Pictet Asset Management (Europe) S.A. (the “Management Company”) has adopted a complaints policy, which provides a common, clear and precise understanding of the way in which the Management Company and its branches (the “Branches”) handles clients' complaints, including a clear definition of the roles and responsibilities of the different stakeholders.
The Management Company is subject to the prudential supervision of the Luxembourg financial services regulator, the Commission de Surveillance du Secteur Financier (the “CSSF”).
The purpose of this document is to provide clear, precise and up-to-date information on the Management Company’s and the Branches’ implemented procedures for managing client’s complaints which comply with the requirements of applicable laws and regulations1.
A complaint can be any written, verbal or electronic communication from a (potential) client or investor to express dissatisfaction and can be submitted free of charge, in an official language of their home country.
If you wish to express your dissatisfaction/complaint, you have to contact your client relationship manager or any other direct contact within Pictet Asset Management. You can also write an email to the following address: PAM_Complaint@pictet.com. When contacting Pictet Asset Management with a complaint, the following information has to be included:
You will receive an acknowledgement of receipt of your complaint, together with the name and contact information of the person in charge of its follow-up, within three (3) working days from the date of receipt.
We are committed to provide you with an answer to your complaint within one (1) month from the date of receipt of your complaint. Where an answer cannot be provided within this period, we will inform you of the delay and the date at which the answer is likely to be provided to you.
In the case you might not receive a response or you are not satisfied with the response you received, you may contact the conducting officer of the Management Company in charge of complaint handling (the “Conducting Officer”), who shall handle the complaint with the support of the compliance team:
Mr Gérard Lorent
Conducting Officer in charge of complaints handling
15, avenue J.F. Kennedy
L-1855 Luxembourg
If, after that, you still consider you did not receive a complete, clear and justified response, you have the possibility of recourse by opening a procedure to resolve the claim out of court with the CSSF.
Please note that you may file your request with the CSSF within one (1) year after you filled your com-plaint with the Management Company.
The opening of the procedure for an out-of-court resolution of complaints to the CSSF is subject to the following cumulative conditions:
You can refer your complaint free of charge to the CSSF in French, German, Luxembourgish or English:
In order to facilitate the filing, the CSSF publishes a form on its website, and we request you to submit your request in accordance with CSSF requirements established on the CSSF website and the applicable form available. Please refer to Article 5 (2) of the CSSF Regulation 16-07 relating to out-of-court complaint resolution.
For complaints raised in relation to a service or product provided through the Branches, a proposition to resolve the case out of court is made in reference with the local process set by the local National Competent Authority
Once the CSSF has received a request that meets all the conditions, it will transmit a copy thereof to the Management Company and will ask the Conducting Officer in charge of complaints to take position within a period up to one (1) month from the date at which the file was sent. The CSSF will inform you of this transmission.
As soon as the CSSF is in possession of all the documents or relevant information, it confirms to you and to the Management Company in writing or by way of a durable medium that it has received the complete request and the date of receipt of the complete request.
Within three (3) weeks after receipt of the complete request, the CSSF informs you and the Management Company:
Once the request analysis has been completed by the CSSF, it will send to the involved parties a conclusion letter with the reasons for the position taken:
You and the Management Company are informed that the conclusions reached by the CSSF after the analysis of the request may be different from the order of a court applying legal provisions.
We are also informed by the CSSF that due to the fact that the reasoned conclusions of the CSSF are not binding, we are free to accept or refuse to follow them. In the conclusion letter, the CSSF draws our attention to the possibility to seek remedies through legal proceedings; in particular, if we fail to reach an agreement after the CSSF issued its reasoned conclusion.
Once conclusion letter is received by the CSSF, both you as complainant and the Management Company will have to inform the CSSF whether each party decides to accept, to refuse or to follow the solution proposed by the CSSF within the timeframe defined by the CSSF in its conclusion letter.
The CSSF issues reasoned conclusion within ninety (90) days, as from the receipt of a complete request (i.e. in possession of all the documents or relevant information).
In case of highly complex files, the CSSF can extend the 90-day period by informing you and the Management Company of the approximate necessary extension as soon as possible and at the latest before the end of the 90-day period.
The CSSF will close the procedure if one of the following occurs:
Important legal information
This marketing material is issued by Pictet Asset Management (Europe) S.A.. It is neither directed to, nor intended for distribution or use by, any person or entity who is a citizen or resident of, or domiciled or located in, any locality, state, country or jurisdiction where such distribution, publication, availability or use would be contrary to law or regulation. The latest version of the fund‘s prospectus, Pre-Contractual Template (PCT) when applicable, Key Information Document (KID), annual and semi-annual reports must be read before investing. They are available free of charge in English on www.assetmanagement.pictet or in paper copy at Pictet Asset Management (Europe) S.A., 6B, rue du Fort Niedergruenewald, L-2226 Luxembourg, or at the office of the fund local agent, distributor or centralizing agent if any.
The KID is also available in the local language of each country where the compartment is registered. The prospectus, the PCT when applicable, and the annual and semi-annual reports may also be available in other languages, please refer to the website for other available languages. Only the latest version of these documents may be relied upon as the basis for investment decisions.
The summary of investor rights (in English and in the different languages of our website) is available here and at www.assetmanagement.pictet under the heading "Resources", at the bottom of the page.
The list of countries where the fund is registered can be obtained at all times from Pictet Asset Management (Europe) S.A., which may decide to terminate the arrangements made for the marketing of the fund or compartments of the fund in any given country.
The information and data presented in this document are not to be considered as an offer or solicitation to buy, sell or subscribe to any securities or financial instruments or services.
Information, opinions and estimates contained in this document reflect a judgment at the original date of publication and are subject to change without notice. The management company has not taken any steps to ensure that the securities referred to in this document are suitable for any particular investor and this document is not to be relied upon in substitution for the exercise of independent judgment. Tax treatment depends on the individual circumstances of each investor and may be subject to change in the future. Before making any investment decision, investors are recommended to ascertain if this investment is suitable for them in light of their financial knowledge and experience, investment goals and financial situation, or to obtain specific advice from an industry professional.
The value and income of any of the securities or financial instruments mentioned in this document may fall as well as rise and, as a consequence, investors may receive back less than originally invested.
The investment guidelines are internal guidelines which are subject to change at any time and without any notice within the limits of the fund's prospectus. The mentioned financial instruments are provided for illustrative purposes only and shall not be considered as a direct offering, investment recommendation or investment advice. Reference to a specific security is not a recommendation to buy or sell that security. Effective allocations are subject to change and may have changed since the date of the marketing material.
Past performance is not a guarantee or a reliable indicator of future performance. Performance data does not include the commissions and fees charged at the time of subscribing for or redeeming shares.
Any index data referenced herein remains the property of the Data Vendor. Data Vendor Disclaimers are available on assetmanagement.pictet in the “Resources” section of the footer. This document is a marketing communication issued by Pictet Asset Management and is not in scope for any MiFID II/MiFIR requirements specifically related to investment research. This material does not contain sufficient information to support an investment decision and it should not be relied upon by you in evaluating the merits of investing in any products or services offered or distributed by Pictet Asset Management.
Pictet AM has not acquired any rights or license to reproduce the trademarks, logos or images set out in this document except that it holds the rights to use any entity of the Pictet group trademarks. For illustrative purposes only.