Legg Mason Australian Equities. Broker Management Summary of Policies & Practices

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1 Legg Mason Australian Equities Broker Management Summary of Policies & Practices May 2013 Legg Mason Australian Equities Broker Management Policies & Procedures 1

2 A PURPOSE OF THIS DOCUMENT Legg Mason Asset Management Australia Limited ( LMAMAL ) provides asset management services to a wide range of unit trusts and discretely managed portfolios across asset classes and sectors. LMAMAL Australian equities team, Legg Mason Australian Equities ( LMAE ) directly manages portfolios investing in securities listed on the Australian Stock Exchange. This document summarizes LMAE s policies & practices for: Appointing & dealings with brokers; and using broker commission flows generated from its trading activity on behalf of its clients to pay for research and other products and services. LMAMAL has appointed separate Legg Mason Inc affiliated fund managers to manage assets of other asset classes. Each of these affiliate manager s trading activities are governed by the affiliates' own broker management policies and procedures which are separate from the policies & process summarised in this document. B. DEALING WITH BROKERS For the purposes of this policy; Broker refers to an agent who handles the orders of clients to purchase and sell equities, or other listed securities. The provision of this service attracts brokerage and/or incurs a spread. Brokerage refers to the fee levied by the broker as their payment for executing trades and the provision of other services reasonably expected to assist in the provision of investment services, trading activity or making investment decisions. As an investment manager, LMAMAL has a fiduciary and statutory duty to act in the best interests of its clients in respect of investment decisions made on the client s behalf. Therefore in respect of trading: The LMAE team should always seek to obtain best execution irrespective of any other brokerage arrangements (whether full broker services or Alternative Brokerage Arrangements) entered into; and No client should be expected to be disadvantaged by any Alternative Brokerage Arrangements (and should be informed with respect of material aspects of such arrangements. To ensure that LMAMAL meets these duties, LMAE s dealings with brokers follow the processes below: 1. Trade Execution Process Roles and Responsibilities Portfolio managers are responsible for making investment decisions and originating trade orders, Trades are then executed by LMAE s separate dealing function. Legg Mason Australian Equities Broker Management Policies & Procedures 2

3 2. Broker selection and ongoing review a) Approval Process: Due diligence reviews are undertaken on any proposed new broker which includes an assessment of the broker's capabilities, experience, resources, access to markets and distribution networks, financial standing as well as review of any legal documentation. Upon completion of the due diligence process the proposed new broker is submitted to the LMAE Broker Committee. All approved brokers, are formally reviewed on at least an annual by the Committee. b) Best Execution While LMAE strives to ensure that all investment instructions are executed in a timely manner, while fulfilling the practice of best execution, it is also imperative that all transactions are within the client execution guidelines and adhere to local trading procedures and guidelines. Best execution is achieved by ensuring that the LMAE s trader has access to all available market pricing information from a wide variety of sources and involves both quantitative and qualitative judgement. Legg Mason Australian Equities Broker Management Policies & Procedures 3

4 C. BROKERS SERVICES LMAE uses the two following arrangements to ensure both best execution and receipt of value add research or services: Full Broker Services Alternative Brokerage Arrangements 1. FULL BROKER SERVICES LMAE typically use full broker services arrangements. The goods or services acquired through such arrangements must be reasonably expected to assist in the provision of investment services, trading activity or making decisions to trade for those clients on behalf of whom brokerage is paid. Examples of broker produced goods and services that are directly linked with trading activity include: Trade execution; and In-house manager support services including broker research, information and services. Such services must be capable of adding value to investment or trading decisions by providing new insights that inform a portfolio manager or analyst when making investment decisions. 2 ALTERNATIVE BROKERAGE ARRANGEMENTS: THIRD PARTY GOODS & SERVICES Alternative brokerage arrangements involve the practice of directing client brokerage commission to a broker in return for third party goods and services ( Alternative Brokerage Arrangements ). I. Policy In relation to its LMAE business, LMAMAL will only enter into alternative brokerage arrangements with brokers for the provision of third party goods and services ( Alternative Brokerage Arrangements ) that are in accordance with Financial Services Council; Guidance No ( GN 10 ). LMAMAL will, in accordance with the following policies and procedures: (i) (ii) review and approve in writing each new Alternative Brokerage Arrangement, and periodically review all existing Alternative Brokerage Arrangement. LMAMAL always seek to obtain best execution, irrespective of any other Alternative Brokerage Arrangement they enter into. For the purposes of this policy Alternative Brokerage Arrangement includes arrangements between LMAMAL and brokers for the provision of any goods or services that are beyond goods and services produced and supplied by the broker and directly linked to trading activity. Legg Mason Australian Equities Broker Management Policies & Procedures 4

