DALTON STRATEGIC PARTNERSHIP LLP ORDER EXECUTION POLICY DECEMBER 2017
|
|
- Collin Price
- 6 years ago
- Views:
Transcription
1 DALTON STRATEGIC PARTNERSHIP LLP ORDER EXECUTION POLICY DECEMBER 2017 General Policy Information Dalton Strategic Partnership (DSP) invests in various asset classes as part of the investment management services which it provides to its clients, that is the funds and portfolios that DSP manages on a discretionary basis. In carrying out this activity we make discretionary investment decisions for our clients ( the funds ) and place orders with other entities for execution. The second Markets in Financial Instruments Directive ( MiFID II ), as implemented in the UK through the MiFID Delegated Regulations and the rules in COBS 11.2A of the FCA Handbook, requires all investment firms, when executing orders on behalf of clients, to take all sufficient steps to obtain the best possible result for their clients, taking into account all relevant execution factors. We have therefore established and implemented a best execution policy, setting out the most important and/or relevant factors that are taken into account, when complying with best execution obligations. The purpose of this document is to set out in detail DSP s execution arrangements and best execution policy. Scope This policy applies to Dalton Strategic Partnership LLP. An investment firm shall be deemed to have executed a transaction where it performs any of the following activities that result in a transaction: a) reception and transmission of orders in relation to one or more financial instruments; b) execution of orders on behalf of clients; c) dealing on own account; d) making an investment decision in accordance with a discretionary mandate given by a client; e) transfer of financial instruments to or from accounts. Full Obligation for Best Execution Responsibility for best execution applies to DSP when we are deemed to be executing a transaction. This will generally be the case when we execute investment decisions to deal on behalf of the funds: a) In markets where we request a broker or other liquidity provider to use his own capital (risk price) in providing liquidity for a trade by dealing as principal; (Equities, Fixed Income, OTC & Listed Derivatives and some types of Foreign Exchange transactions). Dalton Strategic Partnership LLP December
2 b) In markets where we source natural liquidity by responding to a broker s advertised indication of interest (IOI); (Equities, Fixed Income, OTC & Listed Derivatives). c) Directly in the market as a participant in a Multi-Lateral Trading Facility (MTF); (Equities & Fixed Income). Shared Obligation for Best Execution Responsibility for best execution lies with not only DSP but also other entities we may trade with, as these may be subject to the MiFID II requirements on best execution. When we place orders on behalf of the funds we rely on brokers and other counterparties to execute orders on either an agency basis or alternatively as a Systematic Internaliser (SI). These entities then assume responsibility for best execution. This includes orders placed with other entities by DSP via proprietary algorithmic trading. In this circumstance, DSP must ensure that those executing entities have execution arrangements in place that allow DSP to meet its best execution requirement. DSP is then responsible for oversight and monitoring of the execution quality of the broker or other counterparty executing the relevant transactions. Order Placing Where DSP places orders on behalf of the funds it must ensure that orders are: actioned promptly; accurately recorded and allocated; and executed sequentially unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the client require otherwise. The execution process, from order inception through to final settlement, is designed to obtain the best possible result for the client. This process is as follows: 1. The DSP Portfolio manager ( PM ) raises and records an investment decision via the firm s Order Management System (OMS). 2. Order is accepted by the DSP Dealing Team ( DT ) into the Execution Management System ( EMS ) after it has passed all automated compliance checks. 3. DT select venue/broker in line with execution strategy and venue selection criteria detailed below. 4. Trade execution fills feedback automatically to EMS/OMS via fix. 5. Upon completion orders are allocated and booked to the relevant accounts for settlement. When PMs have no access to the OMS, orders can be sent to the DT via copying, in compliance. When these types of orders are placed out of office hours, the DT will place the order directly to a broker s execution desk and recording into systems as soon as practicable. In limited circumstances the PM may place an order directly with an execution venue. Execution Factors When providing execution services to the funds, we must act in accordance with the best interests of each fund. We take all sufficient steps to obtain the best possible result ( best execution ) for the funds taking into account the following factors: price, costs (implicit and explicit), size, Dalton Strategic Partnership LLP December
3 speed, likelihood of execution, likelihood of settlement, the nature of the order, the ability to retain anonymity in the market, (and limiting information leakage); the characteristics of the Funds including the professional client categorisation The relative importance of each of these factors within our execution process will vary depending upon a number of criteria, being: 1. the investment intent of the portfolio manager who created the order at DSP; 2. the characteristics of financial instruments that are the subject of that order; and 3. the characteristics of the execution venues to which that order can be directed. Each order is unique in its characteristics with market conditions never constant. A further factor relevant to best execution is counterparty risk, particularly in the case of instruments which are not settled by delivery versus payment; DSP s credit risk assessment of counterparties may have an impact on our selection of the trading counterparty. The relative importance of these execution factors is therefore variable. However, in most transactions, a combination of total consideration (price plus implicit and explicit costs) and size are usually the most relevant best execution factors. Regulatory requirements provide that best execution does not demand that firms achieve the best possible result with each individual order, but that all sufficient steps should be taken to ensure intended execution outcomes are achieved on an ongoing basis. Consequently our policy is to have a process which ensures that every client order is treated in a way that maximises the chance of getting the best outcomes when trading. Execution Venue Selection Selection of a venue for the execution of an order will be based upon the Execution Factors referred to above. Our policy is to access market liquidity via various methods that offer the potential for DSP to obtain the best possible result with respect to the orders on a consistent basis. We are not affiliated with any broker, bank or venue, allowing us flexibility of venue choice. As a general rule, we will try to identify venues which are sources of mid-point liquidity before entering an order into the lit market; this reduces the spread cost between bid and offer prices and helps reduce market impact as well as information leakage. We verify the execution arrangements in place at the execution venues of choice to ensure that DSP is able to offer best execution to its clients. Our approved trading venues include: Brokers (who in turn will access the market through a venue of their choice) Regulated markets and recognised investment exchanges Electronic crossing networks, such as Liquidnet and ITG Posit Multilateral trading facilities (MTF s), such as Chi-X and Turquoise Systematic Internalisers (SI s), who are primarily bilateral (client vs. house) execution venues with a distinct regulatory status and with enhanced pre- and post-trade transparency requirements Third party investment firms acting as market makers or other liquidity providers. This may include non-eu entities carrying out these functions. Typically, we will use these firms as they provide us with the ability to invest in certain collective investment schemes (pooled funds) Dalton Strategic Partnership LLP December
