Order Execution Policy

Transcription

1 Order Executin Plicy ( SSGMIL ) prvides trading services in equities, fixed incme, futures and ptins, and freign exchange within State Street Glbal Markets, a divisin f State Street Crpratin, ne f the wrld s leading prviders f financial services t institutinal investrs. When executing r transmitting yur rder(s) we take all reasnable steps t prvide yu with the best pssible result n a cnsistent basis by taking int accunt any specific instructins 1 we receive frm yu and a range f executin factrs in accrdance with the principles described in this Order Executin Plicy ( Plicy ). 1. Scpe Our bligatin t cnsistently prvide yu with the best pssible result in accrdance with the Plicy applies in respect f any rder yu may give us in any financial instrument as defined by the Markets in Financial Instruments Directive ( MiFID ), regardless f whether the executin takes place n a venue in the Eurpean Ecnmic Area, an equivalent venue in a third cuntry r n an verthecunter basis. The Plicy nly applies where we have categrised yu as a Prfessinal client and we yu a cntractual r agency bligatin. The duty t prvide best executin des nt apply t transactins invlving Eligible cunterparties and therefre where we have categrised as such the Plicy will nt apply. SSGMIL des nt deal with Retail clients. 2. Executin factrs When executing and/r transmitting yur rders we will take int accunt different executin factrs including, but nt limited t: Price; Csts; 1 See Sectin 4 belw. Page 1

2 Speed; Likelihd f executin; Likelihd and reliability f settlement; Size; Nature f an rder; and Other relevant cnsideratins, such as: Liquidity (relative rder size r financial instruments underlying liquidity); Market Impact; Nature f the available executin venue (regulated versus unregulated market venue);and Nature f the financial instrument. Our traders use their experience and judgment t determine the imprtance f each f these factrs n a case by case basis t assist in achieving f the best pssible result n a cnsistent basis in respect f yur rders. 3. Executin criteria In determining the relative imprtance f the executin factrs, when we are executing and/r transmitting yur rders, we will take int accunt the fllwing executin criteria: The extent t which we believe yu are relying upn us t prvide yu with the best pssible result; The characteristics f yur rder(s); The characteristics f the financial instrument; The characteristics f the available executin venues; and If yur rder is subject t any specific instructins that yu have given us. 4. Specific client instructins Whenever yu have given us a specific instructin regarding an rder r an aspect f an rder, we will execute r transmit such rder r aspect theref fllwing yur specific instructin. We will then apply this Plicy and take reasnable steps t btain the best pssible result fr the elements f the rder nt subject t r limited by yur instructins. Page 2

3 In the event that we feel that yur instructins may have becme unduly limiting t the executin f yur rder, such as where market cnditins have changed, we wuld aim t discuss this with yu and agree a suitable curse f actin. 5. Relative imprtance f the executin factrs While price is generally a key factr, the verall value t a client f a particular transactin may be affected by the ther factrs listed abve. The relative imprtance f each f the factrs will differ depending n: The characteristics f yur rder; The characteristics f the financial instruments t which the rder relates, as certain instruments are easier t execute than thers; The characteristics f the executin venue(s) t which we are able t direct and execute yur rder and the cnditins fr safe settlement assciated with thse venues; and, Cnsideratin f ptential market impact, taking int accunt any instructins yu might give us n participatin levels and having analysed the liquidity and relative size f the rder. 6. Further infrmatin n assetclass specific executin arrangements a. Equity instruments SSGMIL s preferred methd f executing yur rders fr equity instruments is fr ur traders t directly execute yur rder in the market as yur agent using a cmbinatin f techniques ranging frm manual t fully autmated. We may als use smart rder ruters and algrithms in rder t allw us t wrk yur rder(s) acrss multiple venues in the mst efficient manner pssible; we may als crss yur rder with anther SSGMIL client r with anther market cunterparty r liquidity prvider. Where facilities fr direct executin are nt available t us we will transmit yur rder t a suitable thirdparty r affiliated brker fr executin 2. In such cases we will clsely mnitr the perfrmance f the rder in s far as is pssible and will apply the principles described in sectin 7 f the Plicy. In Appendix I f this Plicy we prvide yu with an indicative list f the executin venues and illustrate ur access arrangements, bradly these cmprise the fllwing categries f venue: Regulated markets and third cuntry equivalents; Multilateral trading facilities ( MTF ) and third cuntry equivalents; 2 Please refer t Appendix I and see further in sectin 7 f this Plicy. Page 3

