Designator author. Selection and Execution Policy

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1 Designator author Selection and Execution Policy

2 Contents 1. Context 2 2. Best selection and best execution policy Selection and evaluation of financial intermediaries Agreement by the Global Counterparty Committee Selection of counterparties Determination of an allocation objective Counterparties assessment Conflicts of interest Dealing Venues and Methods Direct Market Access Algorithmic trading Program Trading Brokers Principal Special cases Initial Public Offerings Less liquid products Abnormal market conditions Aggregation of orders Execution factors Price Nature and characteristics of the order Market liquidity Cost Credit Lines Securities lending Internal Crossing Best Execution and Selecting the Dealing Venue Size of the order Market intelligence Settlement Risk Conditions for reviewing the best execution policy Minimum frequency of review Responsibility for the review Terms of review Factors to be taken into account during the review Possible information on updates Selection policy of research services and investment support services Purchase of research Commission Sharing Agreements Commission unbundling Use of Soft Dollars to Obtain Research Services 12

3 1. Context This Policy, in accordance with regulations and the requirements of directives, regulations, legislation and fiduciary duties to our clients provides the framework of the review of the best selection and best execution, of the implemented controls as well as associated responsibilities (first level controls, compliance controls). The best selection and best execution policy is available to clients and is reviewed at least annually. It is enforceable since its publication to all entities 1 within BNPP IP, including BNP Paribas Fin AMS, or other authorised dealing entities that are concerned by requirements linked to best execution. In cases where local legislation or regulatory requirements conflict with, or are more stringent than this policy, those local requirements prevail. If requirements conflict with this policy, the local Compliance Officer should consult with the Head Global Compliance Policy. In the specific case of providing asset management services to third parties selection and best execution processes are in place within BNPP IP, linked to the generally observed practice. Indeed, asset management firms frequently use, for the execution of orders, financial intermediaries, brokers, that have to be selected according to their ability to provide the best execution for the orders received from their clients. Depending on the case direct or through counterparty execution portfolio managers are consequently bound to best selection or best execution obligations (except if a client has given specific instructions whereby there is a requirement to contractually opt out of best execution) except funds subscriptions and purchases. In addition, a component of our investment process places the emphasis on our ability to use high quality external research supplied by professional brokers and independent research providers. A three-step process results from above: A best execution (and best selection) policy A research services selection The implementation of controls monitoring the efficiency of the execution policy either directly implemented or based on services provided by selected third parties. It is worth noting that controls actually have three objectives or impacts: Making sure that the best execution policy is applied Promptly correcting observed failure Facilitating the annual review of the policy, and anticipating a review of this policy if there is a significant change likely to have an impact on the ability to obtain the best possible result for the client. The obligations of this selection and execution policy are owed to all our clients. 1 For the purpose of this document, the expression entity(ies) referring to BNPP IP will exclude BNP Paribas Fin AMS considering its specific activities. The expression entity(ies) referring to BNPP IP also excludes Joint Ventures not 100 % hold. 2

4 2. Best selection and best execution policy 2.1. Selection and evaluation of financial intermediaries The entities of BNPP IP have had a formal system for selecting intermediaries since 1998; it is based on their ability to provide services according to the traded instrument in question Agreement by the Global Counterparty Committee The agreement consists of establishing for BNPP IP entities an approved list of financial intermediaries for each type of financial instrument and for each portfolio management process. To be considered as part of the selection process, the counterparty has first to be agreed. The Brokers Relations Department is in charge of the brokerage agreements. The Global Counterparty Committee acts as the forum for discussing, deciding and acting upon commercial, operational, compliance, legal and risk issues related to eligible counterparties. This Committee is steered by the Head of Risk Control, in his absence by the Head of Compliance of the concerned entity. The Global Counterparty Committee is the only authority to decide on additions, removal and bans of counterparties and periodically reviews the counterparty performance on commercial, operational and risk considerations such as pricing, efficient trade processing or additional services to ensure our clients get the best result and execution. The Commission Sharing Agreement Committee also monitors commission sharing arrangements Selection of counterparties In this context, the selection of counterparties by each portfolio management team within the dealing activity is based on specific criteria which have been identified and/or set by the teams and/or approved by their managers as users. Therefore, criteria can differ from one investment process to another, depending on the importance given to execution quality, access to research and other services provided by intermediaries. Each portfolio management team has its own counterparties selection system, under appropriate and specific procedures written according to the principles mentioned in the present policy Determination of an allocation objective According to the instrument types and portfolio management processes, objectives of brokerage fees, volume or request for quotes can be granted on a calendar basis. The monitoring of these objectives is first level provided by the Brokers Relations Department, second level being provided by the head of the concerned fund management team. Such objectives could influence BNPP IP and dealing entities on transactions in respect of best execution. 3

