Effective December 31, 2019


As part of its monitoring of potential conflicts of interest, Birdee considers it appropriate to be transparent about its policy on the choice of investment universe. The purpose of this document is to clarify any questions you may have regarding a potential conflict of interest between the selection of the ETFs making up our portfolios and BNP Paribas Asset Management’s majority shareholding in our parent company Gambit Financial Solutions.

As an investment firm providing discretionary portfolio management services to retail clients, one of Birdee’s tasks is to select the investment products (ETFs or funds) to be included in the eligible universe for the strategic allocation process. As such, we are responsible for conducting a careful due diligence of each qualified item, taking into account the interests of the end client.

Within this framework, Birdee is led to select securities from BNPP Asset Management. Indeed, BNP Paribas Asset Management’s main activity is the management and marketing of investment funds and ETFs on the market through distributors. BNP Paribas Asset Management thus generates its income through a management fee charged at the fund or ETF level, reflected in the net asset value (NAV).

In this context, a distinct conflict of interest may arise from the capitalist relationship between the two companies.

However, this needs to be qualified and mitigated.

In the context of discretionary management contracts for retail clients, Birdee generates its income through management fees expressed as an annual percentage of the average amount of assets under management.

Birdee neither accepts nor receives retrocessions on investment products in any form whatsoever.

Moreover, in the selection of invested ETFs, Birdee’s responsibility towards its clients implies objective due diligence, based on qualitative and quantitative criteria. Each ETF is thus carefully selected through a pre-selection process on TrackInsight (ETF-independent rating platform), as well as additional quality control at Birdee.

Different objective criteria are used such as: UCITS qualification, underlying benchmark exposure, cost (TER), replication methodology, dividend policy. In addition, the socially responsible investment character of the funds also remains crucial.

Finally, the final decision on the selection of ETFs is left to the free choice of the investment committee, which acts completely independently. Each selected ETF validation is then documented, signed and archived.

Finally, we would like to assure you that the prime selection criterion, in addition to the objective elements developed above, is above all compliance with investor protection regulations. Our shareholders will never influence our decisions at this level. Our clients remain at the centre of our concerns and those of our Investment Committee.