Order execution policy

Transcription

1 Disclosure statement February P a g e

2 1 First State Investments This Disclosure Statement forms part of our obligations relating to the Markets in Financial Instruments Directive (MiFID), and sets out our business practices concerning the execution of orders on your behalf. The primary service First State Investments provides to you is that of portfolio management, part of which involves the execution of decisions we have made to deal on your behalf. When we have made such a decision to deal, our objective is to then provide the highest quality execution reasonably applicable under the circumstances and within the context of markets at that time, balancing sometimes conflicting factors. Through this process we remain committed to providing you with the best possible result on a consistent basis. Set out below is information regarding our order execution policy, which we have established in order to allow us to obtain the best possible results for your orders. If you are a client of Stewart Investors, please refer to the Stewart Investors Order Execution Policy. 2 Order Execution Policy In selecting the most appropriate venues for the purpose of executing your orders, we will take into account the various factors which we believe are relevant to the order, which may include those set out in part one above. In doing so, we will assess what we reasonably believe to be your best interests in terms of executing the relevant order. In conducting this assessment we will take into account all such other factors as we believe may be appropriate including, the ability of the venue to manage complex orders, the quality of the venue including the nature of other participants and order types available, the speed of execution, the creditworthiness of the venue and the quality of any related clearing and settlement facilities. Our Ongoing Responsibilities We have set out below, information on the criteria which determines how we select the different venues on which we may execute your order and have identified those venues on which we will most regularly seek to execute your orders and which we believe offer the best prospects for affording you best execution. We will also assess on a regular basis, the quality of execution afforded by those venues on which we execute your orders and whether we need to change our execution arrangements. While we will take all sufficient steps, based on those resources available to us, to satisfy ourselves that we have processes in place that can reasonably be expected to lead to the delivery of best execution of your orders, we cannot guarantee that we will 2 P a g e

3 always be able to provide best execution of every order executed on your behalf. Global Applications Our policy in providing you with best execution is, so far as possible and subject to the processes set out below, to exercise the same standards and operate the same processes across all the different markets and financial instruments on which we execute your orders. However, the diversity in those markets and instruments and the kind of orders that we carry out on your behalf may mean that different factors will have to be taken into account when we assess the nature of our execution policy in the context of different instruments and different markets. For example, there is no formalised market or settlement infrastructure for over-the-counter transactions. In some markets, price volatility may mean that the timeliness of execution is a priority, whereas in other markets that have low liquidity, the act of execution may itself constitute best execution. In other cases, our choice of venue may be limited (even to the fact that there may only be one platform/market upon which we can execute your orders) because of the nature of the order or of your other requirements. 3 Delivering Best Execution When executing orders on your behalf in relation to financial instruments we must take all sufficient steps to achieve best execution of your orders which, in providing you with a portfolio management service, will generally result from decisions by us to deal in financial instruments on your behalf. This means that we will have in place a policy and procedures which are designed to obtain the best possible execution result, subject to and taking into account the nature of your orders, the priorities we place upon filling those orders and the market in question, and which in our view provides the best balance across a range of factors, some or all of which may be conflicting. We will apply this policy to all orders which we execute on your behalf, with the aim of obtaining the best possible result for you. The factors we will take into consideration include: price; cost; speed of execution; likelihood of execution and settlement; the size of the order; the nature of the order; and any other considerations relevant to the execution of the order. The criteria we will use in determining the relative importance of the execution factors listed above include: your characteristics, including your regulatory client categorisation; the characteristics and nature of your order, including the broader context of the investment style of the portfolio to which it relates and whether any specific instructions are given; the characteristics of the financial instruments that are the subject of your order; and the characteristics of the execution venues to which your order can be directed. 3 P a g e