5 II. Procedures (1) Establishment of an Alternative Brokerage Arrangement LMAMAL may not enter into an Alternative Brokerage Arrangement unless the LMAE Broker Committee has approved it in advance after an evaluation of the proposed arrangement (2) Periodic Review No less frequently than once a year, the LMAE Broker Committee will review each existing Alternative Brokerage Arrangement and approve its continuance. (3) Factors to Consider when Establishing or Reviewing Alternative Brokerage Arrangements To approve the establishment or continuance of an Alternative Brokerage Arrangement, the LMAE Broker Committee must determine in good faith that: a. In accordance with GN 10, The goods or services acquired through such arrangements must be reasonably expected to assist in the provision of investment services, trading activity or making decisions to trade for those clients of the Investment Manager on behalf of whom brokerage is paid (see Section CIII below); b. The goods or service provides lawful and appropriate assistance in the performance of the investment decision-making or trade execution processes; and c. The amount of commissions paid is reasonable in light of the value of the product or service offered (see Section D, below). III. Acceptable Alternative Brokerage Arrangements Research Research refers to the production of information that is capable of adding value to investment or trading decisions by providing new insights that inform a portfolio manager or analyst when making investment decisions. Other Benefits Goods and services supplied by the Broker (whether produced or purchased by the Broker) that are not directly linked with trades and trade advice are unlikely to assist an Investment Manager in the provision of investment services, trading activity or making decisions to trade. Consequently GN 10 provides that goods and services acquired through such arrangements are not acceptable (See C(IV) below for examples). Legg Mason Australian Equities Broker Management Policies & Procedures 5

6 IV. Mixed-Use Items It is the policy of LMAMAL to permit the use of Alternative Brokerage Arrangements to obtain products or services that have components that are acceptable under GN 10 and components that are not eligible (mixed-use items). When obtaining such mixed-use items, only the acceptable portion shall be paid for using Alternative Brokerage Arrangements. The LMAE Broker Committee will regularly review the actual use of the product or service as part of its periodic review of the Alternative Brokerage Arrangements V. Disclosure (1) Annual disclosure should be on request made by LMAMAL to Investors in relation to its LMAE operations and should include: information on all Alternative Brokerage Arrangements information on the costs and, where applicable, the expected benefits of such arrangements: and a statement indicating whether the LMAMAL has complied with GN. 10 and if not, why not. (2) Where a significant change in LMAE s Alternative Brokerage Arrangements has occurred during the year, this will be disclosed to investors in the same way LMAMAL notifies Investors of other significant changes to investment practices. VI. Record keeping LMAMAL will maintain all appropriate records concerning brokerage arrangements transactions in relation to its LMAE operations.: Legg Mason Australian Equities Broker Management Policies & Procedures 6

7 D. REASONABLENESS OF COMMISSIONS In evaluating the full range and quality of a broker s services and determining the reasonableness of commissions charged, LMAMAL via the LMAE Broker Committee will consider the following factors: The execution capabilities of the broker (including ability to achieve best execution); The value of the research provided; The commission rates charged by the broker as compared to commission rates charged throughout the industry; Brokerage arrangements costs charged by other brokers for a similar product or service; and The financial responsibility of the broker and its responsiveness to LMAMAL. E. MANAGING CONFLICTS OF INTERESTS Potential conflicts that could arise from the acceptance of Alternative Brokerage Arrangements are: LMAMAL receiving a benefit to the detriment of its clients; and/or Specific clients receiving benefits to the detriment of other clients. LMAMAL has a number of key controls in place to prevent the above conflicts from arising including: Broker approval processes including setting broker limits and alternative brokerage commission caps. Independent from the LMAE's trading function, the LMAE Broker Subcommittee is responsible to ensure the correct clients benefit from the provision of goods and services through any Alternative Brokerage Arrangements; and Alternative Brokerage Arrangements are reviewed on a periodic basis by the LMAE Broker Committee Legg Mason Australian Equities Broker Management Policies & Procedures 7

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