4 1. Equities Venue Types Used : Brokers ; Regulated Markets ; Electronic Crossing Networks (ECN) ; Multilateral trading facilities (MTF) ; Systematic Internalisers (SI) ; Third party Investment Firms We consider an array of venues and entities, selecting only those we deem appropriate on a tradeby-trade basis when trading in equities on behalf of the funds. The three core routing categories are: i) High Touch Broking Desks These may be brokers who transact on DSP s behalf, on Regulated Markets, through both their own or third part MTF s, or as a Systematic Internaliser (either on a principal or agency basis). When we receive orders that require instant execution, the relative importance of speed and liquidity may be higher than that of price and cost. In these situations, our traders would weigh the benefit of using broker capital (principal risk trade), where the guarantee of liquidity outweighs the cost of discount or premium attached to that risk. In this scenario the negotiated price and size becomes more subjective and is dependent on the level of risk the broker is comfortable with. We may use Program Desks when investing new money for the funds, dealing with redemptions or implementing asset allocation changes. When trading in multiple securities for one or more funds simultaneously, a Program Trade may be the more efficient, controlled and cost effective way of transacting. Savings result primarily from lower commission rates. When executing a risk Program Trade, we generally ask two or more brokers to compete for the business. In times of extreme volatility we may use high touch brokers as an additional order management resource. ii) Algorithmic Execution Providers These are orders traded electronically, in line with certain parameters, (e.g. specified target percent of volume) via a variety of brokers proprietary platforms. We use algorithmic trading primarily to keep execution costs down, retaining order control and fill transparency. We select our brokers for algorithmic trading based on previous execution performance, the transparency of their order handling process and the quality of the general service we receive. iii) Independent Electronic Crossing Networks (e.g. Liquidnet/ITG Posit) When we have large single stock orders to transact, particularly those deemed Large-In-Scale (LIS), we typically use MTFs to find a block-sized match with a natural counter trade. The negotiated price will be based around the prevailing best bid and offer price on the primary market, usually deal at the mid of these two prices. The relative importance of size is a key factor, LIS trades being exempt from MIFID II dark pool caps. Furthermore dealing at the mid price improves spread capture. Dalton Strategic Partnership LLP December
5 2. Exchange Traded and OTC Derivatives Venue Types Used : Brokers ; Regulated Markets ; Multilateral trading facilities (MTF) DSP transacts in exchange-traded derivative instruments on behalf of the funds to hedge against market risk, and to gain exposure to underlying assets. Listed derivatives are in the majority of cases not fungible, and DSP s choice of Execution Venue may therefore be limited. The decision to deal on a particular exchange may therefore be based primarily on the fact that there are no alternative sources of dealing in the products being traded. For example, a PM generates an order in the FTSE- 100 Index future, DSP has no alternative than to transact, via an intermediary, on ICE Futures Europe as this is currently the only venue for that product. Where there is only one execution venue then time and price of execution will be the highest ranked execution factor. Size or order and liquidity will determine whether we access the relevant exchange via high touch, broker algorithm or RFQ (Request for Quote). DSP may transact in over-the-counter (OTC) derivatives on behalf of the funds either when we wish to gain exposure to an underlying asset to which there is no listed equivalent, or when pricing/liquidity may be enhanced. Dalton Strategic Partnership LLP December
6 3. Fixed Income Venue Types Used : Brokers ; Regulated Markets ; Electronic Crossing Networks (ECN) ; Multilateral trading facilities (MTF) As over the counter (OTC) products are not executed on any exchange, it is important we have a sufficient list of counterparties available for us to source the liquidity we require. The choice of counterparty and strategy for trading will be determined by the asset class involved. Where we trade more liquid instruments, such as G10 sovereign bonds or some higher rated corporate bonds, we may execute electronically using a Request For Quote model (asking multiple counterparties to quote, with the best price securing the order). In general, use of these venues essentially performs the price discovery function. For transactions that are not executed using an online, auction-type venue, DSP will use reasonably available and relevant sources of price discovery, including, but not limited to, market transaction prices (e.g. TRACE data) on historical or comparable financial instruments; quotes for, or yields on, historical or a comparable financial instrument; third party pricing vendor prices (viewed with current day market colour) and external or internal pricing models, to establish the best price. Quotes generally should be obtained from more than one counterparty as part of the price discovery process; however, this is not always possible or desirable. In certain markets, attempting to obtain multiple quotes could lead to information leakage and consequently have a negative impact on obtaining best execution. DSP will consider whether multiple quotes can or should be obtained depending on the security type, the security to be traded, the size of the transaction and the prevailing market conditions. All derivatives must be traded under industry legal documentation. This means our choice of counterparty for trading interest rate swaps, inflation swaps, swaptions, credit default swaps and currency forward contracts is generally limited to those banks where the required documentation is in place. As with the process for bond trading detailed above, how we execute a derivatives trade will very much be dependent on the size of the transaction and the liquidity available. Dalton Strategic Partnership LLP December
7 4. Foreign Exchange (FX) Venue Types Used : Brokers ; Regulated Markets Foreign Exchange trades are either conducted through our funds appointed custodian bank, or through a third party bank on DSP s approved broker list, with reference to market rates appropriate for the trade size. DSP undertakes an active negotiation process with regard to direct FX transactions it undertakes for the funds. All FX derivative transactions, as well as FX spot transactions that are ancillary to transactions in MiFID financial instruments, are in scope of the rules on best execution. In relation to other spot transactions, that are not in scope, undertaken as a result of investment decisions in accordance with DSP s discretionary mandate, DSP will nevertheless strive to achieve an optimal outcome for the funds. DSP shall not employ best execution or actively negotiate rates with regard to those indirect spot FX transactions which are undertaken for the funds by third parties such as the funds custodian. Indirect FX transactions are those undertaken without DSP s active involvement such as income repatriation and restricted currency trades. Dalton Strategic Partnership LLP December
8 Monitoring and Review Arrangements The purpose of our monitoring programme is to firstly test the effectiveness of our overall execution arrangements and, secondly, to have oversight of our regulatory obligations on best execution. Our monitoring programme also includes the identification and assessment of the execution arrangements in place at the venues of choice. Through a combination of trade sample analysis and Transaction Cost Analysis, we seek to identify any trends or outliers against relevant benchmarks e.g. Implemantation Shortfall and Interval Volume-Weighted Average Price. i) Real-time Trade Monitoring The effectiveness of our order execution arrangements is monitored by the DSP Dealing Team on an ongoing basis. Once an order is in the market the dealing team will continuously monitor execution strategy in order to obtain the best possible outcome. ii) Post Trade Execution Quality Analysis DSP s Best Execution and Broker Review Committee formally reviews our trading effectiveness on a quarterly basis through broker and independent third party Transaction Cost Analysis. The Committee also reviews trade outliers, commission activity, counterparties, internal trading issues and industry best practice. The committee is comprised of senior management from several areas of DSP including: Trading, Portfolio Management, Legal and Compliance. The Committee subsequently refers its findings to the management board for their approval. iii) Broker Selection Our Policy is to take sufficient steps to determine, when placing an order with another entity to execute, that the entity has arrangements that will enable DSP to comply with the best execution obligation. The criteria to add a counterparty or broker to the Approved List is generally based on evaluation of a number of quantitative and qualitative factors that may include, but are not limited to: competitiveness of commission rates or spreads; promptness of execution; clearance and settlement capabilities; provision of delegated regulatory reporting; quality of service; willingness to commit capital; creditworthiness; and reputation; iv) Execution Policy The Policy is reviewed on an annual basis, to assess whether it is effectively designed to enable the firm to obtain the best possible result for the execution of its orders. This review will include consideration of: The inclusion of additional execution venues or entities; Dalton Strategic Partnership LLP December
9 The factors that determine the choice of venues or entities in the best interest of the funds, including any execution fees, any potential non-monetary benefits attached to the execution services and fees charged by DSP to determine the overall cost-benefit for the funds; The removal of any existing execution venues or entities; and material changes to factors to ensure we continue to achieve best execution. The Policy will also be reviewed on the occurrence of a material change in our dealing arrangements or a material change in our underlying regulatory obligations. A material change means a significant event of an internal or external nature that could materially impact considerations of best execution such as cost, price, speed, likelihood of execution, likelihood of settlement, the ability to retain anonymity in the market, prevention of information leakage, size, nature or any other consideration relevant to the execution of the order. We will notify the funds of any material changes to our execution arrangements or the Policy. The addition or removal of a broker from our approved list would not typically be deemed a material change. Aggregation and Allocation Policy Orders received at the same time with the same instruction or limit may be aggregated and executed in block format. Normally this will work to the advantage of the funds concerned, by achieving a more advantageous price through benefits of scale and by not having separate market orders competing against each other and excessively impacting the price to the detriment of both funds. On some occasions such aggregation may be disadvantageous. Partially executed orders will be allocated on a pro rata basis among all accounts involved in the trade by the OMS automatically, subject to any price limits that dictate otherwise. New Issues The above policy applies equally to the purchase of new issues. For portfolios where the underwriter s allocation of a new issue would result in the security constituting less than 0.25% of a fund s Net Asset Value, the portfolio manager may exercise best judgment in allocating securities. Crosses Crosses executed between funds run by the same fund manager are to be effected at mid market price or in certain scenarios, described below, at the day s closing price. Those executed between customers managed by separate portfolio managers are crossed at a price agreed by the managers which is within the bid offer spread at that time. All crosses must be passed through an external broker unless approved by the Compliance Officer. Crosses are transactions and orders that are placed with external brokers independently and are therefore treated in the same way a every other order for the purpose of best execution. Additionally, a portfolio manager managing multiple funds within the same strategy may (in order to manage cash or for other reasons) wish to increase positions in one fund and decrease positions in another. In this situation, it is may be appropriate to arrange for cross trades to be struck at market closing prices. This achieves certainty of execution, consistency with the prices used on that day for the valuation of the relevant funds, and equality between the funds so that there is no performance gain or loss resulting from a rebalancing which was in the interests of both funds. Closing Auctions Orders submitted for a closing market auction must be limited to a price which is no greater than 1% differential from the indicative auction price at the time the order is instructed. Dalton Strategic Partnership LLP December
10 Dealing Errors Dealing errors will be reviewed on a case by case basis to determine whether there is a material disadvantage to a fund, group of funds or an individual investor. When an error occurs the Dealing Team will, within 24 hours of its occurrence, complete and send a reporting form to the Compliance Officer and Chief Executive Officer who will determine independently whether there is a requirement for the Investment Manager to compensate the fund as well as any possible steps to ensure the error is not repeated. The Chief Executive Officer has ultimate discretion on the payment of compensation. The firm maintains professional indemnity insurance to mitigate the risk of a large error resulting in a significant compensation payment. Dalton Strategic Partnership LLP December
Order Execution Policy Macquarie Investment Management EMEA
Macquarie Investment Management EMEA Version: 2.0 Last approved: December 2017 Last updated: December 2017 Policy owner: Compliance 1. Policy Statement In accordance with regulatory obligations in the
More informationThe jurisdiction of this policy is extended to Tokyo Marine Rogge Asset Management Limited.
