Vontobel Best Execution Policy

Transcription

1 Bank Vontobel AG Vontobel Best Execution Policy This document, (The "Vontobel Best Execution Policy"), contains a summary of the procedures that Bank Vontobel (hereafter named the "Bank") has implemented in order to achieve the best possible result when executing "Client" (hereafter named the "Client") orders in the purchase or sale of financial instruments (equities or other financial instruments). The objective of the "Vontobel Best Execution Policy" is to ensure the long term sustainability of the "Client's" interests. "Client's" who conclude securities transactions through Bank Vontobel can be assured of a professional, fair and transparent service. 1 Scope of the Policy The principles set out in the "Vontobel Best Execution Policy" pertain to the execution of orders given to the "Bank" by the "Client" for the purchase and sale of securities or other financial instruments. Execution as defined by the "Vontobel Best Execution Policy", implies that the "Bank", acting on the basis of a "Client" order executes a transaction with a third-party, in- or outside a regulated market (commission trade), on behalf of the "Client" or immediately concludes a purchase agreement for financial instruments with the "Client" (fixed price transaction) Fixed price transactions shall be covered by the provisions under Section 8. 2 "Client" Execution Achieving the best possible execution for the "Client" The "Bank" has established a process which assures the best possible execution for private and institutional investors, as defined by MiFID. In the context of this process, the criteria listed under section 3 shall be weighted and applied as deemed appropriate in order to achieve the best possible result for the "Client". The continuous implementation of this process ensures that, in accordance with the "Vontobel Best Execution Policy", the best possible results can constantly be achieved.

2 3. Juni 2015 Seite 2/5 3 Precedence of "Client" Instructions "Client" instructions take precedence over the principles of Best Execution listed in this document. When such instructions are given by the "Client", the "Bank" is exempted from adherence to the "Vontobel Best Execution Policy" within the scope of said instructions and the obligation to achieve the best possible execution is deemed to be fulfilled within the scope of the instructions given. 3.1 Instructions pertaining to execution venue The "Bank" will take the "Client's" instructions into consideration in respect to the execution venue. 3.2 Instructions pertaining to trading currency The "Bank" will reflect the "Client's" instructions in respect to trading currency in as far as the security in question can be traded in the requested currency. 3.3 Instructions pertaining to special kinds of orders "Client" instructions can also refer to the type and nature of an execution without a specific execution venue being defined. In particular, this pertains to discretionary security orders ("carefully"). These are orders that the "Bank" receives, with instructions to execute same in several stages depending on the market situation. For "careful" orders, the general practice for order execution between market players shall apply. 4 Selection Criteria and Weighting The "Bank" selects the trading venue in accordance with the list "Vontobel Trading Venues" (see attachment) in such a way that the best possible execution for the "Client" can be expected. The "Bank" considers the following criteria when selecting the trading venue, whereby the individual criteria are weighted to reflect the prevailing market constellation and the art of financial instrument involved: As primary criteria in order to get the best possible execution for the Client shall serve the total amount charged or credited to the "Client" under consideration of the direct and indirect costs of the execution, in particular foreign fees, taxes and commissions

3 3. Juni 2015 Seite 3/5 Likelihood of a full execution and settlement Speed of a full execution and settlement Size and nature of the order Prevailing market situation all other relevant aspects. 5 Trading Venues The "Client" order will be placed on a regulated market, a multilateral trading system (MTF), another supplier of liquidity or on one of Vontobel's internal markets. A list of "Vontobel Trading Venues" is part of a separate document. The document "Vontobel Trading Venues" forms an integral part of the "Vontobel Best Execution Policy". The "Bank" differentiates between the following forms of financial instruments when selecting execution venues: 5.1 Equities Equity orders are either placed manually, or through the use of "smart order router" system, directly on an exchange or with a broker, in order to attain the best possible execution. In those markets where the "Bank" is neither a member, nor does it have direct access through DMA, brokers are chosen that guarantee the best possible execution. 5.2 Interest-bearing securities Orders in trading currency CHF (Swiss Franc) are placed predominantly on the SWX Swiss Exchange. In the event of insufficient market liquidity or other reasons that indicate an obvious advantage to the "Client", or for non-listed securities, the "Bank" will conduct the transaction through interbank trading, either with another bank or another financial services provider. Orders in other trading currencies will usually be executed via interbank trading with another bank of financial services provider. Where an advantage for the "Client" can be expected, or no disadvantage is anticipated, the "Bank" will arrange a fixed-price transaction with the "Client" pursuant to Section 8.

