Core Investments Market Sounding Process

From 2019-2021 AXA IM established a new operating model bringing together core Fixed Income, Equities and Multi-Asset platforms to make up AXA IM Core. Following this alignment and in the context of EU Market Abuse Regulation (MAR), AXA IM Core is communicating how it interacts with brokers when it comes to market soundings below.

The purpose of this notice is to provide information on how your Firm must approach AXA IM Core (primarily Judgemental Equities and Fixed Income teams) with regards to market soundings globally. We request your cooperation in respecting the updated process as outlined below. 

From 20 April 2020, AXA IM Core  has asked that all market soundings are directed to the Core Investments Market Sounding Coordination Team via email. The team acts as a gatekeeper between AXA IM investment teams and brokers for all market sounding contact requests and is responsible for coordinating the interest in the information internally before coming back to the broker. The team will accept wallcrossing terms/compliance scripts as persons authorised by AXA IM to act as Market Sounding Recipients and consent to receiving inside information to facilitate the marketing sounding of Portfolio Managers.

Please do not contact Fund Managers directly about market soundings without first obtaining permission from the Core Investments Market Sounding Coordination Team.  Please note that permission will need to be obtained separately for each market sounding.

The process for approaching Core Investments with market soundings is divided into two steps:

Step 1 - Scoping:

When contacting the Core Investments Market Sounding Coordination Team, you will be asked to confirm whether your firm considers the information you intend to share to be:

i) A market sounding in scope for MAR

ii) Inside Information

iii) For the attention of Framlington Equities or AXA IM Fixed Income;

Framlington Equities

A)    If IPO related and the answer to both i) and ii) is NO:

Your firm will be asked to confirm the following to us:

1. Has a request for admission to trading on a regulated market / MTF or OTF been made?
2. Is the intention to IPO stated publicly?
3. Are there any financial instruments to which this sounding relates (e.g parent company, listed debt etc..) that are publicly listed?

Based on the responses we’ll either confirm you can contact any PM you wish – or take this through our process to formally track the information disclosed as per our standard Market Sounding process.

B)    If answer to either i) or ii) is YES:

Your firm will be asked to confirm the following to us:

• Issuer Name(s)
• ISIN(s) (if applicable)
• Bloomberg Ticker(s)
• Type of request: e.g. Placing/Capital Raise, IPO, Sale or acquisition etc.
• Region: Continental Europe (excluding UK), UK, North America, Developed Asia (including Japan), Emerging Markets (Asia), Emerging Markets (EMEA), Emerging Markets (Latin and South America);
• Company size: Small Cap, Mid Cap, Large Cap;
• Sector/industry: Energy, Material, Industrials, Consumer Discretionary, Consumer Staples, Healthcare, Financials, Information Technology, Telecommunication Services, Utilities, Real Estate;
• Cleansing period: Expected announcement date.

Fixed Income

Your firm will be asked to confirm the following to us:

• Issuer Name(s)
• ISIN(s) (if applicable)
• Bloomberg Ticker(s)
• Region: Continental Europe (excluding UK), UK, North America, Developed Asia (including Japan), Emerging Markets (Asia), Emerging Markets (EMEA), Emerging Markets (Latin and South America);
• Sector/industry: Energy, Material, Industrials, Consumer Discretionary, Consumer Staples, Healthcare, Financials, Information Technology, Telecommunication Services, Utilities, Real Estate;
• Fixed Income Area: Covered, Financial, Industrial, Quasi & Foreign Government, Securitized, Sovereign;
• Maturity
• Cleansing period: Expected announcement date.

Step 2 – Approval to contact Portfolio Managers:

The Coordinator will revert to you with the full set of AXA IM Core Portfolio managers interested in and permitted to receive the market sounding. You may at this stage contact the named Portfolio Manager(s) directly, ensuring your firm engages in line with Article 10(5) which sets clearly your additional obligations. In addition, your Firm should disclose further that calls made to AXA IM UK are expected to be recorded by yourselves in compliance with MAR and ESMA Guidelines Section 2.9 (Written minutes or notes and recording of telephone calls) and if contact is made by telephone, AXA IM UK reserves the right to record the telephone conversation Please ensure that no inside information is communicated without the Portfolio Manager’s consent.

Please contact the Core Investments Market Soundings Coordination Team in case of questions.

Read more

• General Important Information
• Markets in Financial Instruments Directive
• Capital Requirements Directive
• Country by Country Reporting
• Fund Charges and Costs
• Important Information for Unitholders