5 Counterparties assessment A vote is organized at least once a year among the users. This vote plays an integral part in the professional responsibilities of each concerned employee: therefore, taking part is an obligation, showing rigour in the elaboration of the answers and making sure that qualitative comments are all the most precise and clear. Administrative processing for transactions with counterparties has been delegated to BPFS 2. This suggests both an operational management of new counterparties agreements and a monitoring by BPFS of the quality criteria of administrative processing for transactions provided by counterparties. In addition, dealing activity is partly delegated to dealing entities. In this context, the monitoring of execution quality with financial intermediaries suggests both an operational management of new counterparties agreements and a monitoring of the dealing entities quality criteria of execution defined and agreed with BNPP IP. Funds formerly managed by Fortis Investments will be gradually transferred during Conflicts of interest The portfolio management systems of BNPP IP entities require that transactions created by fund managers are allocated in advance of the trade execution. The tools used by the front office record the time of creation and execution of orders. BNPP IP entities trade allocation policy requires that transactions be allocated fairly among portfolios. In general, allocations must be consistent with weighting within the portfolio or such that all accounts receive a similar weighting within a transaction. An electronic trade rounding facility exists within the dealing system. Where orders are partially filled, allocations are made in accordance with the BNPP IP entities allocation policy, which requires allocations to be in compliance with regulatory rules and principles. Therefore, partially filled orders are generally allocated on a pro-rata basis, unless there are good reasons not to, for example using a prorata basis may result in an uneconomic allocation. In these cases, the proposed allocation, and the rationale for it must be recorded, and these allocations are subject to compliance review (if not subject to agreed automated methodology). Where authorised by the regulations, BNPP IP and dealing entities may deal with the affiliates of BNP Paribas or through an exchange where an affiliate has a presence. BNPP IP entities will ensure that it reports transactions with affiliate companies or similar conflicts of interest to its clients if necessary. The compliance department is able to analyse any trading through affiliate companies to ensure that the client has approved the use of affiliates. The employees of BNPP IP entities including BNP Paribas Fin AMS are not allowed to give or accept any gift or entertainment exceeding 230 without receiving the prior approval of the Compliance Department of their entity. This process is strictly controlled and the Compliance Department keeps a register of gifts or potential inducements Dealing Venues and Methods Wherever possible, BNPP IP entities mostly execute its equity and fixed income trades via a centralised dealing function within the BNPP Group. This is dependent upon any overriding instruction of the client. If specific 2 BNP Paribas Fund Services 4

6 instructions are received, it may prevent BNPP IP from following our execution policy and from taking the steps designed and implemented to obtain the best possible result for executing orders. It is BNPP IP entities policy to seek the most favourable execution and the best possible outcome for the client in line with this policy. The dealing desk operates independently from the fund managers. BNPP IP entities have the ability to use a variety of dealing venues and methods. This allows efficient dealing arrangements for a wide variety of trading circumstances that may reduce transaction costs, reduce operational risk resulting in lower chance of error or execution irregularities, and also enable trades to be executed quickly to take advantage of short lived market opportunities Direct Market Access Direct Market Access ( DMA ) refers to electronic facilities that allow buy side firms to benefit generally from a better cost for financial securities they may wish to buy or sell Algorithmic trading Algorithmic trading is the use of computer programs for entering trading orders with the computer algorithm deciding on certain aspects of the order such as the timing, price, or even the final quantity of the order. It can be used to divide up a large trade into several smaller trades in order to manage market impact, opportunity cost, and risk Program Trading Program Trading is used to trade a basket of stocks Brokers BNPP IP entities can use brokers to trade financial instruments where they may need, as an example, to be worked by a trader more carefully in the market. The brokers use their distribution networks to source the other side of the trade Principal BNPP IP entities can use counterparties who may use their own principal (i.e. their own capital or their own trading book) to form settlement to a trade Special cases Initial Public Offerings Initial Public Offerings ( IPOs ) and underwriting involve committing our clients to transactions where there is no guarantee of completion or of receiving a full allocation. Allocation of IPOs and underwriting by brokers is contingent on a number of factors. 5