4 3. Juni 2015 Seite 4/5 5.3 Certificates, warrants and financial derivatives Orders involving certificates, warrants and financial derivatives are usually placed on an exchange for execution. In the event of insufficient market liquidity or other reasons that would indicate an obvious advantage the "Client", the "Bank" will execute the transaction via interbank trading with the respective issuer or another trading partner that quotes prices in the security in question ("Market Maker"). The "Bank" can, especially where it is the issuer of the security or other financial instrument, conclude a fixed price transaction with the "Client" in said instrument in accordance with article Investment Funds The "Vontobel Best Execution Policy" does not apply to the acquisition or divesture of investment fund units via the custodian bank as subscriptions and redemptions of investment funds are usually transacted directly or indirectly via the fund trading platform of said custodian bank at the applicable Net Asset Value (NAV). 6 Broker Selection If the "Bank" is not a member of a selected trading venue, the order will be forwarded to a Broker for execution. The "Bank" maintains a Broker List that is maintained on the back of a documented selection process and periodical Quality Reviews and is binding for the Vontobel Group. In as far as the "Bank" has instructed a third party to execute a "Client's" order, the corresponding transaction is governed by the measures that the Third Party has taken to ensure the best possible execution. The execution quality of "careful orders" by the selected broker is measured versus the "Volume Average Weighted Price" as calculated by Bloomberg. 7 Special features in respect to fixed-price transactions In as far as an interbank trading execution is provided for in accordance with article , the "Bank" will acquire, or dispose of, the financial instrument in question at a negotiated price with a respective contractual partner.

5 3. Juni 2015 Seite 5/5 Note: In the event of an execution via interbank trading, this execution will not take place on a regulated market ("exchange") nor on a multilateral trading system, as defined by Art 4 para 1 No.14 MiFID. 8 Special features in respect to fixed-price transactions On conclusion of a fixed-price transaction, a purchase or sale agreement is arranged between the "Bank" and the "Client" and the "Bank" assumes ownership of the financial instruments (as purchaser) from the "Client", or delivers the financial instruments (as seller) to the "Client". In as far as such purchase or sell orders are conducted with the cope of a fixed-price transaction, the "Bank" will ensure that these orders are executed at the market conditions prevailing at the time of the transaction(s). To this end, all available on- and off-market quotes for the respective financial instrument will be consolidated. Note: Fixed-price transactions are always executed outside of a regulated market (exchange) and outside of a multilateral trading system as defined by Art 4 para 1 No14 MiFID. Execution on an organized market (exchange) or a multilateral trading system as defined by Art 43 para 12 No. 14 MiFID is possible for certain financial instruments. 9 Consent to off-market transaction In the event that an off-exchange execution is possible under the terms of the "Vontobel Best Execution Policy", the "Client" hereby gives his/her approval to execute such trade outside of an organized market or multilateral trading system. 10 Monitoring and Review of the "Vontobel Best Execution Policy" The, under the "Vontobel Best Execution Policy", selected execution venues and brokers will be periodically reviewed and amended as necessary. Furthermore, if the "Bank" has reason to believe that certain criteria for selecting a specific execution venue are no longer valid, it will conduct a review, at least once year, and make any changes deemed necessary. The "Client" permits the bank to make such amendments in this respect unilaterally. The "Bank" will inform the "Client" of any material changes in the "Vontobel Execution Policy by posting an updated version of this document in the internet on