information do you receive on costs and expenses? In addition to the price grid received when you open your account, before the execution of each of your transactions you will receive an estimate of the costs and expenses (including possible distribution commissions, see below) entailed by the proposed transaction and an illustration of their impact on the expected return. This estimate is indicated to you before the confirmation of your instructions. At least once a year, a summary of all these costs and expenses will be sent to you. How are your orders executed? What does the bank do with any distribution commission received? How can you know your portfolio's value? All your orders are executed according to the bank's order execution policy, a summary of which can be found on our website The bank receives from some fund managers a commission, called a distribution commission, as remuneration for its role as distributor of these funds. This commission is deducted from the fund s price (the Net Asset Value - NAV) and is subsequently transferred to the bank according to specific conditions agreed between the fund and the bank. The amount of these distribution commissions received and held by the bank is shown in the estimated costs and expenses (see above). You can know the value of your portfolio at any time by logging into your secure online client space or by contacting your advisor. At least once a year, the bank sends you a statement detailing at least the assets held in your portfolio and their valuation. Order execution and the custody and administration of financial instruments are other examples of financial services provided by the bank for which you will find information in this brochure and/or in other documents or in specific contracts. MiFID 2 Brochure 9

10 CLIENT CLASSIFICATION The MiFID 2 Directive allows a more or less intense level of protection to be provided depending on the category in which each client is classified according to predefined criteria. There are three categories: non-finance-professional clients, finance-professional clients, and eligible counterparties. In order to give you the fullest protection, by default the bank classifies new individual clients in the category of non-finance-professional clients. As a non-finance-professional client 1), you can apply to be classified as a professional client, as long as you meet the eligibility criteria set out in the directive. To know these criteria, you can: consult the MiFID 2 questionnaire concerning your knowledge and experience; contact your advisor. Given the services provided, institutional clients are generally classified as eligible counterparties. In any event, if BGL BNP Paribas provides you with an investment service governed by the MiFID 2 Directive, you will receive notification of your classification when you enter into a relationship with the bank. Attention: It is important to note that the merit of your application for classification as a professional is evaluated by the bank given that less protection is attached thereto. You will be notified of the rights you forfeit by opting for such a classification. Once the bank s confirmation of your new classification has been obtained, you remain free to have it changed by asking to be re-classified as a non-finance-professional client. MORE INFORMATION The new MiFID 2 Directive changes only one aspect of customer classification: municipalities and other local authorities were categorized by the first directive as professional clients. MiFID 2 requires banks to classify them as of 3 January 2018 in the category of non-financeprofessional clients. If you are concerned as a representative of a municipality or a local authority, know that you can apply to be classified again in the category of finance-professional clients provided that you meet the ad hoc criteria. 1) Namely, retail clients within the meaning of the MiFID Directive. MiFID 2 Brochure 10

11 PROFILING The bank is committed to meeting your needs by customizing its services according to the terms and conditions specific to their nature. Of course, a longterm relationship is always the best way to provide you with services that best meet your needs. Nevertheless, investment services such as discretionary management, investment advisory services and order receipt and transmission require customization specifically governed by the MiFID 2 Directive, entailing the establishment of your profile. Via this process, we always inquire about your knowledge and experience of financial instruments, and your investment objectives and financial situation. The MiFID 2 Directive has not made any fundamental changes except that your risk tolerance and your ability to withstand losses are now taken into account in establishing your profile. MORE INFORMATION To allow us to offer you the new protections provided for by the MiFID 2 Directive, we did not just adapt our MiFID questionnaires; we fully reviewed them and integrated them into a new control tool developed specifically for this purpose. This tool not only allows for new protection requirements, but also enhances the protection you already have. If you are already a client of the bank, and it has not yet been done, it is in your interest that we ask you to fill out the new MiFID questionnaire in order to benefit from the most demanding level of protection. Questionnaires used for profiling The implementation of this protection is based on two questionnaires: Questionnaire concerning your knowledge and experience The customization of our services begins with an understanding of your knowledge and experience of the various asset classes of financial products, which we are able to obtain thanks to your answers on this form. MORE INFORMATION We invite you to fill out this questionnaire if you have subscribed to an offer for discretionary management, investment advisory services or order receipt and transmission. On this form, you will also find the eligibility criteria for the " Finance-Professional Client" classification (see above). MiFID 2 Brochure 11