ORDER EXECUTION POLICY (PUBLIC) As of 19 March 2018 1. Policy Statement This document shall outline the principles that apply to the execution of orders in financial instruments on behalf of the funds
More informationOrder Execution Policy 3 rd January 2018
Nordea Investment Management Order Execution Policy 3 rd January 2018 Contents 1. Purpose... 2 2. Regulatory context... 2 3. Scope... 2 4. Order process... 3 5. Execution decision process... 5 6. Venue
More informationJefferies International Limited
Jefferies International Limited Order Execution Policy August 2015 Issued November 2013 Version 2.0 Supersedes all previous Compliance Policies regarding this subject matter Jefferies International Limited
More informationBest Execution Policy
Best Execution Policy River and Mercantile Asset Management LLP Prepared by: River and Mercantile Asset Management LLP Compliance Department Version Number: 1.0 Date Last Approved: 18 December 2017 Approved
More informationOrder Execution and Placement Policy
Order Execution and Placement Policy Version Effective Date 1.1 30 April 2018 Contents Section 1. Introduction... 3 1.1 Purpose... 3 1.2 Scope... 3 1.3 Specific client instructions... 4 1.4 Restricted
More informationBest Execution Policy
Lombard Odier Asset Management (Switzerland) SA Lombard Odier Asset Management (Europe) Limited Lombard Odier Funds (Europe) SA Best Execution Policy Approval and review Document owner Approval authority
More informationCanada Life Investments
Canada Life Investments Order Execution Policy Owner Delegated Owner/s Last Approved 23 February 2018 Next Review Due Q1 2019 Version Number V1 2018 David Marchant, Managing Director & Chief Investment
More informationOrder Execution Policy financial instruments
Order Execution Policy financial instruments Applicable from 3 January 2018 DB0172UK 2017.09 This policy sets out the principles that we follow when executing orders for our retail and professional clients
More informationJefferies International Limited
Jefferies International Limited Order Execution Policy January 2018 Issued November 2013 Version 3.0 Supersedes all previous Compliance Policies regarding this subject matter Jefferies International Limited
More informationNordea Execution Policy
Nordea Execution Policy 1 January 2018 The President of Nordea Bank AB (publ) and Chief Executive Officer (CEO) in Group Executive Management has approved this execution policy ( Execution Policy ), which
More informationC. EXECUTION POLICY TERMS OF BUSINESS
C. EXECUTION POLICY This policy sets out the principles that the Bank follows when executing orders of retail and professional Clients in financial instruments to ensure that the Bank s Clients obtain
More informationMorgan Stanley s EMEA Equity Order Handling & Routing. Frequently Asked Questions. (Last Updated: March, 2018)
Morgan Stanley s EMEA Equity Order Handling & Routing Frequently Asked Questions (Last Updated: March, 2018) This document is part of Morgan Stanley International plc s ( Morgan Stanley ) ongoing efforts
More informationInformation on the RBC I&TS (UK) Best Execution Policy
Information on the RBC I&TS (UK) Best Execution Policy RBC I&TS, UK December 2017 TABLE OF CONTENTS 1.0 PURPOSE OF THIS DOCUMENT...3 2.0 SCOPE OF THE POLICY...3 3.0 WHAT IS THE BEST EXECUTION OBLIGATION?...3
More informationBest Execution and Order Handling Policy
Best Execution and Order Handling Policy OR Taxonomy: Client-related Business Conduct Owner/Issuer: Head Global Trading and Order Generation Why do we have this policy? This policy will set a standard
More informationNEWTON ORDER EXECUTION POLICY
NEWTON ORDER EXECUTION POLICY Version 1.7 December 2017 Effective 3 January 2018 CONTENTS I. Purpose and scope II. Exclusions III. How will orders be executed for the client? IV. Best execution obligation
More informationOrder Execution Policy Purpose and Scope
Order Execution Policy Purpose and Scope As required by the Financial Conduct Authority ( FCA ) rules implementing the Markets in Financial Instruments Directive ( MiFID ), this statement sets out Oppenheimer
More informationORDER EXECUTION AND TRADE HANDLING POLICY
ORDER EXECUTION AND TRADE HANDLING POLICY 2017 Order Execution and Trade Handling Policy 2 2017 ORDER EXECUTION AND TRADE HANDLING POLICY 1 INTRODUCTION Baillie Gifford invests in various asset classes
More informationOrder Handling and Best Execution Policy
Order Handling and Best Execution Policy Effective 3 January 2018 TABLE OF CONTENTS 1 INTRODUCTION... 4 2 PURPOSE OF THIS POLICY... 4 3 ABBREVIATIONS... 5 4 DEFINITIONS... 6 5 POLICY APPLICATION... 8 6
More informationST. JAMES S PLACE UNIT TRUST GROUP ORDER EXECUTION POLICY
ST. JAMES S PLACE UNIT TRUST GROUP ORDER EXECUTION POLICY 1. PURPOSE AND BACKGROUND This document is a description of the St. James s Place approach to order execution and the placement of orders in financial
More informationOrder Execution Policy
Order Execution Policy Introduction This Order Execution Policy (Policy) covers Mirabaud Securities Limited, its representative offices in Geneva and Zurich, and Mirabaud Securities Limited, Sucursal en
More informationStatement on Best Execution Principles of Credit Suisse Asset Management (Switzerland) Ltd.
Statement on Best Execution Principles of Credit Suisse Asset Management (Switzerland) Ltd. Version 1.0 Last updated: 03.01.2018 All rights reserved Credit Suisse Asset Management (Switzerland) Ltd. Table
More informationBlueBay Asset Management LLP RTS 28 Qualitative Assessment of Execution (year ending 31 st December 2017)
BlueBay Asset Management LLP RTS 28 Qualitative Assessment of Execution (year ending 31 st December 2017) April 2018 Page 1 of 7 Explanatory statement BlueBay has in place an Order Execution Policy ( the
More informationTMS BROKERS EUROPE BEST EXECUTION POLICY
TMS BROKERS EUROPE BEST EXECUTION POLICY 1. INTRODUCTION 1.1. This policy is issued pursuant to, and in compliance with, EU Directive 2004/39/EC of 21 April 2004 on Markets in Financial Instruments ("MiFID")
More informationARCHITAS ORDER EXECUTION POLICY: SUMMARY STATEMENT. October 2017 INTRODUCTION
Architas Order Execution Policy: Summary Statement ARCHITAS ORDER EXECUTION POLICY: SUMMARY STATEMENT INTRODUCTION This Order Execution Policy applies to Architas Multi-Manager Limited and Architas Advisory
More informationORDER EXECUTION POLICY. ABG Sundal Collier Group
ABG Sundal Collier Group 3 January 2018 1 Introduction This policy applies to all legal entities directly or indirectly controlled by ABG Sundal Collier ASA, collectively referred to as ABGSC or the Group.
More informationBest Execution Policy
Best Execution Policy 1. General information about this policy TOBAM manages portfolios of investments on a discretionary basis for investment funds and external segregated client s portfolio (together,
More informationBofAML EMEA Order Execution Policy Summary
1. Order Execution Policy This document provides a summary of Bank of America Merrill Lynch s ( BofAML ) Order Execution Policy ( Policy ), which BofAML will adopt when executing orders on behalf of clients.
More informationInformation on our MiFID order handling & execution policy
UBS Limited UBS AG London Branch 5 Broadgate London EC2M 2QS Tel. +44 20 7567 8000 www.ubs.com/ibterms Information on our MiFID order handling & execution policy Product general procedure cash equities
More informationBest Execution Policy
SUBJECT: BEST EXECUTION OVERVIEW: This policy sets out the rules and responsibilities for the best execution of orders on behalf of clients whom we have classified as professional clients of. TABLE OF
More informationBMI Order Execution Policy
BMI Order Execution Policy March 2018 1 P a g e Order Execution policy March 2018 Introduction This Order Execution Policy sets forth information relating to how Bank of Montreal Ireland Plc ( BMI ) seeks
More informationCanaccord Genuity Limited Order Execution Policy
Canaccord Genuity Limited Order Execution Policy April 2015 Introduction Under the EU Markets in Financial Instruments Directive 2004/39/EC (MiFID) and the rules of our regulator, the Financial Conduct
More informationOrder Execution Policy
(ATFX) Order Execution Policy ORDER EXECUTION POLICY Introduction In accordance with the rules of the Financial Conduct Authority (the FCA ) and the requirements of the Markets in Financial Instruments
More informationState Street Global Advisors Ireland Limited. Best Execution Policy
State Street Global Advisors Ireland Limited Best Execution Policy Policy Scope Approach State Street Global Advisors Ireland Limited (the Firm ) will take all sufficient steps to obtain, when executing
More informationBest Execution & Order Handling Policy
Best Execution & Order Handling Policy BGC Brokers LP, GFI Brokers Limited, GFI Securities Limited, Sunrise Brokers LLP. Policy Version V 1.3 Effective Date 20/02/2018 Best Execution and Order Handling
More informationOrder Execution Policy Disclosure. Effective as at 3 January 2018.
Order Execution Policy Disclosure. Effective as at 3 January 2018. Introduction This disclosure sets out selected details of the order execution policies applicable to Westpac Banking Corporation and Westpac
More informationOrder Execution Policy
Order Execution Policy Disclosure Statement February 2018 2 Introduction The primary service Stewart Investors provides to clients is that of portfolio management. We manage funds and portfolios on behalf
More informationORDER AND BEST EXECUTION POLICY
ORDER AND BEST EXECUTION POLICY SUMMARY: This document represents Hottinger Investment Management Limited ( HIM ) - FRN 208737 - Order & Best Execution Policy OWNER: HIM s Board of Directors and Compliance
More informationORDER EXECUTION POLICY FOR PROFESSIONAL CLIENTS Applicable to ENGIE GLOBAL MARKETS head office and branches in the European Economic Area
ORDER EXECUTION POLICY FOR PROFESSIONAL CLIENTS Applicable to ENGIE GLOBAL MARKETS head office and branches in the European Economic Area Version V.2.0 Last update 15 December 2017 Contents I. PURPOSE
More informationInformation on the RBCCM Europe Best Execution Policy
Information on the RBCCM Europe Best Execution Policy RBC Capital Markets, Europe March 2018 TABLE OF CONTENTS 1.0 PURPOSE OF THIS DOCUMENT... 3 2.0 SCOPE OF THE POLICY... 3 3.0 WHAT IS THE BEST EXECUTION
More informationBNY Mellon EMEA Order Handling and Execution Policy
BNY Mellon EMEA Order Handling and Execution Policy For Professional Clients Effective date: 3 rd January 2018 Version number: 1.0 Information Classification: Public 1. INTRODUCTION In accordance with
More informationBest Execution & Order Handling Policy
Best Execution & Order Handling Policy BGC Brokers LP, Aurel BGC, GFI Brokers Limited, GFI Securities Limited, Sunrise Brokers LLP. Policy Version V 1.1 Effective Date 03/01/2018 Best Execution and Order
More informationOrder Execution Policy
Applicable to: Deutsche Asset Management International GmbH Deutsche Asset Management Investment GmbH Deutsche Asset Management (UK) Limited Deutsche Alternative Asset Management (Global) Limited Deutsche
More informationREPORT OLD MUTUAL GLOBAL INVESTORS (UK) LIMITED QUALITATIVE EXECUTION
REPORT OLD MUTUAL GLOBAL INVESTORS (UK) LIMITED QUALITATIVE EXECUTION APRIL 2018 MIFID II REQUIRES (UK) LIMITED (OMGI) TO PRODUCE THIS QUALITATIVE EXECUTION REPORT COVERING ORDERS EXECUTED IN 2017. APPENDIX
More informationOrder Execution and Allocation Policy
Order Execution and Allocation Policy January 2018 1. Scope 3 2. General 3 3. Order execution: Fixed income and forward foreign exchange 3 4. Order transmission: Equities 3 Contents 5. Factors considered
More informationJ.P. MORGAN EMEA FIXED INCOME, CURRENCY, COMMODITIES AND OTC EQUITY DERIVATIVES: EXECUTION POLICY
JANUARY 2018 E M E A F I C C A N D O T C E Q U I T Y D E R I V A T I V E S : E X E C U T I O N P O L I C Y J.P. MORGAN EMEA FIXED INCOME, CURRENCY, COMMODITIES AND OTC EQUITY DERIVATIVES: EXECUTION POLICY
More informationNordea Execution Policy
Nordea Execution Policy January 2017 The President of Nordea Bank AB (publ) and Chief Executive Officer (CEO) in Group Executive Management has approved this execution policy ( Execution Policy ), which
More informationSummary of Best Interest & Order Execution Policy. Regulated by the Cyprus Securities and Exchange Commission No. 335/17
Summary of Best Interest & Order Execution Policy Regulated by the Cyprus Securities and Exchange Commission No. 335/17 1. Introduction This Summary Best Interest and Order Execution Policy ( the Policy
More informationA CYPRUS INVESTMENT FIRM REGULATED BY THE CYPRUS SECURITIES AND EXCHANGE COMMISSION
License Number: KEPEY 066/06 Reg. office: 2-4 Arch Makarios III Ave, Capital Center, 9th Floor, P.O.Box 21255, CY-1505, Nicosia, Cyprus Head office: Alpha Business Center, 1 st Floor, Block B, 27 Pindarou
More informationEXANE EXECUTION POLICY
EXANE EXECUTION POLICY DISCLAIMER Exane 2016. All rights reserved. No part of this document may be reproduced in any form or by any means - electronic, mechanical, photocopying, recording or otherwise
More informationEXECUTION POLICY JANUARY 2018
EXECUTION POLICY JANUARY 2018 OVERVIEW We are active equity specialists, crafting high-conviction portfolios for client-focused solutions. Investment excellence is at the heart of our business. This policy
More informationBEST EXECUTION AND CLIENT ORDER HANDLING POLICY FOR PROFESSIONAL AND RETAIL CLIENTS
BEST EXECUTION AND CLIENT ORDER HANDLING POLICY FOR PROFESSIONAL AND RETAIL CLIENTS APPLICABLE TO SOCIÉTÉ GÉNÉRALE ENTITIES IN THE EUROPEAN ECONOMIC AREA (Head office, Branches, and Subsidiaries) Version
More informationLombard Odier Group Markets in financial instruments directive (MiFID) Conflict of interest policy and Order Execution Policy
Lombard Odier Group Markets in financial instruments directive (MiFID) Conflict of interest policy and Order Execution Policy Markets in financial instruments directive (MiFID) conflict of interest policy
More informationBest Execution Policy. Crossbridge Capital LLP
Best Execution Policy Crossbridge Capital LLP Contents 1 Introduction... 3 1.1 The Best Execution obligation... 3 1.2 Application of FCA and EU regulations... 3 1.3 Direct and indirect execution... 4 1.4
More informationB E S T E X E C U T I O N P O L I C Y
True Trade Limited Best Execution Policy POLICY INFORMATION Policy date February 2018 Policy owner Head of Legal and Compliance Contact person John Rufford Version 2.0 1 Overview This Best Execution Policy
More informationPrimary execution factors considered. 1 Most Least
2017 Best Execution Summary The MiFID II regulations require Reyker to produce a report to detail the methodologies employed by Reyker for the execution of client orders. This report is broken down according
More informationBest Execution. Introduction. This policy should be read in conjunction with other documents
Best Execution Best Execution Introduction Our Best Execution Policy (the Policy ) is applicable if you are a client of ours where: a. we execute on your behalf deals in respect of financial instruments
More informationOrder Execution Policy Instant Execution
Order Execution Policy 1. Introduction 8Safe UK Limited (hereafter 8Safe UK, or the Company ), whose registered office is at Broadgate Tower, 20 Primrose Street, London EC2A 2EW, United Kingdom is authorised
More informationSberbank CIB (UK) Limited
& SIB (Cyprus) Limited, London Branch 85 Fleet Street, 4th Floor, London EC4Y 1AE, United Kingdom Phone +44 0 207 583 3257 Fax +44 0 207 822 0779 Order Execution Policy October 2017 SBERBANK CIB (UK) LIMITED
More informationWilliam Blair: Client Order Execution Policy
William Blair: Client Order Execution Policy December 2017 Purpose of the Policy The Client Order Execution Policy sets forth information relating to how William Blair International Limited ( WBIL or the
More information2017 MiFID II EXECUTION QUALITY REPORT
2017 MiFID II EXECUTION QUALITY REPORT 1. Scope and Background T. Rowe Price International Ltd ( TRPIL ) is an investment firm subject to the Markets in Financial Instruments Directive II ( MiFID II ).
More informationOrder Execution Policy STP/ECN
Order Execution Policy STP/ECN Order Execution Policy 1. Overarching Principles IronFX Global (South Africa) (Pty) Ltd ( IronFX SA ), in line with the Financial Advisory and Intermediary Services Act,
More informationOrder Execution Policy. January 2018 v1
Order Execution Policy January 2018 v1 Table of Contents Introduction... 2 Scope... 2 Background... 3 Legislation Reference... 3 Business Model... 3 Client Category... 4 Authorised Personnel... 4 Best
More informationCiti Markets & Banking EXECUTION POLICY
Citi Markets & Banking EXECUTION POLICY July 2010 CITI MARKETS & BANKING EXECUTION POLICY July 2010 This policy, which we refer to as the General Policy, sets forth the general basis on which Citi Markets
More informationAgent - The Company receives the Client orders which are then transmitted to the Liquidity Providers for further execution.
Version 6.0 1.1. Following the implementation of the Markets in Financial Instruments Directive (MiFID II) in the European Union and its transposition in Cyprus with Law 87(I)/ 2017, the Company is required
More informationOrder Execution Policy
Order Execution Policy Effective 3 January 2018 1 Contents 1. Purpose... 3 2. Scope and Applicability. 3 3. Order Execution. 3 4. Best Execution..... 3 5. Applicability of Best Execution... 3 6. Execution
More informationBest Execution and Client Order Handling Policy
Best Execution and Client Order Handling Policy Date : March 2018 Introduction and Purpose In order for Guy Butler Limited (GBL) to be compliant with the Markets in Financial Instruments Directive (2014/65/EU)
More informationOrder Execution Policy - Corporate & Investment Bank Division - EEA
Level 3 Order Execution Policy - Corporate & Investment Bank Division - EEA Deutsche Bank AG (branches & relevant affiliates within the EEA) Corporate & Investment Banks Division ( The Bank ) 1. Introduction
More informationOrder Execution Policy for clients of the SEB
Order Execution Policy for clients of the SEB Effective from 03.01.2018 Table of Contents 1. Introduction 3 2. Scope 4 2.1 Clients covered 4 2.2 Geographies covered 4 2.3 Financial Instruments covered
More informationExecution Policy. 1 Purpose. to and taking into account the execution factors (see paragraph 4).
Execution Policy 1 Purpose We have put in place an Execution Policy to ensure that, as required by the FCA Rules, we take all sufficient steps to obtain the best possible result on behalf of our Clients
More informationSummary of the Best Execution Policy
1. Introduction The summary of the Best Execution Policy outlines the key arrangements The Toronto-Dominion Bank (London Branch), TD Securities Limited, TD Bank (Europe) Limited and TD Global Finance Unlimited
More informationINFORMATION ON THE ORDER EXECUTION POLICY OF PATRIA FINANCE FOR PROFESSIONAL CLIENTS
INFORMATION ON THE ORDER EXECUTION POLICY OF PATRIA FINANCE FOR PROFESSIONAL CLIENTS 1. SCOPE OF BEST EXECUTIONS In accordance with the Markets in Financial Instruments Directive 2014/65/EU ( MiFID II
More informationUnion Bancaire Privée UBP SA, London Branch London, Asset Management Order Execution Policy Equities
Union Bancaire Privée UBP SA, London Branch London, Asset Management Order Execution Policy Equities 1. Introduction As required by the Directive n 2014/65/UE of the European Parliament and of the Council
More informationSTIFEL NICOLAUS EUROPE LIMITED ORDER EXECUTION POLICY
STIFEL NICOLAUS EUROPE LIMITED ORDER EXECUTION POLICY This Order Execution Policy is supplemental to the Stifel Nicolaus Europe Limited ( SNEL, we, the firm, our or us ) Terms and Conditions and thus forms
More informationLAM S BEST SELECTION AND BEST EXECUTION POLICY
Date reviewed/updated April 2017 LAM S BEST SELECTION AND BEST EXECUTION POLICY This document provides information on the best selection and best execution policy of Lyxor Asset Management ( LAM ). 1.