4 Systematic internalisers; Internal and external crssing netwrks; and Marketmakers, brkers, banks and ther liquidity prviders. Yu may f curse instruct us t execute yur rders using particular venues r cmbinatins theref. Subject t regulatin and acceptance by SSGMIL, yu may instruct us t direct yur rder t specific cunterparties fr executin. Frm timettime we may determine that it is beneficial t yur rder t execute it utside f a regulated market r MTF. Prvided that yu have given us yur express prir cnsent and we believe it is cnsistent with this Plicy t d s, we will execute yur rders in such a manner. b. Fixed Incme instruments SSGMIL typically executes yur rders in fixed incme instruments directly with ther market cunterparties (als knwn as dealers), because the use f trading venues is traditinally limited in fixed incme markets. When seeking prices frm such market cunterparties we will lk t btain qutes frm the key dealers fr the particular instrument and wuld aim t gain at least three qutes where the instrument permits this and rarely mre than five. There may be limited circumstances where, based n ur expertise and judgment, yur best interests may be better served by seeking prices frm fewer r mre market cunterparties. The chice f cunterparties varies based n the specific instrument. When selecting cunterparties t seek prices frm, in additin t the executin factrs, we will cnsider the fllwing characteristics f available cunterparties: Electrnic executin capability and ability t qute a market via Blmberg functinality; The quality f indicative bids and ffers and assciated spreads; Previus executins perfrmed with the cunterparty; Status f the cunterparty as a: lead manager f the applicable issuance f the instrument; and/r, knwn specialist in the instrument r sectr. c. Futures and ptins In the absence f specific instructins, when we are executing r transmitting yur rders in futures, we exercise ur wn discretin, based n ur experience, judgment, and the nature f yur rder(s) t prvide yu with the best pssible result and we take int accunt the fllwing executin factrs: Page 4

5 Price; Market impact; Size f the rder; Speed/ likelihd f executin; Market depth and liquidity in the cntract; and, Any specific instructins yu may give us. 3 d. Freign SSGMIL will typically transmit yur rders in freign exchange derivatives fr executin t a suitable thirdparty r affiliated brkerdealer fr executin 4, subject t jurisdictin. SSGMIL acts as yur agent; hwever, the relevant thirdparty r affiliate may becme yur cunterparty t the trade, depending n the specifics f the transactin. Additinally, at yur request we will rute yur rders t a specific cunterparty f yur selectin. When deciding where t transmit yur rders, SSGMIL will act in yur best interests when exercising ur prfessinal judgment t select an affiliate r thirdparty dealer based n ur assessment f that firm s ability t satisfy the varius executin factrs related t yur rder and taking int accunt any instructins yu may have given us. Finally, in respect f any rders in freign exchange which d nt cnstitute a financial instrument (i.e. spt cntracts and certain frward cntracts), whilst the bligatin fr best executin f rders under MiFID des nt apply, we will seek t apply the principles f this Plicy as we believe this serves yur general best interests. 7. Other imprtant matters a. Use f thirdparties and affiliates In rder t gain access t certain markets where we d nt have a membership r ther direct access arrangements, we may need t transmit yur rder t an affiliated r third party firm fr executin n ur behalf. We will exercise ur judgment, skill and experience t determine the apprpriateness and suitability f the relevant affiliate r third party firm. 3 Please refer t sectin 4 abve. 4 Please refer t Appendix I fr details f SSGMIL s affiliates. Page 5

