Sparinvest S.A. Best execution and order execution policy

Transcription

1 Sparinvest S.A. Best eecution and order eecution policy

2 Best eecution and order eecution Contents 1. Purpose Best Eecution Criteria to achieve Best Eecution Broker selection and venues for eecution Eecution of trades Cross-trades Aggregation and Allocation Aggregation Allocation Documentation Policy supervision Consent and publication

3 Best eecution and order eecution 1. Purpose The policy applies for Sparinvest S.A. and its branch ID-Sparinvest, Filial af Sparinvest S.A., Luembourg ( Sparinvest ) and implements the requirements under the EU Directive on markets in financial instruments and any related regulation laid down by Luembourg and Denmark. The policy applies to the eecution of orders placed by Sparinvest on behalf funds under management (the Funds ) or institutional clients (the Clients ). Sparinvest must act honestly, fairly and professionally in accordance with the best interest of the Funds and the Clients when eecuting orders on their behalf. 2. Best Eecution Sparinvest will take all reasonable measures to achieve the best possible result for both the Funds and the Clients, when Sparinvest makes trading decisions, eecute trade orders or convey these to brokers for eecution. However, if the Funds or the Clients request Sparinvest to eecute a trade order through a specific broker or trading venue, Sparinvest is not obligated to achieve best eecution. 2.1 Criteria to achieve Best Eecution The efforts of Sparinvest to achieve best eecution takes into consideration the investment goals, investment policy and risk profiles of the Funds and Clients. In addition, Sparinvest considers the characteristics of the trade order, the financial instruments involved in the trade, and the broker or trading venues used to eecute the trade order. The factors taken under consideration when eercising best eecution will include the following, as determined on a case by case basis: The size and nature of the order Available prices Liquidity of the market (which may make it difficult to eecute an order) - Transparency on interaction of order flows - Deep and diverse liquidity to fit a range of eecution strategies - Protective measures to address information leakage to help minimize market impact - Controlled access designed to preserve quality liquidity Trading costs and characteristics of trading venues Speed of eecution Likelihood of eecution and settlement Type of financial instrument and other factors relevant to the eecution of the trade 3 11

4 Best eecution and order eecution When determining what relative weight to assign to the above factors, Sparinvest will consider the investment guidelines, the characteristics of the financial instrument, and the status of the trading venues and/or brokers relevant to the given instrument. In general, the price of the given financial instrument - that is, the total cost including all fees - will have the greatest influence. However, other factors, such as speed of eecution, the likelihood of eecution, and possible price improvements, also carry weight when decisions regarding trades are made. 2.2 Broker selection and venues for eecution Sparinvest approves both brokers and venues for eecution of trade orders. The choice of broker is based on a Broker Selection Policy, which encompasses price, eecution and settlement, understanding of investment process etc., i.e. which markets may be traded and which instruments can be traded. Sparinvest monitors the selected brokers, venues and trading systems in order to evaluate their effectiveness and whether they are providing the best possible results for the Funds and Clients. It is thus possible for Sparinvest to identify and implement improvements in the trade processes so that Sparinvest meets the criteria for best eecution. Sparinvest will perform an annually due diligence on both brokers and venues to make sure that they continue to be compliant with applicable regulation and this policy. For further information regarding selected brokers and venues for eecution, see the Appendi to this policy. 3. Eecution of trades Sparinvest will act out of consideration to the Funds and the Clients best interests and provide for the prompt, fair and epeditious eecution of trades. Sparinvest conveys trade orders in accordance with what Sparinvest deems will bring the best possible result within the defined investment guidelines of the Funds and the Clients When Sparinvest chooses a broker or trading venue to eecute a trade order, such decisions are based on a thorough analysis of the instrument in question, and market conditions in general, which will allow for an adequate assessment and ensuring best eecution. Sparinvest shall ensure that orders eecuted on behalf of the Funds and Clients are recorded and allocated immediately and accurately and that comparable orders are eecuted sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable or the interests of the Funds or Clients require otherwise. The financial instruments, payment or other assets received in settlement of the eecuted orders, shall be promptly and correctly delivered to or registered in the account of the relevant Funds or Clients. 4 11

5 Best eecution and order eecution Sparinvest shall not misuse information related to pending orders on behalf the Funds or Clients and shall take all reasonable steps to prevent misuse of such information by any of their relevant persons. 3.1 Cross-trades Sparinvest may trade between the Funds or Clients. Such trades may only be eecuted if the trade is in the best interest of both the selling and the buying side. When eecution a cross trade fair pricing will be ensured and documented according to the Sparinvest internal trade procedure and Valuation Policy. 4. Aggregation and Allocation 4.1 Aggregation When Sparinvest eecutes trade orders on behalf of the Funds and Clients, Sparinvest may choose to aggregate these orders with trade orders conducted on behalf of other Funds or Clients. Aggregation can be a disadvantage in relation to a specific order, however Sparinvest will only aggregate trade orders if it is not disadvantageous for the Funds or the Clients. Order aggregation may occur when the portfolios of the Funds and Clients predominantly contain the same securities. In such cases, the characteristics of the order, the investment objectives and strategies of the Funds and Client as well as market conditions will, among other things, be considered. 4.2 Allocation When Sparinvest has aggregated trade orders, the subsequent allocation of the trade will be based on the same trade price and the necessary steps will be taken to ensure a fair, timely, orderly and equitable allocation, so that no Funds or Clients receive preferential treatment over any other Funds or the Clients. In cases where it has proven impossible to buy or sell a sufficient number of financial instruments, these will when possible be distributed pro rata based on the desired number of securities, with respect for trading costs. 5. Documentation Sparinvest must be able to demonstrate that it has eecuted/placed orders on behalf the Funds and Clients in accordance with this policy. Therefore, all trades stored electronically and are subject to ongoing supervision by Sparinvest in order to make sure that all trades comply with investment guidelines etc. of the Funds and Clients. 6. Policy supervision Sparinvest will at least annually re-assess this policy to verify that it is serving its purpose, including the quality of order eecution by brokers. 5 11