12 Questionnaire concerning your objectives and your risk tolerance Through targeted questions concerning your investment objectives and your risk tolerance, a bespoke tool determines which of the four typical profiles selected by the bank fits you. These four profiles are: Low risk Moderate risk High risk Very high risk Your investment horizon is roughly less than 3 years. You are looking primarily for the preservation of your capital, by limiting your investment risk. The assets in your portfolio will mainly produce regular but moderate income. Your portfolio will be exposed to low volatility. Your investment horizon is between 3 and 5 years. You seek a moderate growth in your capital, by a fair balance between capital appreciation of your assets and income generation. The assets in your portfolio will be more varied, generating both regular and irregular income. Your portfolio will be exposed to moderate volatility in the medium and long term. Your investment horizon is between 5 and 10 years. You seek significant growth in your capital, by a large increase in the value of your assets and high income generation. The assets in your portfolio will be very varied, generating mainly irregular income. Your portfolio will be exposed to increased volatility in the short and medium term. Your investment horizon is more than 10 years. You are looking for strong growth in your capital, focusing on capital gains. The assets in your portfolio will be among the most risky, with their income exposed directly to market fluctuations. Your portfolio will be constantly exposed to high volatility, especially in the short term. MORE INFORMATION This questionnaire should not be filled out if you have subscribed to an order receipt and transmission offering, but should be for any subscription to an advisory or discretionary management offering. It is essential that you answer the questions taking into account your investment objectives and your risk tolerance in general, i.e. for all your financial assets, whether held in a bank account or in several accounts, even if they are held with banks other than BGL BNP Paribas. The particular objective you intend to assign to the portfolio you entrust to us may correspond to the profile calculated on the basis of the answers given. In this case, if you have subscribed to an advisory contract, advice will be provided according to this calculated profile; if you have subscribed to a discretionary management contract, the management strategy will correspond to this calculated profile. If, however, you consider that the calculated profile does not take into account this specific objective, you can opt for a special profile by completing a specific form. This form should be used with the utmost care, because your portfolio will be managed according to a profile that deviates from your investor profile in general. Therefore, we ask you to note on this waiver form the specific objective that you assign to this portfolio, making it possible to monitor over the years the advisability of maintaining the special profile. You will find additional information on the concepts presented above on the cover page of the "Investor Profile" questionnaire. MORE INFORMATION We wanted to further strengthen the MiFID 2 protection mechanism by including a simulation of the historical performance of a model portfolio corresponding to each of the four profiles. Apart from the name of the profile, calculated based on your answers, and its description, we consider it important to show you how a model portfolio is likely to behave during a major crisis so that you can be aware of this. For example, in view of the simulation of the historical performance of the model portfolio corresponding to the calculated profile, if you think that the calculated profile is too risky for the specific purpose of your portfolio, you can of course fill out a waiver request for the profile and choose a lower-risk profile. MiFID 2 Brochure 12

13 Miscellaneous questions How do I fill out the questionnaires? We have made various channels and processes available to you to help you fill out the questionnaires in the way that is most convenient for you. Do not hesitate to call your advisor on this point or, if necessary, consult your secure online client space. If you are a new client, the questionnaires must be filled out at the same time as the other documents for opening the account or, in any case, when opening your securities account. I have filled out the questionnaires in the secure online client space and wish to deviate from the calculated profile. How do I do this? Simply fill out the waiver request form, indicating the specific objectives that you want to assign to your portfolio. The form must then be sent to the bank to have your advisor review the validity of the waiver request. It is possible in this context that they will contact you to speak with you in person. What should I do if I have several accounts? When you have several accounts in our bank, you only need fill out the questionnaire once! Its outcome will impact each of your accounts, while you may adjust the specific objectives of each account as appropriate using the waiver form. This solution is also valid if you have one account under an order receipt and transmission offering and another under an advisory/discretionary management offering: you fill in a single questionnaire relating to your knowledge and experience and it will be taken into consideration for all of your accounts. On the other hand, a waiver request is valid only for the account for which it was requested and accepted. How long is my profile valid? Your profile remains valid as long as nothing changes in your personal, family and/or professional situation. To ensure this periodically, we will ask you to confirm, even verbally, that there has been no change in your situation. This will confirm that your profile is still in line with your investment objectives and your risk tolerance. What if changes in my situation occur in the meantime? Your relationship with the bank is a long-term one, and what is true when determining your profile will not necessarily be so tomorrow: your income may increase, your family grows, you change your job or retire, you receive a gift or an inheritance, etc. It is also possible that financial markets move in such a way that you would be willing to take a little more risk for a better return or, conversely, that they prompt you to adopt a more cautious profile. In this case, we strongly recommend that you contact your advisor to talk with them directly. Some changes in your situation may have no impact on your investor profile, while others will require adjustments that should be taken into account quickly, especially if you have subscribed to a discretionary management offering. In any case, we will ask you to fill out a new questionnaire to determine your profile taking into account the new answers you give. The specific objective I had chosen for management of my portfolio has changed. What should I do? It is just as important that you let us know about this change, because then the special profile will more than likely have to be reviewed. Again, direct contact with your advisor is the recommended procedure, but you can also submit a new waiver request containing the new objective. There are several joint account holders and our individual profiles are different. How will the portfolio be managed? In this case, by default we adopt the most conservative profile of all the joint account holders. If, however, you wish to have another type of profile adopted, you may fill out a waiver request form, signed by all the joint account holders, specifying the reason for the waiver request. This special profile can be terminated at any time by one or all of the joint account holders, and the rule of the most conservative profile will then be applied by the bank. MiFID 2 Brochure 13

