Investment engagement policy
Foyer Group has established an engagement policy under the amended law of 24 May 2011 relating
to the exercise of certain shareholders’ rights at the general meetings of listed companies. This policy
highlights the general framework within which Foyer Group integrates shareholder engagement into
its investment strategy and describes how companies held are monitored on relevant issues put to a
vote at a general meeting.
This policy applies to direct investments by the group’s “insurance” subsidiaries for the subsidiaries’
equity and the technical insurance reserves of those subsidiaries, with the exception of reserves of the
contracts where the investment risk is borne by the policyholder.
WEALINS S.A. applies thus this policy for investments relating to its equity and other technical
insurance reserves, with the exception of investments made for unit-linked products.
WEALINS S.A. offers a range of unit-linked life insurance and capitalisation products whose financial
risks are fully borne by the policyholders and whose underlying investments provide access to up to
four different types of funds, depending on the product and the target market.
These may be external funds (UCITS etc.) and/or internal collective, dedicated and/or specialised
insurance funds set up and managed in accordance with Luxembourg regulatory provisions, and in
particular with the provisions of circular letter LC 15/3 of the Commissariat aux Assurances
(Luxembourg insurance supervisory authority).
Through these external and/or internal funds, policyholders of WEALINS S.A. products can invest in a
large number of strategies and investment profiles, most often managed by external and independent
financial managers and sometimes, when the regulatory provisions of the policyholders’ countries of
residence allow it, directly by the policyholders.
Investment decisions are thus taken by these external financial managers, mandated by WEALINS
S.A. in the case of internal collective or dedicated funds, or by the policyholders themselves who may,
if they so wish, seek investment advice.
The mandated financial managers undergo prior selection, which includes a due diligence and
verification process. WEALINS S.A. signs a financial management “framework agreement” with each
manager.
The financial managers manage the portfolios entrusted to them by WEALINS S.A. in accordance with
the investment policy applicable to each of the portfolios. The investment policy is annexed to the
“framework agreement”. It sets out the strategy for each portfolio and defines the asset classes and
the applicable ranges or limits for each category of assets in which the manager can freely decide to
invest. The investment policy reflects the limits set out in CAA Circular 15/3 regulating investments of
this type of asset for companies established in Luxembourg.
WEALINS S.A. is not therefore involved in the choice of the assets representing the technical
insurance reserves of the unit linked contracts or in monitoring the governance, financial performance
or capital structure of the listed companies in which it may have acquired holdings in the context of
those contracts.
WEALINS S.A. does, however, ensure that the asset managers that it has mandated use their mandate
in accordance with the investment strategy of each portfolio, within the limits of CAA Circular 15/3 or
the more stringent limits imposed by the company.
In general, WEALINS S.A. does not intend to use the voting right resulting from such holdings in listed
companies but could decide to use this voting right depending on the relevance of the issue put to the
vote, or the importance of the holding that WEALINS S.A. might acquire in a listed company.
Consult the engagement policy here: