LYXOR INTERMEDIATION S BEST SELECTION AND BEST EXECUTION POLICY

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1 Creation date 01/01/2017 Date of review /update 03/01/ /04/2018 LYXOR INTERMEDIATION S BEST SELECTION AND BEST EXECUTION POLICY This document contains information about LYXOR INTERMEDIATION s best selection and best execution policy. 1. CONTEXT AND APPLICABLE REGULATIONS LYXOR INTERMEDIATION is an investment firm approved by the French Prudential Supervisory and Regulation Authority (ACPR in French) to provide reception and transmission of orders and execution services for third parties covering all the financial referred to by the Article L211.1 of the French Monetary and Financial Code. The European Markets in Financial Instruments Directive 2014/65/UE of 15 may 2014 (hereinafter «MIFID2»), which came into force on 3rd January 2018, enhanced the common investor protection standards and reinforces the rules of good conduct applicable to financial intermediaries. The best selection and best order execution obligation is an important component of MIFID2. LYXOR INTERMEDIATION complies with this obligation by implementing the policy, which aims to (i) ensure the best selection of broker and counterparty (hereinafter Entities ) and Venues (as defined below) and/or (ii) take all sufficient steps to achieve the best possible result for its clients when executing their orders with regards to the criteria referred to below. Further details on Best Execution principal can be found in the following: Articles L533-18, L et L of the French Monetary and Financial Code ; Recommendations made by the AMF n (Guide dedicated to Best Execution). As of the date of the update of the present policy, LYXOR INTERMEDIATION s clients were Lyxor Asset Management, Lyxor International Asset Management and the Companies to which they have partly or totally delegated their fund management activity, acting on behalf of the Investment Funds or the mandates that they manage (hereafter the Companies ). These Companies are classified as Professional Clients. 1 1

2 2. ENTITY SELECTION POLICY In accordance with applicable laws and regulations, LYXOR INTERMEDIATION has introduced a broker and counterparty selection procedure to ensure the best possible execution of orders. These Entities are selected at an annual meeting of the validation Committee (the Validation Committee ) according to a voting process based on pre-defined, relevant and objective criteria. In order to meet their own regulatory obligations the Entities selected must offer the best possible execution when they deliver an investment service to LYXOR INTERMEDIATION and/or its clients. 2.1 Details regarding Entity selection The participants in the annual voting process leading to Entity selection are the following departments (hereinafter the members of the Validation Committee ), bearing in mind that one Validation Committee meeting will be held per client: Representatives of LYXOR INTERMEDIATION s trading desk; Representatives of LYXOR ASSET MANAGEMENT support teams (Operations) to which the trades were outsourced; Representatives of the client in question; LYXOR INTERMEDIATION s Head of Compliance for Investment Services (hereinafter the RC ). After the annual voting process, the Members of the Validation Committee define the list of authorized Entities (the List ) listed by class of instrument and by client. 2.2 Entity selection criteria The criteria considered when selecting Entities include the following: The brokerage fees and prices offered compared with market benchmarks; The quality of the trading information and the related tools; Execution quality-access to places of listing and other execution venues algorithms available; Quality of business relations and the market information provided; Quality of the Settlement/delivery of operations; Confirmation receipt time. The RC, who is also the Chief Risk Officer of LYXOR INTERMEDIATION, updates the list of criteria above in order to select and evaluate potential Entities. 2.3 Changes to the List of Entities during the year LYXOR INERMEDIATION is responsible for global relations with the Entities selected and may decide to make the changes described below during the year: 2 2