7 Pursuit of IPO share allocations (placing business with particular brokers in the expectation that BNPP IP entity will receive favourable allocations in future issues) represents a clear conflict of interest. Therefore, BNPP IP entities never allow such considerations to influence its trading strategy. For US clients, trading IPOs through affiliate companies is not possible. Fund managers are required to obtain and complete the offer document ensuring that the allocation for the clients is determined in advance. Fund managers are not allowed to place speculative IPO orders that would breach the investment guidelines if the whole application were granted. Allocation of IPOs must be fair according to regulatory rules and principles, and the BNPP IP entities allocation policy. Allocations are weighted in accordance with the size of the order. Very small allocations are adjusted to ensure that accounts do not receive an uneconomic allocation of stock. Compliance is actively involved in the oversight and monitoring of the IPO allocation process Less liquid products Where BNPP IP entities execute, transmit or place an order on a client s behalf, in a financial instrument for which there is a limited market and/or limited liquidity and/or limited price transparency, the dealing entity will use best efforts to achieve the best possible result for the clients. In executing an order, or placing or transmitting an order for execution with a third party in these circumstances, BNPP IP entities will assume that they have provided the best possible result and this will satisfy their obligations to clients under this Policy Abnormal market conditions In the case of severe market turbulence, and/or internal or external system failure, the ability to execute orders on a timely basis, or at all, will become the primary factor. In the event of system failure BNP Paribas Fin AMS may not be able to access all of our chosen execution venues Aggregation of orders Except in cases where client restrictions are in place which prevent aggregation of orders, BNPP IP will aggregate orders where it is unlikely that aggregation will work overall to the disadvantage of any client whose order is to be aggregated. However it is possible that the effect of aggregation may work to a client s disadvantage in relation to a particular order Execution factors BNPP IP and dealing entities undertake, within the meaning defined by the European Directive, to "take all reasonable steps to obtain the best execution for their clients". In this context, BNPP IP entities consider the wider picture when the dealing venue and instrument type is chosen. The following factors are taken into account when considering OTC transactions: Price 6

8 Specialisation of market making in complex derivatives Speed of trading Market intelligence Settlement Counterparty credit rating and quality of the counterparty The Counterparty Selection Committee takes into account the performance of counterparties in respect of the factors listed above as well as the future risks of authorised counterparties Price The implementation of requests for quotes (apart from listed markets) is likely to identify the best price. It is however worth noting that in some parts of the OTC market, a single quote may only sometimes be possible, in particular in case of illiquid, customised or complex products. In any case, a record of the quotes obtained within the framework of request for quotes contributing to getting the best price, subject to the realisation of other criteria of execution, is retained Nature and characteristics of the order BNPP IP entities may deal in highly complex instruments where quotes are only available from one counterparty or where the market marking is confined to a single execution venue. With any transaction, the aim is to achieve the best possible result. With respect to Counterparties, dealing entities will use counterparties that have been approved by the BNPP IP counterparty committee Market liquidity As liquidity in OTC markets is not constant from day to day or, indeed intraday, BNPP IP entities may not be able to access the market at certain times. This factor is taken into account when considering the prices achievable Cost BNPP IP entities will take into account any commissions or fees (direct or indirect) when considering best execution for OTC transactions to arrive at the best possible result for the client Credit Lines Although a counterparty may offer the best price or value for a given order, the broker may not be able to secure the best terms with a particular counterpart as a credit line may not have been approved for the client. 7

9 Securities lending For securities lending, BNPP IP entities use a limited number of counterparties including BP2S 3 and Fin AMS either directly or as agent to approved counterparties to benefit from a size effect on the market Internal Crossing Where clients use the same custodian and where appropriate, BNPP IP may take advantage of crossing opportunities, where permitted by the client and/or local regulation. Care is taken to ensure that both sides of the trade benefit from little or no commission and at a fair price to all parties. Internal Crossing is subject to local Compliance approval Best Execution and Selecting the Dealing Venue The dealing entity determines the execution characteristics of received orders by applying the following criteria, hierarchically ranked: Selection of an authorised provider (intermediary or counterparty) among the list established by the ordering party; Choice of the authorised provider(s) according to their ability to respect the execution policy linked to the order, so as to optimise the dealing-desk services and respect the orders typologies; If need be: On the scope of financial instruments subjected to brokerage commissions or allocated volumes, at the request of the client who will have first communicated his budgets or allocations of volumes per authorised provider: choice of a provider authorised on the list, according to advance/delay of different criteria (of allocated brokerage fees or volumes distributed compared to the objectives and in accordance with possible indications expressed by the client). On the scope of the other financial instruments, at the request of the client who will have first communicated a ranked list of authorised providers with objectives in terms of market share or participation to requests for quotes: choice of the authorised provider according to advance/delay according to these objectives. The Parties will progress using the methods and the frequency of review of this classification. As a consequence, no order may be transmitted by management teams to BNP Paribas Fin AMS, with instructions imposing the use of a specific intermediary (broker or counterparty), which would be in contradiction with best execution principle, unless this choice is wholly justified and documented, in the best interest of clients. Although trading via many venues to capture liquidity might seem beneficial, gains can be neutralised by the brokerage fees charged to customers for each transaction. The entities of BNPP IP use post-trade cost analysis provided by third parties to help assess the quality of trading decisions. 8