6 The chice f thirdparty and affiliate firms will be determined by an nging assessment f their ability t supprt ur best executin bligatins t yu and a cmbinatin f the fllwing cnsideratins which will depend n the market we aim t access: Executin capabilities and range f accessible venues in target markets; Range f electrnic executin and rder handling capabilities; Credit ratings and quality f settlement arrangements; Status f the thirdparty r affiliate as: an fficial market maker r ther market specialist; and/r a knwn specialist in the market, sectr r instrument. Client rders executed using such arrangements are subject t mnitring and review 5 in rder t assess bth the utcme f the rder against the Plicy and the verall perfrmance f the thirdparty r affiliate firm. b. Third Party Brker Net Trading SSGMIL may, frm time t time, rute rders fr securities that are nt actively quted r fr which sufficient liquidity des nt exist t third party brkers which reprt such trades t State Street n a net basis, meaning that the price is inclusive f that brker s cmpensatin and/r fees (including, withut limitatin, stck brrw and cnversin fees arising in cnnectin with trading American Depsitry Receipts and Glbal Depsitry Receipts). Such brkers cmpensatin and fees d nt appear n yur trade cnfirmatins. These rders als remain subject t SSGMIL s fees and cmmissins, which are separately agreed with yu and set frth n yur trade cnfirmatins. State Street des nt receive any prtin f such brkers cmpensatin. By placing these types f trade rders with State Street yu are deemed t have acknwledged and agreed t State Street ruting and executing the rders in the manner described abve. c. Publicatin f limit rders We believe that it is nt always in yur best interests t make public limit rders in shares admitted t trading n a regulated market when they are nt immediately executed under prevailing market cnditins. We therefre will seek t btain a general instructin frm yu during the nbarding prcess, which we will als recnfirm peridically thereafter, which allws us t use ur discretin as t whether r nt t make such rders public. Unless therwise instructed, we will fllw the general instructin in respect f each rder yu give us. d. Executin f rders utside a regulated market r MTF 5 Please refer t sectin 8. Page 6

7 Frm timettime we may determine that it is beneficial t yur rder t execute all r part f it utside f a regulated market r MTF. Prvided that yu have given us yur express prir cnsent, btained during the nbarding prcess and peridically renewed thereafter, when we believe that it is cnsistent with this Plicy t d s we will execute yur rders in such a manner and apply the principles f this Plicy. e. Order aggregatin and allcatin When executing and/r transmitting yur rders we may cmbine yur rders with thse f ther clients f SSGMIL, which may include affiliated cmpanies. We will nly d this where we reasnably believe that it is in the verall best interest f each client. In the limited circumstances where SSGMIL r an affiliate may need t trade n its wn accunt, such as when trading ut f errrs assciated with client rders, we wuld nt cmbine yur rders with thse rders. 8. Mnitring and versight SSGMIL clsely mnitrs the effectiveness and perfrmance f its executin arrangements and delivery f best executin t its clients in respect f this Plicy. The relevant trading desks perfrm regular mnitring using a variety f methds pretrade, during trading and psttrade, including third party analytics. In additin t frntffice mnitring, the cmpliance department cnducts independent mnitring and may challenge findings and utcmes when required thrugh the curse f their prgram. SSGMIL has established a Best Executin Cmmittee ( BEC ) with set terms f reference in rder t prvide versight f the firm s executin arrangements and perfrmance findings. The BEC reprts directly t State Street Glbal Markets EMEA Senir Management Cmmittee, and meets mnthly t cnsider the findings f mnitring activities by the trading desks and cmpliance department. The BEC s membership cmprises senir representatives frm trading, peratins, transitin management, cmpliance, legal and risk. 9. Prcedural arrangements The Plicy and ur rder executin arrangements are reviewed at least annually by the relevant trading desks, cmpliance and BEC, but may be updated mre frequently when required, such as where we identify a material change which may affect ur ability t deliver best executin n a cnsistent basis. In the event that any material changes are made t the Plicy r t ur executin arrangements we will ntify yu accrdingly. Finally, yu may request that we demnstrate adherence t this Plicy in respect f any rder(s) we execute n yur behalf. Such requests shuld be made in writing and directed t: Head f SSGM EMEA Cmpliance Page 7

8 20 Churchill Place Canary Wharf Lndn E14 5HJ United Kingdm Effective date: January 2017 Legal and regulatry ntices and disclaimer State Street Eurpe Limited, authrised and regulated by the Financial Cnduct Authrity; (iii) State Street Glbal Markets Internatinal Limited, authrised and regulated by the Financial Cnduct Authrity 2017 State Street Crpratin All Rights Reserved. Page 8