6 Best eecution and order eecution In addition, the Policy will also be re-assessed if there are material changes that affect the company's ability to continue to achieve the best possible result for the Funds and Clients. 7. Consent and publication Sparinvest will obtain prior consent from the Funds and Clients to this Policy. Furthermore, Sparinvest will obtain prior consent from the Funds and Clients in order to eecute an order, where relevant, outside of a regulated market or multilateral trading facility. Sparinvest will make this Policy and any material changes hereto available at the following website, sparinvest.lu Luembourg 6 December 2016 Board of Directors Per Noesgaard, formand Henrik Lind-Grønbæk Richard Jacqué 6 11

7 Best eecution and order eecution Appendi: Main trading venues Sparinvest may use the following main trading venues when obtaining Best Eecution. This list of trading venues may have changed since the last update of the Policy. The list of trading venues will be reviewed at least annually in accordance to this Policy. Venue ABG SUNDAL ABN AMRO ALL GERMAN SE Alpha Alpha IntraSpread American Stock Echange AQUA Aquis Echange ARCTIC SECURITIES ATD Auto AUREL Australian Stock Echange BANCA PORTUGUES BARCLAYS Barclays Capital LX BATS Trading Ltd. BB&T BCP Berlin Stock Echange BIDS Bloomberg Liquidity Platform BLOOMBERG TRADEBOOK BM&F Bovespa BNP PARIBAS Equity Bonds BOFA MERRILL BofAML MLXN Bolsa Meicana de Valores Bolsas y Mercados Españoles Bombay Stock Echange Borsa Italiana S.p.A. Bursa Malaysia Securities Clearing Berhad BXE (BATS) Dark Book BXE (BATS) Lit Book BAADER BANK CARNEGIE Derivatives Structured Products Funds 7 11

8 Best eecution and order eecution CENT ANOTACIONES Chi-X Canada Citadel Connect Citi Cross CITIBANK CONVERGEX ConvergE Millennium ConvergE Vorte CREDIT AGRICOLE CREDIT SUISSE Credit Suisse Crossfinder CS Light Pool CX2 CXE (CHI-X) Dark Book CXE (CHI-X) Lit Book DAIWA DANSKE BANK DAVY SECURITIES DBS VICKERS DEUTSCHE BANK Deutsche Bank SuperX DNB ELEVATION EQUINET AG EQUITA Euro MTF Euro TLX EUROMTF Euronet (Amsterdam, Brusselles, Paris) EURONEXT-AMSTER EUROTLX FEARNLEY SECURITIES Fidelity CrossStream Frankfurt Stock Echange (Deutsche Boerse) GMP SECURITIES GOLDMAN SACHS GS Sigma X Hi-mtf Hong Kong Stock Echange HSBC ICX BLX ICX VWAPX IEX Indonesia Stock Echange ING 8 11

9 Best eecution and order eecution INSTINET Instinet BlockMatch Instinet BLX US Instinet CBX US Instinet VWAPX Europe Instinet VWAPX US International Securities Echange ITAU ITG ITG Posit ITG Posit JEFFERIES Johannesburg Stock Echange JP MORGAN JP Morgan JPMX JYSKE BANK KCG GETMatched Knight Link Knight Match Korean Stock Echange Level ATS Liquidnet H2O Liquidnet Negotiated London Stock Echange Luembourg Stock Echange Lyn MACQUARIE BANK Madrid Stock Echange MAIN FIRST BANK AG Market Aess MATCH Now MITSUBISHI MM WARBURG Montreal Echange MORGAN STANLEY MTS France München Stock Echange Nagoya Stock Echange NASDAQ NASDAQ Dubai Limited NASDAQ OMX (Stockholm, Helsinki, and Copenhagen) National Stock and Option Echanges National Stock Echange of India New York Stock Echange NIKKO 9 11

10 Best eecution and order eecution NOMURA NOMX COPENHAGEN NOMX ICELAND NOMX STOCKHOLM NORDEA Nordic ABM Nordic at Mid NYKREDIT NYSE Euronet (Amsterdam, Brussels, Lisbon and Paris) Omega OPPENHEIMER Osaka Stock Echange Oslo Bors ASA Pacific Stock Echange PARETO SECURITIES PDQ Philadelphia Stock Echange PLATOU SECURITIES Potamus RABO SEC RBC RBS REDBURN SC LOWY SEAPORT SEB ENSKILDA Shanghai Stock Echange Singapore Echange Securities Trading Limited SIX Swiss Echange Societe Generale Spar Nord SPAREBANK 1 SPERBANK SSGM BlockCross STIFEL SWEDBANK Sydbank Taiwan Stock Echange Tel Aviv Stock Echange TMX Select Tokyo Stock Echange Toronto Stock Echange Tradeweb TRADITION FINANCIAL SERVICES 10 11

11 Best eecution and order eecution TSX Venture Echange Turquoise MidPoint UBS UBS ATS UBS MTF UNICREDIT Vienna Stock Echange VONTOBEL Warsaw Stock Echange WELLS FARGO Wells Fargo WELX Xetra MidPoint Date of last review: 6 December