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. Background The European Directive on Markets in Financial Instruments No. 2004/39/EC Of 21 April 2004 ( MiFID ) which came into force on 1 November 2007, establishes common standards of investor protection and strengthens the rules of good conduct that apply to financial intermediaries. The obligation to ensure best selection and best order execution is an essential component of MiFID. LAM complies with this obligation by implementing the policy described herein, which aims to ensure that the best financial intermediaries are selected and/or obtain the best possible result when executing orders on behalf of its clients, on the basis of the criteria specified below. This policy applies to all or all of the following LAM activities: - Collective portfolio management of UCITS and AIF; - Individual portfolio management; - Order reception and transmission ( ORT). 2. Best selection policy To ensure the best possible order execution, LAM has set up a procedure to select the best brokers and counterparties ( Entities ). These entities are selected in an annual voting process that is based upon predetermined, relevant and objective criteria. The objective of this process is to draw up a list of Entities that are capable of handling the volume of orders that LAM places and in accordance with the general and/or specific service requirements of its clients. Pursuant to their regulatory obligations, the Entities selected are obliged to provide the best possible execution when providing an investment service to LAM. The best selection policy applies to the following clients: - To UCITS and AIF that are managed by LAM when the managers of these funds place orders for execution with the Entities, except when LAM delegates asset management to a third-party; - To third-party UCITS and AIF that LAM manages under delegation, subject to any specific orders or instructions that may be provided to LAM by the lead manager of the UCITS/AIF or by the Board of Directors of the UCITS/AIF; - To LAM acting in his capacity as agent under an investment mandate.
2.1 Entity selection criteria The main criteria that are taken into account when selecting intermediaries are: Brokerage fees and the prices obtained in comparison with market leaders The trading information and trading tools The execution access to exchanges, markets and other execution venues algorithmic offerings The the business relationship and the market information provided The trade The speed of trade confirmation. LAM s Risk, Internal Control and Compliance department prepare and maintain the list of the criteria that are used to select and evaluate candidate Entities. The Entities are elected annually by the members of the Validation Committee, which is composed of representatives from the following functions and departments: Support functions (Operations) LAM s management department The Risk and Compliance departments The Internal Control department. When the annual voting process is completed, the members of the Validation Committee draw up the list of authorised Entities for each category of financial instrument (the List ). 2.2 Amendments to the List during the year Since LAM is responsible for the relationship with the selected Entities, it may make the following amendments to the List during the course of the year: Removal of a Entity from the List: The Internal Control, Risk and Compliance departments may, at any time, decide to prohibit work with an Entity in the event of a serious situation, such as (but not limited to) the risk that the Entity may default, be sanctioned or have its license withdrawn. An Entity may also be removed from the List during the year if a serious event is observed, on the proposal of a member of the Validation Committee with the prior approval of Compliance. Accreditation of a new Entity other than at the annual Validation Committee meeting: The department that requests approval of the Entity must first have the Entity approved by the Validation Committee at a special meeting attended by the aforementioned members. Accreditation may be annual, overall or more restricted (for example, in terms of duration or a specific number of orders). 2.3 Selection of Lyxor Intermediation Among the Entities selected by the Validation Committee, LAM has selected Lyxor Intermediation, a provider of investment services that has been approved by the Prudential Control and Resolution Authority ( the ACPR ) to provide order reception and transmission services and order execution for third parties. As an investment firm that provides order reception and transmission and order execution services, Lyxor
Intermediation has implemented its own best selection and best execution policy, which is available at www.lyxor.com. As indicated in Lyxor Intermediation s best selection and best execution policy, LAM and Lyxor Intermediation, at the proposal of either, may at any time review the terms and conditions, the Entities and the arrangements proposed to LAM in respect of Lyxor Intermediation s order reception, transmission and execution services. 2.4 Review of the best selection policy Any substantial change in the terms and conditions proposed by a selected Entity (such as a substantial change in the fees charged, a deterioration of the execution system (and in particular a decrease in the types of instruments handled, loss of access to an electronic platform, restructuring, or a modification of systems or tools) may trigger a review of LAM best selection policy. In the absence of internal or external events that may require that LAM s best selection policy be reviewed during the year, the policy will be reviewed annually by the Validation Committee. The results of this review are recorded in the Committee s meeting report. If the policy is modified, the revised policy will be made directly accessible to LAM s clients on the Internet, which will constitute valid notification. 3. Best execution policy This best execution policy applies to clients that are UCITS or AIF that are managed by LAM. It does not apply to UCITS or AIF for which LAM has delegated asset management. It applies to UCITS and AIF for which LAM is the delegated asset manager, subject to any specific orders or instructions that may be provided to LAM by the lead asset manager of the UCITS or AIF, or by the board of directors of the UCITS or AIF. Any instructions to LAM specified in the UCITS or AIF prospectus itself also have precedence over this policy. Lastly, this policy also applies to orders which LAM executes under individual investment mandates. LAM selects Entities to execute its orders, or those of its clients, pursuant to Articles 314-75 and 314-75-1 of the AMF s General Regulations. 3.1 Execution criteria In addition to the price of order execution, LAM s execution criteria include the overall cost of execution, the total cost of the trade, the speed of execution, and the likelihood of execution and settlement. The relative importance of these criteria (and the possible use of additional criteria) will depend on the types of orders received and the types of financial instruments involved.