14 INVESTMENT TESTS The MiFID 2 Directive requires that various tests be performed in your interest. We have made every effort to ensure that these tests are easily understandable and fit naturally into the investment process. Investment advisory and order receipt and transmission offerings When you are considering investments in financial products, the bank conducts two types of tests depending on whether you have subscribed to an investment advisory offering or an order receipt and transmission offering. Testing the appropriateness of the transactions If you are a non-finance-professional client, for both of these services, you are assured that the bank will verify that you have the necessary knowledge and experience of the asset class containing the financial instrument that you plan to acquire, based on the form relating to your knowledge and experience (see, above, the "Profiling" part of the questionnaire concerning your knowledge and experience). MORE INFORMATION In order to ensure the highest level of protection, the bank carries out this test for all asset classes and not only for those containing the highest-risk products as required by the MiFID 2 Directive. When you have the necessary knowledge and experience, your order is transmitted for execution without further formalities regarding this test. If it turns out that you do not have the necessary knowledge and/or experience, the bank will offer to provide you with all relevant information so that you are able to understand not only the characteristics of the product in question but also the risks inherent in it. Then, if you confirm your order, we will forward it for execution and the questionnaire concerning your knowledge and experience will be automatically updated. However, if you do not wish to receive the information on the characteristics and risks, your order can be transmitted for execution only based on your explicit confirmation. MORE INFORMATION There are more and more fact sheets on the financial products you want to buy. These documents are sometimes even standardized by European regulations to allow you to read them easily regardless of the product s producer. We urge you to consult these documents before making your investment decision. The main characteristics and the risks inherent in the types of financial products are mentioned in the Bank's "Investor Panorama" brochure that was given to you when you opened your account. You can also obtain this brochure on request. Read it immediately, given the great variety of financial instruments and specific features that could have an influence on your choice. For example, one bond may be very different from another. One can be fixed-rate, the other variable-rate, and yet another inflation-indexed or convertible or even hybrid. Any investment in financial products is risky, but this risk is highly variable from one type of product to another and an informed knowledge of the products will avoid you being disappointed either because their performance is below your expectations, or due to a loss. MiFID 2 Brochure 14

15 Testing the suitability of the transactions Wanting to provide you with high-quality counselling, the BNP Paribas Group monitors several thousand securities on which we have formed an opinion. These securities are part of a "Recommended Universe" that the bank allows you to acquire. MORE INFORMATION Except in special cases, you can also acquire securities that are not part of this "Recommended Universe". In that case, we express no opinion on such securities. Once you have subscribed to an investment advisory offering, the bank will carry out a suitability test on the planned investments based on the profile determined during your profiling (see, above, the "Profiling" part of the questionnaire concerning your objectives and your risk tolerance"). The risk budget resulting from your profile determines the limits of your risk appetite. The suitability test therefore allows you to compose and arbitrage your portfolio taking into account your personal, family and professional situation and in accordance with the objective you have assigned to your portfolio. Whenever you consider carrying out a transaction that is not in line with this framework, we may not give you any advice that would have the effect of degrading your risk budget beyond the fixed limit. Any transactions you perform will then be executed by the bank at your own risk. As part of an investment advisory offering, a specific document entitled "Statement of Suitability" is sent to you before you confirm your order. This document provides various useful information for making your investment decision, such as the composition of your portfolio and your risk budget before and after simulation, as well as the bank's advice. You should diligently consult this document before making your decision to transmit your basket of orders to the market or not. This suitability test is performed regardless of the communication channel that you use to carry out your transactions. It goes without saying that contact with your advisor will enable them to fully ascertain the suitability of the investments you are considering by examining, where appropriate, any factor relating to a specific need (e.g. the hedging of a transaction, or a specific investment duration). MORE INFORMATION To allow for technological change, we have developed our tools so that the suitability test on all the transactions you initiate can be performed via your secure online client space when you have subscribed to an investment advisory offering. This way, you will always know your portfolio s risk profile before and after simulation of the transactions you plan to carry out. How is this test carried out? When, on your own initiative or based on personalized counselling by your advisor, you are considering a transaction involving a single financial instrument or multiple orders, the bank performs a simulation of the impact of the product(s) in question on the "risk budget" relating to your profile, taking into account the risk rating (on a scale from 1 to 7) of said financial product(s). The result of this test is communicated to you by your advisor if you are in contact with them, or via your secure online client space when you use this channel to carry out your transaction. MiFID 2 Brochure 15