3 Removal of one or more Entities from the List during the year: the RC may decide to impose a ban on working with one of the Entities in serious circumstances including, but not limited to, a risk of default, disciplinary action or withdrawal affecting the Entity in question. Any Entity may also be removed from the list at any time if a serious event occurs, on the suggestion of a member of the Validation Committee and after validation by the RC; Accreditation of a new Entity otherwise that by the Validation Committee: any request for the accreditation of a new Entity by LYXOR INTERMEDIATION is subject to prior (i) notification of the client in question for their approval and (ii) validation at an exceptional Validation Committee meeting attended by the Members of the Validation Committee may be annual/global or more limited (for specific period of time or number of orders, for example). 2.4 Monitoring and re-examination of the selection policy LYXOR INERMEDIATION regularly monitors the effectiveness of this selection policy and particularly the execution quality of the Entities selected under this policy. LYXOR INTERMEDIATION will rectify any failings noted and re-examine the selection policy where appropriate. Any major changes to the conditions offered by one or more selected Entities (such as substantial changes to the prices applied, a sudden deterioration in the execution arrangements, and especially a reduction in the range of instruments handled, loss of access to an electronic platform, restructuring that may entail major operational risks, changes in the systems/tools used, etc,..) may result in the re-examination of his selection policy if this change affects LYXOR INTERMEDIATION s ability to achieve the best possible result for its clients. If no internal or external events occur that require the re-examination of LYXOR INTERMEDIATION s selection policy during the year, the policy is reviewed at annual Validation Committee meetings. If changes are made to LYXOR INTERMEDIATION s selection policy, the updated version will be published on the website which will be equivalent to LYXOR INTERMEDIATION informing its clients of these changes. 3. VENUES SELECTION POLICY Abiding by the laws and rules in force, LYXOR INTERMEDIATION takes all sufficient measures to ensure the best selection of Execution venue (hereinafter Venue ). The selection process is part of the best execution process. According to the law in force, the Venue encompasses the Regulated Markets (RMs) (e.g. the London Stock Exchange, Nyse Euronext, etc.), Multilateral Trading Facilities (MTFs), Organized Trading Facilities (OTFs), Systematic Internalisers (s) that execute orders otherwise than on RMs, MTF, or OTFs by acting directly as the counterparty and using their own equity. For avoidance of doubt, LYXOR INTERMEDIATION is not a member of any venue or other Regulated Market, 3 3

4 and is not. LYXOR INTERMEDIATION will select in priority the RM where the security on which an order had been placed, is listed. The security of the transaction and the settlement are viewed as the main selection criterion. The factors used in the Venue selection process are detailed per asset classes and described in the table in part 4 below Best Execution Policy (see details in column labeled Venue Selection Factors/Criteria ). Apart from the venues listed above, LYXOR INTERMEDIATION may use liquidity providers, such as for example, but not limited to, Market-Makers, notably when ETFs shares are concerned. It is noteworthy to stress that due to the nature of certain financial instrument, the nature of the order or the client s requirement, LYXOR INTERMEDIATION may meet cases where the order may be executed on one venue only. In such cases, the venue selection policy will not apply. 3.1 Orders not executed on a RM or a MTF When the interest of its clients is at stake, LYXOR INTERMEDIATION may decide not to route an order to a RM or a MTF. Before the decision comes into force, LYXOR INTERMEDIATION informs its clients of the decision and must obtain their prior approval either in a general frame or when the order concerned is placed. Clients expressly authorize LYXOR INTERMEDIATION to execute orders elsewhere that on Regulated Market or Multilateral Trading Facility. Clients may withdraw this authorization at any time, however, on either a temporary or permanent basis. Routing order out of a RM, a MTF or an OTF is driven by the interest of the clients, enhances the flexibility and the capacity to execute the order, but increases the counterparty risk. 3.2 RM or MTF selection process In the pursuance of client best interest, LYXOR INTERMEDIATION may decide to modify the list of selected Venues. The selection process takes into account: the published prices, the depth of liquidity-size (Bid/Ask volumes registered in the order book), the market volatility, the execution delay, the costs, the quality of the settlement-delivery of the securities. When LYXOR INTERMEDIATION routes an order to a broker, the Venue selection is processed by the said broker under its own selection rules and responsibility. As required by MIFID2, LXYOR INTERMEDIATION will report on an annual basis the result of this selection process and assessment, and will report it in the dedicated report as required by the Directive and its supplementing regulation (2017/576). The information published by the Venues under report MIFID2 supplementing regulation (2017/575) as public information, will be used for the assessment made by Lyxor Intermediation under regulation 2017/576. This report will encompass the 5 main Venues (execution) and / or Entities (reception and transmission) used by LYXOR INTERMEDIATION during the previous year. Once completed, the report will be posted on LYXOR INTERMEDIATION s website. 4 4