9 Appendix I Executin Venues The fllwing list sets ut the varius arrangements ( SSGMIL ) may use in each in market and assetclass t execute yur rders. The precise venues and arrangements will be selected in accrdance with the Plicy, subject t any preferences yu may indicate and specific jurisdictinal requirements. References t direct access include venues where SSGMIL is either a member/participant r has direct market access thrugh a thirdparty that is itself a member. This list may change frm time t time, please cnsult yur SSGMIL representative fr details f ur mst current capabilities and t discuss yur executin requirements further 1. Eurpean venues Direct Access Thirdparty brker Austria Vienna Stck Belgium Eurnext Brussels Bulgaria Bulgarian Stck Cratia Zagreb Stck Cyprus Cyprus Stck Czech Republic Prague Stck Denmark NASDAQ OMX Nrdic Cpenhagen Estnia NASDAQ OMX Baltic Tallinn Finland NADAQ OMX Nrdic Helsinki France Eurnext Paris Germany Frankfurt Stck (Xetra) Börse Berlin Equiduct Eurex Deutschland Greece Athens Stck Hungary Budapest Stck Iceland NASDAQ OMX Iceland Ireland Irish Stck Italy Brsa Italiana Latvia NASDAQ OMX Baltic Riga Lithuania NASDAQ OMX Baltic Vilnius Luxemburg Luxemburg Stck Netherlands Eurnext Amsterdam Nrway Osl Børs Burgundy Page A11

10 APPENDIX I Pland Warsaw Stck Prtugal Eurnext Lisbn Rmania Bucharest Stck Russia Mscw Stck Slvakia Bratislava Stck Slvenia Ljubljana Stck Spain Blsa de Madrid Switzerland SIX Swiss United Kingdm BATS Eurpe / ChiX Eurpe Lndn Stck Turquise 2. Middle East and Africa venues Direct Access Thirdparty brker Bahrain Bahrain Stck Egypt Egyptian Ghana Ghana Stck Israel TelAviv Stck Kenya Nairbi Stck Kuwait Kuwait Stck Mrcc Casablanca Stck Nigeria Nigerian Stck Qatar Qatar Stck Turkey Brsa İstanbul Suth Africa Jhannesburg Stck United Arab Emirates Abu Dhabi Stck Dubai Stck Uganda Uganda Stck 3. AsiaPacific venues Australia Australian Securities ChiX Australia Bangladesh Dhaka Stck China Shanghai Stck (inc. ShanghaiHng Kng Stck Cnnect) Hng Kng Hng Kng Stck (inc. ShanghaiHng Kng Stck Cnnect) Hng Kng s and Clearing India Bmbay Stck Natinal Stck Indnesia Bursa Efek Indnesia Japan JASDAQ Securities Nagya Stck Osaka Securities Sappr Securities Tky Stck ChiX Japan SBI Japannext Direct Access Affiliated brker Thirdparty brker Page A12

11 APPENDIX I Malaysia Bursa Malaysia Pakistan Karachi Stck New Zealand NZX Markets Philippines Philippine Stck Singapre Singapre Sri Lanka Clmb Stck Suth Krea Krea Taiwan Taiwan Stck Thailand The Stck f Thailand Viet Nam H Chi Minh City Stck 4. Americas venues Brazil BM&F BOVESPA Ri de Janeir Stck Canada Alberta Stck Mntreal Trnt Stck Vancuver Stck Affiliated brker Thirdparty brker Chile Santiag Stck Clumbia Clumbia Stck Mexic Blsa Mexicana de Valres Peru Lima Stck United States New Yrk Stck NYSE Arca NASDAQ BATS Blckcrss 5. Relevant SSGMIL affiliates Glbal State Street Bank and Trust Cmpany EQ FI FUT FX EMEA State Street Bank GmbH AsiaPacific State Street Glbal Markets (Japan) Americas State Street Glbal Markets, LLC State Street Glbal Markets Canada, Inc. Currenex, Inc. All executin venues listed are available thrugh State Street Glbal Markets Internatinal Limited as f Nvember Venues are subject t peridic review and change State Street Crpratin All Rights Reserved Page A13