10 Size of the order Where the size of the order is above Normal Market Size (NMS), the optimal approach to best execution may be to request a price from a single counterpart and manage execution accordingly; even if such executions are inferior to other market indications of interest. Alternatively, obtaining quotes in NMS to discover the counterpart which will likely to offer the best quote and then opening up is another technique to achieve the best possible result. The records of the brokers, quotes and trade sizes will be kept. BNP Paribas Fin AMS will seek to trade with those that have historically offered the best terms for these types of transactions Market intelligence The timeliness, accuracy and consistency of market intelligence may be crucial in determining the implementation of an order or series of orders. BNPP IP will focus on the quality of research, the procurement of market access and the timeliness of market sensitive information. Just because a broker provides market intelligence does not mean that BNPP IP entities will execute with that venue Settlement Risk BNPP IP must have confidence in the confirmations and settlements process. Dealing entities will only trade with counterparties approved by BNPP IP s entities Conditions for reviewing the best execution policy Minimum frequency of review This execution policy, available to clients, is reviewed at least once annually, even if no changes are required. Nevertheless, any significant change having an impact on the ability to obtain the best possible result also implies a likely review of the execution policy. Among the factors leading to this anticipated review, in a non exhaustive way, the following can be confirmed: Reporting of very large gaps compared to initial objectives, during controls made by fund management teams or the Compliance Department Occurrence of a new release such as: New venues that, after study, ought to be added to the selected list of venues, because they would enable to achieve better outcomes during the execution New investments process among the company New financial instruments among the asset management universe etc. 9

11 Responsibility for the review The definition of the execution policy is in the first place the portfolio management company s responsibility. Nevertheless, the Compliance Department is in charge of making sure that the review of this policy, at least annually, takes place correctly. It is part of the controls plan implemented by the Compliance Department. As mentioned above, undertaking a review does not imply a systematic change in the execution policy. However, the decision of keeping the execution policy unchanged must be traced. On the contrary, if facts or reporting lead to an anticipated change of the execution policy, the review is to be conducted as soon as possible. The Compliance Department is responsible for calling for immediate action Terms of review The review is conducted during a formal meeting gathering at least, under the presidency of the Chief Investment Officer or his representative, fund managers designated by him, the Head of Compliance of the company, and eventually BNP Paribas Fin AMS. This meeting leads to minutes, under its President s initiative Factors to be taken into account during the review Any factor that could damage the quality of execution has to be taken into account: change in the environment (execution venues, services provided by counterparties ), types of investments process, financial instruments used, orders nature, etc. Besides, as mentioned in the part of this procedure devoted to controls of the best execution, the report written by the Head of Compliance based on his observations has to be taken into account when the execution policy is annually reviewed. For all the orders issued by an asset management company, and transmitted to the market through a dealing entity, the quality of the entity executing the trade has to be associated with the execution policy review. According to the elements gathered, to the assessment of the implemented policy and of its results, as well as to the objectives to be reached, the execution policy or its implementing detailed terms (matrix, benchmarks, etc.) should be confirmed or modified. The minutes must be precise enough to make the new elements of the execution policy clear, enforceable, and be subject to relevant controls Possible information on updates In case of significant changes in the execution policy or in its implementing terms, clients must be informed. The annual review Committee has then to decide the manner in which the information should be given to clients, including of course the update of the information available on the web site of the company. 10