4 4 Execution Processes We owe a duty of best execution when we execute orders on your behalf. We may place or transmit your orders to another entity for execution. When we do this, we will be under an obligation to act in accordance with your best interests. As we primarily provide portfolio management services to you, we will exercise our discretion in executing orders resulting from decisions by us to deal in financial instruments on your behalf. We consider an order to exist where we have made such a decision to deal on your behalf, or where an execution instruction is given to us that gives rise to contractual or agency obligations owed by us to you. We believe this to be the case where we exercise our discretion in relation to the exercise of your order. Where you provide us with a specific instruction in relation to an entire order, or any particular aspect of an order including selecting to execute on a particular venue, we will execute the order in accordance with your instructions. However, please note that if you provide us with a specific instruction, this may prevent us from following some or all of the steps in our order execution policy that are designed to obtain the best possible result for the execution of your orders. In following your instructions we will be deemed to have taken all sufficient steps to provide the best possible result in respect of the order or aspect of the order covered by your specific instructions. Therefore, if you require your order to be executed in a particular manner and not in accordance with our order execution policy, you must clearly state your desired method of execution when you place your order. To the extent that your specific instructions are not comprehensive, we will determine any non-specified components in accordance with our order execution policy. Trading Venues In meeting our obligation to take all sufficient steps to obtain on a consistent basis the best possible result for the execution of your orders, we may use one or more of the following venue types when executing an order on your behalf: regulated markets; multilateral trading facilities; organised trading facilities systematic internalisers; and third party investment firms acting as market makers or other liquidity providers. We believe that these venues or sources of liquidity enable us to obtain on a consistent basis, the best possible result for orders we execute on your behalf. We will assess which venues within this list are likely to provide the best possible result for our clients on a transaction-by-transaction basis. The execution venues we route the majority of our orders through are listed within the Appendix of this document. In certain financial instruments there may only be one execution venue. In executing a trade in such circumstances we will presume that we have provided the best possible result in respect of these types of financial instruments. Brokers and Counterparties We will generally place or transmit your orders to third-party investment firms ( brokers ) for execution. In doing so, we will take all sufficient steps to obtain the best possible result for you. The entities with which such orders may be placed, are specifically approved by us after review in accordance with our policy and they must have execution arrangements that enable them to comply with our obligations. We may also place such orders with our affiliate companies around the world for execution on our behalf, in which case those affiliates will also adhere to this policy. We have a process for the selection of brokers with whom we place orders for execution. The specific criteria to add a broker varies based on the relevant asset class, however the approval process is applied in the same manner across all asset classes. We do not conduct any activity with a new broker until the screening and approval process has been completed. 4 P a g e

5 The criteria to add a broker to the approved counterparty list is generally based on a number of factors which may include, but is not limited to, our assessment of their: ability to provide adequate coverage to the asset class globally; pricing capability; liquidity and limit provision; sustainability; operational capability; service quality; and reputation, including regulatory status and history. All approved brokers undergo screening including disciplinary actions, criminal proceedings and reputational issues, conducted by our Risk Management team. In order to minimise the risk of potential conflicts of interest when selecting brokers with whom to place orders for execution, the commission rates we pay are set so as not to discriminate between different brokers. We also do not take part in any form of directed brokerage or commission recapture arrangement. We do not receive any form of remuneration, discount or non-monetary benefit for directing orders to a particular venue or broker for execution. Selection of a broker for an order is driven solely by the factors and inputs as described in this policy. Algorithmic Trading Where we use a broker to execute orders on your behalf, such execution may also be achieved through the use of algorithmic trading, in which an order is traded in line with specific parameters using a proprietary platform provided by that broker. First State actively utilizes algorithmic trading as a key tool in sourcing liquidity solely through the use of broker sponsored algorithms. First State places thresholds and limits on each order to prevent the possibility of erroneous orders being sent into the market and limit the potential for market abuse. When we seek to use a specific algorithmic trading platform in order to execute orders, we will only do so where we have reviewed that platform and the way in which it operates, and determined that we believe it is appropriate to use in order to seek to achieve best execution. First State requires that algorithmic providers ensure that their electronic systems are monitored through a clear and formalised governance process and that sufficient business continuity plans are in place in the event of systematic failure. First State has procedures and arrangements, including training, to ensure the sufficient level of necessary skills and expertise to manage the use of algorithms. 5 Asset Class Considerations Alongside the use of third-party investment firms, we will also review the opportunities for direct execution of your orders, generally through multilateral trading facilities or direct access to regulated markets. The decision between using third-party firms and direct execution will be made having regard to the relative importance of the execution factors for the specific financial instrument in question, in line with the following instrument-related considerations: Equities Orders relating to equities (including related exchange-traded collective investment schemes and derivatives) are generally executed either by third party investment firms or, through multilateral trading facilities or by directly accessing markets. In considering the execution factors and deciding the appropriate execution venue, we will take account of factors such as the reason for the order, the size of the order relative to liquidity, specific portfolio manager instructions (including price limits) and other grounds deemed relevant at the time. While price will generally be the most important factor, for larger orders particularly factors such as execution certainty, market impact reduction and execution speed may have greater importance. If we transmit the order to a broker for execution, we will select a broker which has a track record of achieving the best result for orders of a similar nature. Fixed Income and Money Market Instruments Orders relating to Fixed Income and money market instruments are executed either by third party investment firms or through multilateral trading facilities. Orders executed through multilateral trading facilities will usually involve obtaining 5 P a g e

6 screen-based competitive quotations and this approach seeks the best price through competition among multiple third party investment firms. In the case of larger orders we are more likely to place orders directly with third party investment firms in which case we will generally obtain at least three quotes and retain these for audit purposes, assuming these quotes can be obtained without impacting the market. While price (including all execution costs) will generally be the most important factor, we may take other factors into account as appropriate to the size and nature of the order. factors may be taken into account as is appropriate for the size and nature of the order. In some instances where execution speed and certainty and/or market impact are judged to be more important, we may deal on the basis of quotes provided by a single execution venue, which will be retained for audit purposes. In some instances where execution speed and certainty and/or market impact are judged to be more important, obtaining multiple quotes may have a negative impact on obtaining best execution or for some orders there may only be one potential counterparty, in which case we may approach a single broker or counterparty on the basis of their suitability for that transaction. In such cases we will check the fairness of any price proposed by gathering market data relevant to the estimation of such a price and, if possible, comparing to similar assets. Currency Orders relating to foreign exchange are generally executed with third party investment firms. Depending on the size of an order, we will generally obtain several simultaneous quotations from multiple counterparties and retain these for audit purposes, with the predominant factor being best price at the time of execution. For some orders, particularly larger orders, a single counterparty may be approached dependent on the execution strategy at the time of the order to avoid impacting the market significantly. In such a case, counterparty selection will take into consideration factors such as previous execution performance, clearance and settlement capability, credit worthiness and financial stability, timely trading and ability to trade in large volumes. Derivatives For orders in over-the-counter derivatives, we will generally consider price (including costs) to be the most important factor, however other execution 6 P a g e

7 Collective Investment Schemes Orders in collective investment schemes which are not exchange-traded will normally be in an environment where there is no secondary market. Generally we will place such an order with the relevant administrator of the scheme, who will be the execution venue. Such transactions will be effected at the appropriate net asset value, with execution certainty being the most important factor. In respect of financial instruments which can be traded on a Regulated Market or a Multilateral Trading Facility, you should note that subject to your prior consent, some of your orders may be executed outside of a Regulated Market or Multilateral Trading Facility where we believe we can achieve the best possible result for execution of your order by doing so. Monitoring and Review We will continually monitor the effectiveness of our order execution arrangements and policy to identify and where appropriate, correct any deficiencies. A group comprising our investment, business management and risk management teams meet quarterly to review all trade allocation data using qualitative and quantitative measures. Through this process we assess whether the execution venues included in this policy provide the best possible result for you or whether we need to make changes to our execution arrangements from time to time. We review our order execution arrangements and policy at least annually or whenever a material change occurs that affects our ability to continue to obtain the best possible result for the execution of your orders. We will notify you of any material changes to our order execution policy. All references in this document to we or us are references to First State Investments. First State Investments is the trading name for First State Investment Management (UK) Limited and First State Investments International Limited, each of which is authorised and regulated by the Financial Services Authority. Where we utilize the services of First State Investments affiliated companies around the world for execution purposes, we will expect them to follow this policy and for any external brokers and such third parties to treat them as though they were First State Investments companies. The ultimate holding company of the First State Investments group is the Commonwealth Bank of Australia. Last date of review: 30 June P a g e