More informationCITI SECURITIES SERVICES EXECUTION POLICY
CITI SECURITIES SERVICES EXECUTION POLICY ISSUE DATE: JANUARY 2018 VERSION: 1.0 2017 Citigroup Inc. TABLE OF CONTENTS 1 POLICY 3 ANNEX A: PRODUCT SPECIFIC POLICIES 10 2017 Citigroup Inc. POLICY 1 PURPOSE
More informationTowers Watson Investment Management (Ireland) Limited. Towers Watson Investment Management Limited. Best Execution and Order Handling Policy
Towers Watson Investment Management (Ireland) Limited Towers Watson Investment Management Limited Best Execution and Order Handling Policy Section I: Overview 1. Scope This policy applies to Towers Watson
More informationOrder Handling and Execution Policy. January 2018
fu Order Handling and Execution Policy January 2018 Contents 1. Purpose 3 2. Scope 3 2.1. Receipt and Transmission of Orders 3 2.2. Execution of Orders on Behalf of Clients 3 2.3. Requests for Quote 3
More informationSelection and Execution Policy
Selection and Execution Policy April 2015 SELECTION & EXECUTION POLICY Purpose This document describes how selection and execution policies are established when Amundi carries out its portfolio management
More informationBest Execution Policy Customer Distribution
Best Execution Policy Customer Distribution ICBC Treasury Department This document is the property of ICBC London Plc and may not be copied, used or disclosed in whole or in part, stored in a retrieval
More informationNordea Execution Policy
Nordea Execution Policy November 2014 The President of Nordea Bank AB (publ) and Chief Executive Officer of the Nordea Group (CEO) in Group Executive Management have approved this policy, which was last
More informationOrder Execution Policy
Order Execution Policy December 2017 Order Execution Policy 1. General Information, trading under the registered name of Equiti or Divisa Capital (Company Registered No. 07216039), is authorised and regulated
More informationBEST INTEREST AND ORDER EXECUTION POLICY
BEST INTEREST AND ORDER EXECUTION POLICY 1. Introduction This Summary Best Interest and Order Execution Policy ( the Policy ) is provided to you (our Client or prospective Client) in accordance with the
More informationQuality of Execution Annual Report
Quality of Execution Annual Report Firm: Cheyne Capital Management (UK) LLP ( Cheyne Capital or the Firm ) Calendar Year Disclosure Period: 1 st January 2017 to 31 st December 2017 Report Date: 30 th April
More informationGLOBAL ORDER EXECUTION POLICY
This document is for professional clients only. It is not to be distributed to or relied on by retail clients. GLOBAL ORDER EXECUTION POLICY NOVEMBER 2017 avivainvestors.com Date Version Number Changes
More informationING Wholesale Banking Best Execution and Order Handling Policy
ING Wholesale Banking Best Execution and Order Handling Policy 1. When do we apply best execution to client transactions? This ING Wholesale Banking Best Execution and Order Handling Policy (the Policy)
More informationAPPLICABLE AS FROM
SUMMARY OF THE ORDER EXECUTION AND ORDER HANDLING POLICY ( THE POLICY ) APPLICABLE AS FROM 03.01.2018 Table of Contents What is Best Execution? 3 How will your orders be executed? 3 Where do we execute
More informationPictet Asset Management Best Execution Policy
Pictet Asset Management Best Execution Policy CONTENTS 1. Introduction 2 2. Scope 2 Direct Responsibility for Best Execution 2 Indirect Responsibility for Best Execution 3 3. Order Execution 3 4. Execution
More informationINTL FCSTONE LTD INFORMATION ON ORDER EXECUTION POLICY. April 2018
INTL FCSTONE LTD INFORMATION ON ORDER EXECUTION POLICY April 2018 INTL FCStone Ltd 1 st Floor, Moor House, 120 London Wall, London, EC2Y 5ET Telephone +44 (0)20 3580 6000 Fax +44 (0)20 3580 6001 Registered
More informationBEST EXECUTION AGGREGATION AND ALLOCATION POLICY. Green Street Advisors (UK) Ltd (GSA)
BEST EXECUTION AGGREGATION AND ALLOCATION POLICY Green Street Advisors (UK) Ltd (GSA) Last reviewed: 12.2017 (MiFID II Update) BEST EXECUTION POLICY PART ONE: THE QUALITY OF EXECUTION In accordance with
More informationBest Execution Policy
Best Execution Policy 1 INTRODUCTION Usage of this Best Execution Policy must be in conjunction with the Compliance Manual and other company policies and procedures currently in effect and as amended from
More informationBest Execution, Order and Placement Policy
Best Execution, Order and Placement Policy DOCUMENT CONTROL Document Details Document Title: Applicability: Document Classification: Best Execution, Order and Placement Policy Thesis Asset Management Limited
More informationOrder Handling and Execution Policy Asset Class Specific Appendices Foreign Exchange (FX) Appendix
BNP London, Paribas June 2017 CIB Order Handling and Execution Policy Asset Class Specific Appendices Foreign Exchange (FX) Appendix BNP PARIBAS CIB GLOBAL MARKETS London, December 2017 Table of Contents
More informationBasis Capital Markets Order Execution Policy Disclosure
Basis Capital Markets Order Execution Policy Disclosure Order Execution Policy Disclosure Basis Capital Markets UK Limited, Basis UK (Firm Reference Number 732477), is an Appointed Representative of GCM
More informationOrder Execution Policy
Order Execution Policy Order Execution Policy September 2018 Introduction AUSPRIME is the tradename of Lttrader Limited (hereinafter the Company, We, Our, Us ), which is registered with the Register of
More informationQuality of Execution 2017 Annual Report
Quality of Execution 2017 Annual Report Report Date 30 th April 2018 This report is provided in respect of Boussard & Gavaudan Investment Management LLP registered in England and Wales with registration
More informationMorgan Stanley s EMEA Equity Order Handling & Routing. Frequently Asked Questions. (Last Updated: February, 2017)
Morgan Stanley s EMEA Equity Order Handling & Routing Frequently Asked Questions (Last Updated: February, 2017) This document is part of Morgan Stanley International plc s ( Morgan Stanley ) ongoing efforts
More informationBy giving SEB an Order the client agrees to the transaction being executed in accordance with this Policy.
Best Execution Policy 1. Introduction This document Best Execution policy (hereinafter the Policy ) specifies the procedures, which SEB will follow when executing or forwarding transaction orders (hereinafter
More informationCOLUMBIA THREADNEEDLE INVESTMENTS - EMEA 1 ORDER EXECUTION POLICY (FOR PROFESSIONAL CLIENTS)
COLUMBIA THREADNEEDLE INVESTMENTS - EMEA 1 ORDER EXECUTION POLICY (FOR PROFESSIONAL CLIENTS) Exchange Traded Products Annex - applicable to applicable to the following instrument types: Exchange Traded
More informationBest Execution Client Disclosure Statement HSBC UK Bank Plc Global Markets. Dated 1 July 2018 PUBLIC
Best Execution Client Disclosure Statement HSBC UK Bank Plc Global Markets Dated 1 July 2018 PUBLIC Copyright. HSBC UK Bank plc 2018 ALL RIGHTS RESERVED. No part of this publication may be reproduced,
More information