12 3. Selection policy of research services and investment support services 3.1. Purchase of research The cost of the provision of external research is effectively distinguished from the cost of executing a trade, and is included in the overall commission paid on a transaction. However, BNPP IP entities and dealing entities have no incentive to pay brokerage commissions unless the service provided can be of benefit to the performance of their clients, and therefore their sole consideration when placing a trade with a broker is that the best possible outcome will be achieved. BNPP IP entities can also acquire research from independent providers with no links to the executing broker. This is paid for via the use of commission sharing agreements, although trades are only executed pursuant to such an agreement where a client has explicitly permitted this, or previously permitted trades to be executed pursuant to a soft commission agreement. The use of commission sharing agreements is detailed in the next section. The quality of all research received is analysed by the fund managers and the internal research teams in the interest of the investment process. For these reasons, some entities of BNPP IP have set up a team dedicated to managing its relationships with external investment decision-making services providers. The team organises a voting session by portfolio managers on the quality of the financial research and services they have received. The vote considers the following criteria: Quality of research : Coverage (geographic, by sector, by market capitalisation, etc.); Overall quality of analysis (quality of models used, reliability of forecasts, etc.); Relevance of trade recommendations expressed by the analysts and presented by the sales teams Efficiency of client relationship management (quality of follow-up and phone interviews, ability to organise meetings with companies managers, etc.). These votes are consolidated and studied in the framework of Brokers Review Committee managed by Brokers Relations department. This Brokers Review Committee examines the results of the vote and makes sure they are correctly understood. Then, based upon the votes and the needs expressed by portfolio managers, it decides which providers may enter or exit the panel of approved providers. Finally, the Brokers Review Committee validates rankings, which allow it to determine the budget for research services Commission Sharing Agreements Some entities of BNPP IP also acquire research from independent providers with no links to the execution broker. This is paid for by means of commission sharing agreements. 11

13 Under a Commission Sharing Agreement, these entities instruct the broker to pay a part of the normal commission paid to a third-party research provider as payment for research and advisory services that have assisted the fund managers in investment decisions for client portfolios. Such commissions are only paid in respect of research, execution and advisory services which support the fund managers decision making process. This arrangement enables these entities to accurately track spend on research services provided and compare the value for money obtained from broker research services, against that provided by independent research houses. This allows them to identify and use the best providers of investment research services. Commission Sharing Agreements are not dependent upon placing specific volumes of business with individual counterparties and are subject to contractual provisions that prevent the commission sharing agreement from conflicting with our obligation to obtain best executions for clients Commission unbundling When a commission is paid to a broker for the execution of a trade, part or all of this payment represents payment for the execution and, where appropriate, clearing of the trade. However, a part of the cost may represent payment for research services provided by the broker. In some jurisdictions BNPP IP entities have a regulatory requirement to provide a breakdown of the execution and research and advisory services purchased by commission. BNPP IP entities will ensure clients receive such reports. BNPP IP entities believe that it is appropriate to use commissions to purchase these services as the commissions represent a fair method of splitting out the costs of such services in an appropriate way across all clients whose portfolios have benefited from these services. Financial Services regulators have set rules as to the execution, research and advisory services BNPP IP entities can pay for through commissions and they meet these regulatory requirements Use of Soft Dollars to Obtain Research Services Soft Dollars is prohibited apart from services offered in the US and for clients who have permitted such activity. For those clients who permit soft commission or commission sharing arrangements on this basis, the following will apply. In the case where more than one broker/dealer is capable of providing the best combination of price and execution with respect to a portfolio transaction, BNPP IP entities may select a broker/dealer that furnishes research services. These research services may include: Furnishing advice concerning the value of securities, the advisability of investing in, buying or selling securities and the availability of securities, purchasers and sellers in the marketplace. Furnishing information, reports, analysis and seminars about issuers, industries, securities, trading markets, legislative and political developments, economic factors and trends, portfolio strategy, access to research analysts, corporate management personnel, industry experts and economists, comparative performance evaluation, technical measurement services, quotation services and other products and services including third party publications, reports and analysis, computer and electronic access, information and accessories that deliver, process or otherwise utilize information including the research described above. All of these products and services assist BNPP IP entities in carrying out their investment decision-making responsibilities. Effecting securities transactions and performing functions incidental thereto such as clearance and settlement. 12

14 In addition, if a BNPP IP entity determines in good faith that the commission charged by a broker/dealer is reasonable in relation to the value of research and brokerage services provided by such broker/dealer, this entity may cause a client account to pay an amount of commission greater than the amount another broker/dealer may charge, but within a competitive range for full service broker/dealers. A BNPP IP entity may enter into agreements with broker/dealers regarding the allocation of a minimum annual amount of brokered transactions to such broker/dealers. In exchange, this entity receives research and research related software and services as described above. A transaction will be placed with such broker/dealers only if consistent with the best execution policies described above that take into account the provision of research and related services and the entity will terminate any such arrangement or compensate the broker/dealer in cash for such research to the extent it cannot fulfil the arrangement consistent with such policies. Some mixed-use products and services can be used by BNPP IP entities for both research/execution and nonresearch purposes such as administration and marketing. If these products or services are obtained using soft dollars, BNPP IP entities will allocate the cost between research and non-research uses. BNPP IP entities will use their own hard dollars to pay that part of the cost that is not attributable to research/execution uses. Some brokerage and research services received may benefit client accounts other than the account generating the soft dollar credits. 13

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