16 Discretionary management offering Establishing your investor profile is essential when you subscribe to a discretionary management offering. Based on your profile, we ensure that you have sufficient knowledge of the characteristics and risks related to the types of financial products that may be invested on your behalf according to the management strategy you have chosen. Of course, the discretionary management contract you sign provides information on the types of financial products in question. After signing this contract, the bank carries out portfolio management operations on your behalf and monitors the suitability of your portfolio with due regard to the management strategy you have chosen based on your profile. As you will have understood from reading this brochure, the success of your investments is strongly linked to your relationship with your advisor. This relationship will grow through constant contact with the bank. Since opportunities for contact are less frequent when the bank performs discretionary management of your portfolio, if you have subscribed to such an offering it is essential to read the management reports that are sent to you regularly, to verify that the management is still in line with your objectives and your personal situation. If this is not the case, it is essential that you contact your regular advisor without delay. MiFID 2 Brochure 16

17 EXECUTING YOUR ORDERS Processing of your orders concerning financial products You have given an order for a financial product? It is then up to the bank to ensure its correct execution. To do this, we have taken a series of measures relating to the processing of orders to allow their rapid execution as they arrive. Of course, the execution procedures vary widely depending on the nature of the financial product in question, which is why the implementation deadlines can also be highly variable. The bank will warn you if there is a serious difficulty in executing your order and will look for solutions with its correspondents in charge of actual execution. In any event, as of the execution of your orders and until the receipt or sale of the financial products, you will receive appropriate information on ongoing operations and their performance. Best execution policy Given the wide variety of financial products, but also of execution procedures due to market organization, the bank has determined a best execution/selection policy, under which all its clients financial-product orders are executed according to predefined parameters. These policies are aimed at obtaining the best result, which is determined by factors such as price, cost, speed and probability of execution. Please note, however, that this does not constitute a guarantee of best execution for all the orders taken individually, but means that each individual transaction will be executed according to standard procedures adopted for all orders of the same type. The bank may not be able, in full or in part, to execute your orders according to its best execution/selection policy if your instruction contains specific features (e.g. the place of execution). In this case, your order will be executed according to the specific features that you have decided. You will find more details about the bank's best execution policy in the dedicated brochure available on request or on the bank's website ( MiFID 2 Brochure 17

18 CONTINUING OBLIGATIONS Acting in the interest of clients is a concept that is not materialized merely by a significant number of measures concerning the provision of services. We have also put in place a system with a range of measures ensuring a constantly high quality of your investments. Preventing conflicts of interest In order to best serve your interests, the bank has adopted a series of provisions to prevent situations of conflict of interest from occurring. These provisions are intended to prevent the bank from unduly serving its own interests or those of other clients rather than your interests. In short, these measures are preventive (in particular: the adoption of a Code of Conduct, the establishment of Chinese walls ensuring the segregation of duties, security measures governing the dissemination of information within the bank, insider trading prevention standards, etc.) and control-focused, by regularly reviewing the bank's activities to identify situations that could be the source of conflicts of interest. These provisions are described in the document entitled "The Conflict of Interest Policy" available on request and on the bank's website ( Safeguarding financial instruments On a continuing basis, the bank ensures that your assets (funds and financial instruments) registered in its books undergo safeguard measures to ensure their preservation. These measures include, inter alia, separation of the bank's assets from those of its clients, keeping the asset register and account, performing reconciliations and sending to all clients a statement of their financial assets. Other measures have also been put in place when your securities are deposited with intermediaries. In addition, you will find more information on the system of compensation for funds and financial assets in the brochures entitled "Information on the protection of your deposits" and "Information on the protection of your investments" available on request and also on the bank's website ( MiFID 2 Brochure 18

19 MiFID 2 Brochure 19

20 BGL BNP PARIBAS S.A. 50, avenue J.F. Kennedy L-2951 Luxembourg Corporate and Trade Register Luxembourg: B 6481 Marketing Communication January 2018