5 3.3 Fees paid by the Venue When selecting an Execution Venue, LYXOR INTERMEDIATION receives neither any retrocession, nor any form of inducement paid by the selected Venue. This grants that the selection process conducted by LYXOR INTERMEDIATION is carried out on an independent basis. 3.4 Re-examination of the Venue Selection policy The Venue selection policy is examined on a yearly basis and updated by the RC if needed. The list of selected Venues is reviewed annually by the Validation Committee which comprises: Representatives of LYXOR INTERMEDIATION s trading desk; LYXOR INTERMEDIATION s RC. The RC updates the list of factors/criteria in order to select and evaluate the Venues. 4. BEST EXECUTION POLICY This best execution policy applies to all the financial instruments referred to by Article L of the French Monetary and Financial Code and handled by the Entities selected by LYOR INTERMEDIATION. In accordance with Article L I of the French Monetary and Financial Code, LYXOR INTERMEDIATION takes all sufficient measures to achieve the best possible result for its clients when executing orders. 4.1 Execution criteria In terms of execution criteria, LYXOR INERMEDIATION looks at the execution price, together with the total cost of the transaction, execution speed, likelihood of execution, settlement and the size and specific nature of the order received. The relative importance of these criteria (and of any additional criteria added will depend on the client s characteristics of the order received, and the type of financial instrument involved. Execution matrix by order type The main order types and the associated execution criteria are described in the table below: ORDER TYPE TARGET PRICE OR BENCHMARK EXECUTION CRITERIA Conditional AVWAP (average volume-weighted asset price) or Price - Liquidity other strategy At the market Entry price (last price quoted) Speed Liquidity Limit Limit Liquidity - Costs Discretionary Entry price (last price quoted) Price - Liquidity Market on opening Market on opening Liquidity - Costs Market on close Market on close Liquidity - Costs 5 5

6 If specific instructions are transmitted by a client when they place an order, they should note that this releases LYXOR INERMEDIATION from the sufficient efforts obligation arising from the application of this execution policy. If a client s instruction only covers one part or one aspect of the order, LYXOR INTERMEDIATION must meet its best execution obligation for the part of the order not covered by the instruction. In accordance with Article L of the French Monetary and Financial Code, the execution is not intended to apply for the benefit of eligible counterparties. Execution matrix by class of financial instrument Thanks to its selection policy (see paragraph 2.2 above), LYXOR INTERMEDIATION has access to all the places of listing are likely to provide the best execution orders. In order to guarantee that it is offered the best execution conditions, LYXOR INTERMEDIATION may execute orders through Regulated Markets (RMs), Multilateral Trading Facilities (MTFs), Organized Trading Facilities (OTFs), Systematic Internalisers (s). Depending on the order s characteristics and the financial instruments involved, LYXOR INTERMEDIATION may use the tools made available to it by the selected Entities, such as Direct market Access (DMA), which allow the Entry of orders for their execution on one or more RMs, MTFs or OTFs. LYXOR INTERMEDIATION may otherwise decide to transmit an order to a selected Entity so that it can undergo conventional execution on the market in question (CARE). Clients expressly authorize LYXOR INTERMEDIATION to execute orders elsewhere that on Regulated Market or Multilateral Trading Facility. Clients may withdraw this authorization at any time, however, on either a temporary or permanent basis. 6 6