3.1.2 LAM s execution criteria by order type and price benchmark The table below shows the main types of orders executed and their execution criteria. Order type PRICE TARGET OR BENCHMARK EXECUTION CRITERIA Staggered AVWAP (the average price weighted by trading Price - Liquidity discretionary (soignant) volume) or some other strategy Market order Entry price (last quote) Speed - Liquidity Limit order Limit price Liquidity - Costs Standard Entry price (last quote) Price- Liquidity discretionary Opening Opening price Liquidity Costs Closing Closing price Liquidity Costs LAM s best selection policy (see above) gives it access to all trading venues that are capable of offering best order execution, and via Lyxor Intermediation whenever possible. When orders are placed with Lyxor Intermediation, LAM has continuous access to all information concerning the orders that Lyxor Intermediation executes. This enables LAM to verify, if necessary, that the services provided by Lyxor Intermediation are appropriate and that it observes the execution policy. The execution criteria that Lyxor Intermediation observes for each type of order is indicated in its best execution policy, which is available at www.lyxor.com. If a client provides specific instructions when placing an order, that client is informed that this discharges LAM from its best efforts obligation under its execution policy. When a client s instruction applies to only one part or aspect of its order, LAM s best execution obligation will apply to only the part of the order that is not covered by the client s instruction. This rule also applies to any specific instructions that LAM gives to Lyxor Intermediation. The client expressly authorises LAM and Lyxor Intermediation to execute orders other than on a Regulated Market or on a Multilateral Trading Facility. However, the client may revoke this authorisation at any time, either temporarily or permanently. This policy applies to LAM s professional and non-professional clients and does not apply to eligible counterparties. 3.1.3 LAM s execution criteria by type of financial instrument Financial instruments and type of execution expected (when applicable) Money market instruments and their derivatives Execution venue Best execution strategy Best execution criteria / factors
Interest rate swaps OTC Counterparties are selected on the basis of their capacity to regularly show prices. For liquid instruments cost will be the main selection criterion. For less liquid instruments access to liquidity will also be taken into consideration. Interest rate futures RM Depending on the liquidity of these instruments, it may be more efficient to trade them via DMA or through a futures broker cost / responsiveness / number of liquidity / final price Equity securities, ETF, commodities and their derivatives Equities RM, SI, OTC Orders that are for a specific security and is of a conventional type (i.e. VWAP, TWAP, POV, Market, Open or Close) will be sent to intermediaries that are selected in particular for the diversity of their algorithms and their access to liquidity, which may also be obtained through DMA. Cost / liquidity / algorithm diversity / speed / When an order involves a basket of securities, it is either (1) sent to intermediaries that offer good coverage in accordance with the best selection procedure (in terms of margin, STP and settlement quality), or (2) traded OTC when the selected counterparty provides free execution (e.g. for a basket of equities underlying a derivative transaction entered into with this counterparty). Index futures RM DMA execution may be selected for liquid futures. Futures that cannot be accessed as easily (due to their market or time zone) may be handled by intermediaries selected on the basis of their access to and knowledge of the relevant market, the diversity of their cost / market access / algorithm diversity
algorithms and execution costs. Equity futures RM Intermediaries are selected on the basis of their capacity to regularly show prices, their responsiveness to requests, the flexibility of their execution and the number of counterparties with which they work. price / number of responsiveness Warrants, Certificates and CFD Rights, RM Depending on the liquidity of the instruments traded, DMA will be possible (typically for options that are near the money) or the desk will use intermediaries selected for their knowledge of this market and their capacity to show firm prices and provide sufficient liquidity. price / number of responsiveness ETF (all types of underlyings) RM, SI, OTC and Primary Market Intermediaries are selected (1) for their knowledge of this market, (2) their capacity to find liquidity for these products, competitive prices and counterparties with complementary interests, and (3) their responsiveness in providing the execution price (NAV). impact on price (vs. inav) (if relevant) / fees / / number of counterparties For orders that exceed an appropriate threshold the selected intermediaries will be asked to provide an RFQ in order to select the least costly execution, in terms of direct costs and impact on price. Shares or units in investment funds OTC, Primary Market When executing trades on the primary market, a reliable automated link with depositaries and transfer agents will ensure the most efficient execution. For secondary market trades (e.g. involving shares or units in a closed fund), best execution depends on the ability to find a counterparty and ensure, and the capacity to find a counterparty in the secondary market