8 6 Appendix: Execution Venues First State Investments may use the following execution venues when obtaining best execution. This list is not exhaustive and may be subject to change and revised from time to time. First State Investments may use venues not listed below where it deems appropriate in accordance with the Order Execution Policy. Regulated Markets and multilateral trading facilities Accra Stock Exchange Athens Stock Exchange Australian Securities Exchange Barclays LX BATS Europe BATS Trading BIDS Blockcross BM&F BOVESPA Boerse Berlin Equiduct Trading Bolsa Mexicana de Valores Bombay Stock Exchange Borsa Istanbul Borsa Italiana Botswana Stock Exchange Budapest Stock Exchange Bursa Malaysia Cantor Fitzgerald Chicago Stock Exchange Chi-X Australia Chi-X Europe CitiCross CitiMatch Colombo Stock Exchange Convergex Millennium CS Crossfinder Deutsche Bank SuperX Dhaka Stock Exchange Doha Securities Market Dubai International Financial Exchange Euronext Amsterdam Euronext Brussels Euronext Lisbon Euronext London Euronext Paris Fidelity CrossStream Egyptian Exchange Frankfurt Stock Exchange GreTai Securities Market Harare Stock Exchange Hochiminh Stock Exchange Hong Kong Stock Exchange Indonesia Stock Exchange IEX Market Indonesia Stock Exchange Instinet Blockmatch Irish Stock Exchange Istanbul Stock Exchange ITG Posit Johannesburg Stock Exchange JPM-X JSE Securities Exchange Karachi Stock Exchange KCG MatchIT Korea Exchange (KOSDAQ) Korea Exchange Level Lima Stock Exchange Liquidnet Europe London Stock Exchange Madrid Stock Exchange Match Now ATS Mauritius Stock Exchange Merrill Lynch Instinct X Mexican Stock Exchange MS Pool Muscat Stock Exchange Nairobi Securities Exchange Nasdaq BX Nasdaq Capital Market NASDAQ OMX Copenhagen Exchange Nasdaq OMX Global Select Market NASDAQ OMX Helsinki Exchange NASDAQ OMX Nordic NASDAQ OMX Stockholm Exchange NASDAQ PSX NASDAQ Stock Market National Stock Exchange of India National Stock Exchange (NSX) New York Stock Exchange Nigerian Stock Exchange NYSE Arca NYSE MKT Oslo Stock Exchange Philippine Stock Exchange Port of Spain Stock Exchange Prague Stock Exchange Russian Trading System Stock Exchange San Jose Stock Exchange Santiago Stock Exchange Shenzhen Stock Exchange 8 P a g e

9 Sigma X Singapore Exchange SIX Swiss Exchange Stock Exchange of Thailand SWX Swiss Block Taipei Exchange Taiwan Stock Exchange Tokyo Stock Exchange Toronto Stock Exchange TriAct Match Now Turquoise UBS ATS UBS MTF Vienna Stock Exchange Warsaw Stock Exchange Wiener Boerse Xetra Third-Party Investment Firms including Systematic Internalisers Equity Securities Ambit Capital Private Ltd ANZ Banking Group Ltd Argonaut Securities pty Limited Axis Capital Limited Bahana Securities Ltd Baillieu Holst Limited Banco Santander SA Bank BCA Syariah PT Bank OCBC NISP Tbk PT Bank Of America Corp Bank of China International (UK) Ltd Bank of Montreal Barclays Capital Securities Limited Bativala & Karani Securities India Private Ltd Bell Financial Group Ltd BNP Paribas Securities (Asia) Limited Bradesco Securities Inc BTIG Hong Kong Limiited Canaccord Genuity Securities Limited China International Capital Corporation Limited CIBC World Markets Inc CIMB Securities Ltd Citic Securities Co, Ltd Citigroup Global Markets Limited CLSA Limited Cormark Securities Inc Credit Suisse Securities (Europe) Limited CT CLSA Securities (Pvt) Limited CT Smith Stockbrokers (Pvt) Limited Daiwa Capital Markets Europe Limited Danareksa Sekuritas PT DBS Vickers Securities (UK) Ltd Deutsche Bank AG DNB Bank Dragon Capital Markets Limited Dundee Securities Corporation Euroz Securities Limited Exane Limited Exotix Partners LLP First NZ Capital Securities Ltd Forsyth Barr Limited Foster Stockbrocking Pty Ltd GMP Securities LP Goldman Sachs International Green Street Advisors (UK) Limited Hartleys Limited Ho Chi Minh City Securities Corporation HSBC Bank plc ICBC Standard Bank plc ICICI Brokerage Services Limited Imara S.P. Reid (Pty) Limited India Infoline Limited Indo Premier Securities Instinet Europe Limited Investment Technology Group Limited ISI Group Inc Itau BBA UK Securities Limited Jefferies International Limited JM Financial John Keells Stock Brokers (Pvt) Limited JP Morgan Securities Limited Kempen & Co NV Kepler Cheveux KeyBanc Capital Markets Inc KGI Securities Co Ltd Kotak Securities Ltd Ladenburgh Thalmann Liquidnet Europe Limited Luminex Macquarie Capital (Europe) Limited Mandiri Sekuritas 9 P a g e

