Order Execution Policy

Transcription

1 Glbal Markets Order Executin Plicy State Street Bank Internatinal GmbH, Frankfurt branch State Street Bank Internatinal GmbH, Frankfurt branch ( SSB Intl. GmbH Frankfurt branch ) prvides the fllwing investment services t its clients under the Markets in Financial Instruments Directive ( MiFID ): Executin f rders n behalf f clients in investment fund units (Agent Fund Trading/AFT) Receptin and transmissin f rders in relatin t freign currency derivatives fr executin t State Street Bank and Trust Cmpany, Lndn branch ( SSBTC Lndn branch ) (Freign Exchange/FX) When executing r transmitting yur rder(s) we take all reasnable steps t prvide yu with the best pssible result n a cnsistent basis by taking int accunt any specific instructins 1 we receive frm yu and a range f executin factrs in accrdance with the principles described in this Order Executin Plicy ( Plicy ). Depending n yur requirements, SSB Intl. GmbH Frankfurt branch can als pass rders in relatin t freign currency derivatives fr executin t State Street Bank Internatinal GmbH, Lndn branch ( SSB Intl. GmbH Lndn branch ). These rders are cvered by the separate dcument Order Executin Plicy State Street Bank Internatinal GmbH, Lndn branch and are nt part f this Plicy. 1. Scpe This Plicy nly applies where we have categrised yu as a Prfessinal client and we yu a cntractual r agency bligatin. The duty t prvide best executin des nt apply t transactins invlving Eligible cunterparties and therefre where we have categrised yu as such in respect f such business this Plicy will nt apply; specific transactins and services are identified in sectin 6 belw. SSB Intl. GmbH Frankfurt branch des nt deal with retail clients. 1 See Sectin 4 belw. Page 1

2 2. Executin factrs When executing and/r transmitting yur rders we will take int accunt different executin factrs including, but nt limited t: Price; Csts; Speed; Likelihd f executin; Likelihd and reliability f settlement; Size; Nature f an rder; and Other relevant cnsideratins, such as: Liquidity (relative rder size r financial instruments underlying liquidity); Market Impact; Nature f the available executin venue (regulated versus unregulated market venue);and Nature f the financial instrument. Our emplyees use their experience and judgment t determine the imprtance f each f these factrs n a case by case basis t assist in achieving f the best pssible result n a cnsistent basis in respect f yur rders. 3. Executin criteria In determining the relative imprtance f the executin factrs, when we are executing and/r transmitting rders n yur behalf, we will take int accunt the fllwing executin criteria: The extent t which we believe yu are relying upn us t prvide yu with the best pssible result; The characteristics f yur rder(s); The characteristics f the financial instrument; The characteristics f the available executin venues; and If yur rder is subject t any specific instructins that yu have given us. Page 2

3 4. Specific client instructins Whenever yu have given us a specific instructin regarding an rder r an aspect f an rder, we will execute r transmit such rder r aspect theref fllwing yur specific instructin. We will then apply this Plicy and take reasnable steps t btain the best pssible result fr the elements f the rder nt subject t r limited by yur instructins. In the event that we feel that yur instructins may have becme unduly limiting t the executin f yur rder, such as where market cnditins have changed, we wuld aim t discuss this with yu and agree a suitable curse f actin. 5. Relative imprtance f the executin factrs While price is generally a key factr, the verall value t a client f a particular transactin may be affected by the ther factrs listed abve. The relative imprtance f each f the factrs will differ depending n: The characteristics f yur rder; The characteristics f the financial instruments t which the rder relates, as certain instruments are easier t execute than thers; The characteristics f the executin venue(s) t which we are able t direct and execute yur rder and the cnditins fr safe settlement assciated with thse venues; and, Cnsideratin f ptential market impact, taking int accunt any instructins yu might give us n participatin levels and having analysed the liquidity and relative size f the rder. 6. Asset-class specific arrangements a) Agent Fund Trading (AFT) Fund rders are executed n behalf f clients thrugh SSB Intl. GmbH Frankfurt branch and are nt placed n any German r internatinal stck exchange fr executin, but always with the investment manager issuing the fund units r with the respective Transfer Agent r with the respective custdian. Cnsequently, the executin venue is pre-determined by the rdered fund. All transactins are cnsidered Over-The- Cunter (OTC). Page 3