7 The execution venue according to the types of financial instruments, and the strategy and criteria adopted by LYXOR INTERMEDIATION in order to achieve the best execution for its clients, are described in the table below: FINANCIAL INSTRUMENTS AND INFORMATION ABOUT THE EXPECTED TYPE OF EXECUTION (WHER APPROPRIATE) EXECUTION VENUES VENUES SELECTION FACTORS/CRITERIA STRATGY ADOPTED TO ACHIEVE BEST EXECUTION OF ORDERS BEST EXECUTION FACTORS/CRITERIA Money market instruments related derivatives Interest swaps rate Futures contracts Interest rate Futures MR, OTC RM Equity securities, ETFs, commodities and related derivatives Counterparties are selected according to their ability to regularly publish prices. For liquid instruments he costs will be the main selection criterion. For less liquid instruments, access to liquidity will also be taken into consideration. It will be either more efficient to trade the desired products through DMA or to call on the specific expertise of Futures brokers, depending on the liquidity of the product involved. Costs/Response time/number of Flexibility Liquidity/final price Shares RM,, Primary Market No applicable criteria Request in the form of conventional orders (VWAP, TWAP, POV, at-the-market order, market-on-opening order or market-on-close order) relating to a given share are transmitted to intermediaries selected for the diversity of their algorithms and their access to liquidity (access to Liquidity can also be achieved through DMA). If the order relates to a basket of shares, it is either (i) transmitted to intermediaries that have the right coverage using the best selection procedure (margin, coverage, STP, quality of settlement) or (ii) executed OTC if the counterparty selected provides lower execution cost (case of baskets underlying a Costs/Liquidity/Diversity of algorithms/speed/ Quality of settlementdelivery 7 7

8 Futures contracts Index Futures Futures contracts Equity Futures RM RM derivative entered into with this same counterparty, for example). New issued shares may be bought directly from the issuer (on the primary market). Execution through DMA may be preferred for liquid Futures contracts. Futures contracts whose markets are more difficult to access (e.g. specific market or time zone) may be entrusted to intermediaries selected for their access to and knowledge of the market in question, for the diversity of their algorithms and for their execution costs. Intermediaries are selected for their ability to publish prices regularly, the speed of their responses to requests, their execution flexibility and the number of counterparties with which they work. Costs/Market access/diversity of algorithms Price/Costs/Response time/number of Flexibility Warrants, Rights, Certificates, CFDs ETFs (all types of underlying assets) Units or shares in undertakings for collective RM RM, OTC Primary Market OTC, No applicable criteria Depending on the liquidity of the instruments involved, either DMA will be possible (typically options in the money) or LYXOR INERMEDIATION will work with intermediaries selected for their knowledge of the market and their ability to publish prices and provide adequate liquidity. Intermediaries are selected for (i) their knowledge of the market, (ii) their ability to find liquidity for these products, competitive costs and counterparties likely to ensure an alignment of interests and (iii) the speed with which they provide execution prices (order to be executed at NAV). For size above an appropriate threshold, quotes will be requested from intermediaries (RFQs) to allow selection of the least costly execution method in terms of overall cost and h price impact. For Primary market, trades relating o a fund, the most efficient form of execution will Price/Costs/Response time/number of Flexibility Price impact (vs. inav) where relevant/fees/quality of settlementdelivery/number of counterparties Quality of settlementdelivery/ability to find a counterparty on the 8 8