10 Maybank Kim Eng Securities (London) Ltd Merrill Lynch International Mirae Asset Securities (HK) Limited Mitsubishi UFJ Securities International plc Mizuho International Securities Moelis Australia Securities Morgan Stanley & Co International plc Motilal Oswal Securities Ltd National Australia Bank Limited National Bank Financial Nomura International plc OSK Securities Bhd Paradigm Capital US Inc Patersons Securities Limited Petra Capital Pty Ltd Phillip Capital Limited Piper Jaffray (previously Simmons & Co International Ltd) Raymond James Limited RBC Europe Limited RBS Morgans Limited Samsung Securities (Europe) Ltd Sandler O'Neill & Partners, L.P. Sanford C. Bernstein Limited Santander SA Scotia Capital (USA) Inc Shaw Stockbroking Limited Shenyin Wanguo Securities (HK) Limited Shinhan Financial Group Co Ltd SMBC Nikko Securities Societe Generale SA Standard Chartered Bank State Street Bank & Trust Company Stifel Nicolaus Limited Taylor Collison Limited The Royal Bank of Scotland plc The Toronto-Dominion Bank Trimegah Securities Tudor Pickering Holt & Co Securities Inc UBS Limited Wells Fargo Securities LLC Wilson HTM Wood & Company Financial Services A.S. Yuanta Securities Company Limited Third-Party Investment Firms Debt Securities Australia and New Zealand Banking Group Ltd Banco Bilbao Vizcaya Argentina SA Banco Colpatria Multibanca Colpatria SA Banco Santander SA Bank Hapoalim BM Barclays Bank plc Barclays Capital Inc BNP Paribas SA Cantor Fitzgerald Europe CIBC World Market Securities Inc Citigroup Global Markets Inc Citigroup Global Markets Limited Commerzbank AG Credit Agricole SA Credit Suisse Securities (Europe) Limited Credit Suisse Securities USA LLC Deutsche Bank AG Exotix Limited Goldman Sachs International HSBC Bank PLC ICBC Standard Bank PLC ING Bank NV ITAU BBA UK Securities Limited Jefferies International (Holdings) Limited JP Morgan (SEA) Ltd JP Morgan Markets Limited JP Morgan Securities Limited JP Morgan Chase Bank NA Liquidity Finance LLP Liquidnet Europe Limited Marketaxess Europe Ltd Merrill Lynch International Ltd Merrill Lynch Pierce, Fenner & Smith Inc Mizuho International PLC Morgan Stanley & Co International PLC Mitsubishi UFJ Securities International plc MUFG Securities EMEA PLC National Bank of Abu Dhabi PJSC Natixis (Paris Branch) Nomura International plc Oppenheimer Europe Ltd Raiffeisen Bank International AG Scotia Bank Societe Generale SA Standard Chartered Bank Royal Bank of Scotland PLC TPCG Financial Services UBS AG UBS Limited Unicredit Bank AG 10 P a g e

11 Multilateral Trading Facilities Equity and Debt Securities Bloomberg Fixed-Income Trading Instinet BlockMatch Liquidnet Europe Limited ICAP True Mid BGC Global Bond Exchange London Stock Exchange AIM MarketAxess Europe Limited POSIT Third-Party Investment Firms Foreign Exchange and Derivatives Australia and New Zealand Banking Group Ltd Barclays Bank plc Citibank NA Citigroup Global Markets Limited HSBC Bank plc JP Morgan Chase Bank NA JP Morgan Securities PLC Merrill Lynch International Ltd Morgan Stanley & Co International plc Standard Chartered Bank State Street Bank and Trust Company The Royal Bank of Scotland plc UBS AG Regulated Markets Exchange Traded Derivatives Chicago Mercantile Exchange EDX London Eurex Euronext.liffe Euronext.liffe Bclear Hong Kong Exchanges and Clearing Italian Derivatives Market MEFF NASDAQ OMX Copenhagen NASDAQ OMX Helsinki NASDAQ OMX Stockholm NYSE Euronext Amsterdam Australian Securities Exchange Montreal Exchange 11 P a g e