Santiago Principles Self-Assessment


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  • Pillar 1: Legal
  • Pillar 2: Institutional
  • Pillar 3: Investment
Principle 1

1. The legal framework for the SWF should be sound and support its effective operation and the achievement of its stated objective(s).

1.1. The legal framework for the SWF should ensure legal soundness of the SWF and its transactions.

1.2. The key features of the SWF’s legal basis and structure, as well as the legal relationship between the SWF and other state bodies, should be publicly disclosed.

Document: Act No.2012-1599 December 31st, 2012 [In French]

Bpifrance is a joint holding company, uniting the activities of the public institution OSEO, CDC Entreprises and the Strategic Investment Fund (Fonds Stratégique d'Investissement or "FSI"). Act no. 2012-1559 of December 31st of 2012 amended Order no. 2005-722 of June 29th of 2005. In turn, OSEO laid down the legal framework and governance arrangements to sanction the creation of Bpifrance.

Bpifrance Financement is a financial company (Compagnie Financière) incorporated under the form of a limited company (Société Anonyme) governed by Article L517-1 of the Code Monétaire et Financier and et Seq. [In French]

Ownership of Bpifrance is evenly split (49,18% each) between the French State (through the “EPIC Bpifrance”) and the Caisse des Dépôts et Consignations (the "CDC). Private commercial banks own 1,35% of Bpifrance’s capital. Bpifrance has three main subsidiaries dedicated to financing, export insurance and investments. The investment activities are operated through a management company (Bpifrance Investissement) licensed by the French Financial Market Authorities (AMF).

Therefore, all aspects of its governance, organization and compliance rules follow the French regulation, specifically Article L 531-1 et Seq of the French Financial and Monetary Code.

[In French] which is directly transposed from the European Union Regulation on asset management, and notably Article 49 of Règlement de l’Union Européenne n°468/2014

[In French]

Principle 6

6. The governance framework for the SWF should be sound and establish a clear and effective division of roles and responsibilities in order to facilitate accountability and operational independence in the management of the SWF to pursue its objectives.

Bpifrance is managed by a CEO and a Deputy CEO. Several executive directors lead distinct and various activities which prevent conflicts of interest. Due to its dual activities of investment and financing, Bpifrance is under the supervision of the AMF [In French] as well as the Banking supervisor (ACPR). [In French]

Hence, sovereign wealth fund’s activities (Bpifrance Investissement) are subject to both French asset and market regulations.

The board of the main entities of Bpifrance Groupe is composed of shareholders’ representatives, as well as independent/qualified members. Article 3 of Act No.2012-1599 December 31st, 2012 [In French].

Our website provides more information to support our high level of corporate standards and transparency. [In French]

Principle 18

18. The SWF’s investment policy should be clear and consistent with its defined objectives, risk tolerance, and investment strategy, as set by the owner or the governing body(ies), and be based on sound portfolio management principles.

18.1. The investment policy should guide the SWF’s financial risk exposures and the possible use of leverage.

18.2. The investment policy should address the extent to which internal and/or external investment managers are used, the range of their activities and authority, and the process by which they are selected and their performance monitored.

18.3. A description of the investment policy of the SWF should be publicly disclosed.

Bpifrance established an investment policy which is available on its website. [In French]. 

Annual reports and investor presentations published on the website provide additional insights relating to asset allocation, risk and return objectives as well as preferred sectors to invest in.

The investment strategy is long term, encompasses the management’s market wisdom and risk is evaluated seriously. Moreover, Bpifrance invests in companies of all sizes

In terms of internal managers, Bpifrance takes pride in posting all employment offerings on the website to the general public. [In French]