that title to the shares or units is properly transferred. Derivatives on this underlying (exchange for physical, synthetic total return swaps, options, etc.) Debt securities and associated derivatives RM, OTC Intermediaries/counterparties are selected for their capacity to regularly show prices, their responsiveness to requests, the their contractual documents, the flexibility of their execution and the number of counterparties with which they work. price / number of responsiveness / Emerging and developed market government bonds (OAT, supranational, sovereign, covered and T- bills) and/or corporate bonds OTC Counterparties will be asked to respond to an RFQ so that the best price may be selected. Cost will be the main selection criterion for liquid instruments. For less liquid instruments access to liquidity will also be taken into consideration. Online bidding will be the preferred method in liquid markets. price / capacity to deliver bonds / When an order is for a basket of bonds, the best counterparty will be selected for its capacity to deliver the entire basket at the best price. Inflation-linked convertible exchangeable bonds bonds, bonds, OTC Counterparties will be asked to respond to an RFQ so that the best price may be selected. Cost will be the main selection criterion for liquid instruments. For less liquid instruments access to liquidity will also be taken into consideration. price / capacity to bonds / Derivatives on the above underlyings, including synthetic total return swaps Forex and associated derivatives OTC Intermediaries/counterparties are selected for their capacity to regularly show prices, their responsiveness to requests, the their contractual documents, the flexibility of their execution and the number of counterparties with which they work. price / number of responsiveness / Quality of
Spot, Forward and Swaps OTC Best execution will either be delegated to a counterparty that ensures transparency with these markets, or will be obtained by seeking bids from counterparties for fixing orders (WM Reuters, ECB Rate) price / cost / liquidity Other derivatives Other eligible financial contracts Efficient portfolio management techniques RM, OTC Intermediaries/counterparties are selected for their capacity to regularly show prices, their responsiveness to requests, the their contractual documents, the flexibility of their execution and the number of counterparties with which they work. price / number of responsiveness / Repos, reverse repos and other securities financing transactions OTC Counterparties are selected on the basis of their price and responsiveness. The documentation and of eligible collateral, and the counterparty s flexibility if adjustment is necessary are also taken into consideration. price / RM: A regulated market (e.g. the London Stock Exchange or NYSE Euronext). SI: A systematic internaliser, which executes client orders outside of a RM or MTF by using its own capital to act as a direct counterparty. DMA: Direct Market Access, using tools provided by a broker that enable orders to be placed for execution on one or more RM, MTF or OTF. 3.1.4 Use of Société Générale as a counterparty LAM may select Société Générale (Paris) to be a counterparty for OTC derivatives.
In addition to the minimum annual verifications and the independent valuation that LAM performs on each over-the-counter financial instrument, the competitiveness of Société Générale s terms and conditions is generally checked by conducting calls for tenders or issuing requests for quotes (RFQ). When competitive bidding or RFQ are not initially possible (e.g. for financial contracts that are based on a proprietary SG strategy or which involve a relatively small nominal amount), LAM will compare the price proposed by the counterparty with its own independent valuation. If the difference between the two exceeds a specified threshold, LAM will abandon the transaction or will issue an RFQ. In the event that LAM selects another counterparty than Société Générale for an OTC derivative transaction, mainly for reasons of operational simplicity, LAM may use Société Générale services in a back-to-back arrangement. In such a case, LAM will first enter into the transaction with Société Générale, which will then enter into a similar transaction with the counterparty that LAM has selected, under the terms that LAM has specified. Lastly, for certain UCITS, AIF or investment mandates, LAM may ask Société Générale to make a contractual commitment to take all reasonable steps when executing orders to ensure the best possible result for LAM, its clients or the UCITS/AIF, pursuant to Article L.533-18 of the French monetary and financial code. 3.2 Order transmission To send their orders to LAM and ensure their traceability, LAM fund managers and clients mainly use the Order Management System ( OMX ) developed by Lyxor. If this order transmission system ceases to function correctly for some reason, LAM will inform everyone affected by this of this situation and of the alternate means that will be used in accordance with the Business Continuity Plan in effect. 3.3 Reports and confirmations Execution information is entered in the OMX order transmission system when the order is completed and is immediately made available to Lyxor s Operations department, which will check the trade confirmation issued by the broker or counterparty. Lyxor Intermediation will also send LAM periodic reports with the following statistics for each type of financial instrument: * the volume of orders traded over the relevant period during the current year * the number of trades executed by brokers * the amount of fees on equity trades paid to each broker. 3.4 Review of the execution policy Except for major events that require review during the year, LAM s execution policy is reviewed annually by the Validation Committee (see section 2.1 above). The result of this review is recorded in the Committee s meeting report.
When LAM reviews order execution terms, conditions and systems, it pays particular attention to the following information and factors: - The scope of the financial instruments covered by the execution policy - Access to platforms and other execution venues - Execution strategy - Voting participants - Voting criteria - Events during the relevant period - 1 st and 2 nd level controls If the policy is modified, the revised policy will be made directly accessible to LAM s clients on the Internet, which will constitute valid notification.