9 investment Derivatives relating to his type of underlying (Exchange for Physical, Synthetic Total Return Swap, Options, etc.) Primary Market RM, OTC MTF, No applicable Debt securities and related derivatives Government bonds (OATs French treasury bonds, supranational, sovereign and agency bonds, covered bonds, treasury bonds, etc.) issued by developed countries and/or corporate bonds Inflation-linked, convertible exchangeable bonds MTF, OTF MTF, OTF criteria be provided through an automated and reliable connection to centralizing agents and depositories. For trades on the secondary market (such as exchanges of closed-ended fund units), best execution will consists of the ability to find a counterparty and ensure that the transfer of ownership takes place smoothly. Intermediaries/counterparties are selected for their ability to publish prices regularly, the speed of their responses to requests, the quality of the relevant contractuel documentation, their execution flexibility and the number of counterparties with which they work. Quotes are requested from counterparties (RFQs) to get the best prices. For liquid financial instruments the costs will be the main selection criterion. For less liquid financial instruments, access to liquidity will also be taken into consideration. Electronic RFQs will be preferred on liquid markets. If an order relates to as basket of bonds, the best counterparty will be selected based on its ability to deliver the whole basket at best price. Quotes are requested from counterparties (RFQs) to get the best prices. For liquid financial instruments the costs will be the main selection criterion. For less liquid financial instruments, access to liquidity will also be taken into consideration. secondary market Price /Quality of settlementdelivery/number of Flexibility/Response time Price /Ability to deliver bonds/quality of settlement-delivery Price /Ability to deliver bonds/quality of settlement-delivery 9 9

10 Derivatives relating to this type of underlying Synthetic Total Return Swaps RM, OTF MTF, Currencies and related derivatives Spot contracts, Forwards contracts, NDFs and swaps Other derivatives Other eligible financial contracts MTF, OTC RM, OTC MTF, Intermediaries/counterparties are selected for their ability to publish prices regularly, the speed of their response, the quality of the related contractual documentation, their execution flexibility and the number of counterparties with which they work. Best execution will either be delegated to a counterparty that publishes its prices on the market, o will be achieved by requesting quotes from various counterparties for fixing orders (WM Reuters, ECB Rate, etc.) Intermediaries/counterparties are selected for their ability to publish prices regularly, the speed of their response, the quality of the related contractual documentation, their execution flexibility and the number of counterparties with which they work. Price /Number of Flexibility/Response time/quality of settlement-delivery Price/Costs/Liquidity Price /Number of Flexibility/Response time/quality of settlement-delivery The list of venues and brokers / liquidity providers used by LYXOR INTERMEDIATION is published in the annual report in annex of the present policy. 4.2 Order transmission methods Clients mainly use the Oder Management System (OMX hereinafter OMX ) developed by Lyxor Asset Management and maintained by LYXOR INTERMEDIATION to transmit their orders to LYXOR INERMEDIATION and guarantee their audit trail. If the OMX meets disruptions and becomes unavailable, LYXOR INTERMEDIATION will inform its clients of the system s unavailability and the substitute arrangements made in accordance with the current Business Continuity Plan. 4.3 Reports and declarations Execution reports are incorporated within the OMX once order execution is completed and are immediately made available to Lyxor Asset management s Operations department, which checks the transaction confirmation issued by the selected Entity

11 4.4 Orders partially executed In any case where orders sent by different clients, pre-allocated and formally aggregated are partially executed, LYXOR INTERMEDIATION, in application of the regulation in force, allocates the executed quantities under the pro-rata rule based on the quantity of the pre-allocated orders formerly placed by the clients, taking into account the minimum quantity / amount / number of shares or minimum holdings constraints, if any. 4.5 Re-examination of the execution policy LYXOR INTERMEDAITION s execution policy is reviewed at annual Validation Committee meetings (see section 2.1. above). This review is formally documented through minutes of these Validation Committee meetings. LYXOR INTERMEDIATION considers the factors and criteria below when it re-examines its order execution condition and arrangements: - Order execution price; - Total transaction cost; - Execution speed and likelihood of execution; - Settlement/delivery; - Quality of the documentation for derivatives; - Intra-period events; - Controls performed at level 1 and 2 (permanent supervision). The execution policy may be revised at any time as a result of substantial changes or internal or external events (significant market incidents, substantial changes in costs, change in scope of the financial instruments handled, major changes to existing arrangements, etc.) affecting LYXOR INTERNATIONAL s ability to continue consistently achieving the best possible result when executing its clients orders by using the execution venues described above. If changes are made, the updated version will be directly accessible on the internet and will be equivalent to LYXOR INTERMEDIATION informing its clients of these changes