4 b) Freign Exchange (FX) SSBTC Lndn branch executes all f yur Direct FX rders in freign exchange derivatives n an OTC basis acting as a principal t the trade fllwing a request frm yu fr a qute ( Request fr Qute r RFQ ). Yu will cntact a SSB Intl. GmbH Frankfurt branch Sales Trader. Upn receiving an RFQ frm yu, and where yu are bth a prfessinal client and we reasnably believe that yu are relying upn us t prvide the best pssible result r yu have made us aware at the utset that yu are relying upn us t this effect, ur Sales Trader will seek a price frm ne f ur SSBTC Lndn branch Traders by prviding them with relevant infrmatin abut yur rder (i.e. type f cntract, currency pair, ntinal and maturity). The price prvided by the SSBTC Lndn branch Trader will be based upn their assessment f the market in that currency pair at the time and cnsideratins arund SSBTC Lndn branch market and cunterparty risk. Our Sales Trader will give yu the pprtunity t accept r reject the price ffered, hwever precise details f pricing remain prprietary t SSBTC Lndn branch in rder t permit SSBTC Lndn branch t manage their market risk. If yu accept the prpsed price, yur Sales Trader will transmit yur rder fr executin t SSBTC Lndn branch. SSBTC Lndn will then execute the FX transactin as principal. Finally, in respect f any rders in freign exchange which d nt cnstitute a financial instrument (i.e. spt cntracts and certain frward cntracts), the bligatin fr best executin under MiFID des nt apply and therefre this Plicy will nt be applicable. 7. Other imprtant matters a. General Infrmatin Please be infrmed that rights f the investr might change, in case f nn-german respectively freign funds, which are nt nminated fr the distributin t the public fr the German market, due t the applicable lcal law in the apprpriate nn EU member states. This especially applies t funds with ISINs f nn EU member states fr e.g. CH Switzerland, BH - Bahamas, SI Singapre etc. b. Order aggregatin and allcatin When executing and/r transmitting yur rders we may cmbine yur rders with thse f ther clients f SSB Intl. GmbH Frankfurt branch, which may include affiliated cmpanies. We will nly d this where we reasnably believe that it is in the verall best interest f each client. Page 4

5 8. Mnitring and versight SSB Intl. GmbH Frankfurt branch clsely mnitrs the effectiveness and perfrmance f its executin arrangements and delivery f best executin t its clients in respect f this Plicy. In additin t frnt-ffice mnitring, the cmpliance department cnducts regular independent mnitring and challenges findings and utcmes when required thrugh the curse f their prgram. 9. Prcedural arrangements This Plicy and ur rder executin arrangements are reviewed at least annually by the relevant departments, Cmpliance and senir management, but may be updated mre frequently when required, such as where we identify a material change which may affect ur ability t deliver best executin n a cnsistent basis. A current versin f this Plicy is made available t yu n the SSB Intl. GmbH Frankfurt branch website. Finally, yu may request that we demnstrate adherence t this Plicy in respect f any rder(s) we execute n yur behalf. Such requests shuld be made in writing and directed t: State Street Bank Internatinal GmbH Cmpliance Management Brienner Straße München Germany Effective date: August 2017 Legal ntices and disclaimer The prducts and services utlined herein are nly ffered t prfessinal clients r eligible cunterparties thrugh State Street Bank Internatinal GmbH, authrised by Deutsche Bundesbank and the German Financial Supervisry Authrity. This dcument and infrmatin prvided herein des nt cnstitute investment, legal, regulatry, tax r accunting advice and is nt a slicitatin t buy r sell securities nr t enter int any transactin, nr is it intended t cnstitute any binding cntractual arrangement r cmmitment by State Street Bank Internatinal GmbH t prvide securities services nr any ther financial services. Prspects, clients r cunterparties shuld be aware f the risks f participating in trading equities, fixed incme, and freign exchange instruments, derivative instruments and/r in investments in illiquid r emerging markets. Derivatives generally invlve leverage and are therefre mre vlatile than their underlying cash investments. Prspects, clients r cunterparties shuld be aware that prducts and services utlined may put their capital at risk. Further, past perfrmance is n guarantee f future results and, where applicable, returns may increase r decrease as a result f currency fluctuatins. This cmmunicatin is nt intended fr retail clients, nr fr distributin t, and may nt be relied upn by, any persn r entity in any jurisdictin r cuntry where such distributin r use wuld be cntrary t applicable law r regulatin. This cmmunicatin is nt intended t suggest r recmmend any investment r investment strategy and des nt cnstitute investment research. This publicatin r any prtin heref may nt be reprinted, sld r redistributed withut the prir written cnsent f State Street Bank Internatinal GmbH State Street Crpratin - All Rights Reserved Page 5