Best Execution Policy

Transcription

1 Best Execution Policy for Formuepleje A/S 1 of 5

2 1. Introduction & purpose This Best Execution Policy for Formuepleje A/S (the Company ) describes the procedures followed by the Company when executing orders and transactions on behalf of investment associations and alternative investment funds, customers with whom discretionary mandate agreements have been made or other investors with whom discretionary portfolio management agreements have been made (hereinafter referred to as Customers ). In accordance with this policy, the Company will ensure that the best possible result is obtained under the given circumstances when executing orders for Customers and in the Customers interests. Furthermore, the Best Execution Policy aims to ensure that the Company acts in the Customers interests when the Company communicates transaction orders to other units who will perform transactions on behalf of the Company. The Best Execution Policy is given to the Company s Customers and is supported in the Company by internal procedures and routines that ensure compliance with applicable legislation in the area. The Best Execution Policy is also available on the Company s website. 2. General provisions for transactions The Company executes transaction orders for securities on behalf of Customers with whom portfolio management agreements have been made or for associations with which investment advice or portfolio management agreements have been concluded. Furthermore the Company executes transactions and redemption of certificates issued by its Funds. This service is provided against payment of a fee of 250,- DKK to the Funds Market Maker. All Transactions are settled through the clients custodian bank. Costs The Company does not receive any transaction income from trading in securities for the Company s Customers. All transaction costs accrue to the depositary executing the order. 3. Best execution factors The Company takes all reasonable measures to achieve the best possible result for the Customers in the given circumstances when completing transaction orders (best execution). The Company considers a range of factors which affect the total settlement amount, comprising the price of the instrument and all expenses directly related to executing the order. Factors taken into consideration: Price Costs Speed Likelihood of execution and settlement Scope Type Settlement Other issues of possible relevance to the order Criteria for determining the importance of the factors: The division s target, investment strategy and risk profile of the Customer The characteristics of the transaction order The characteristics of the instruments traded and trading systems used. The total consideration will usually be given most weight. The total consideration refers to the price of the securities and all expenses directly related to executing the order, including fees in connection with the execution venue, settlement and other fees to third parties involved in executing the order. The Company reviews the above factors regularly to assess their adequacy and suitability for delivering the best possible result for customer transactions. 4. The Customer s instructions The Company will always execute orders in accordance with a Customer s instructions as stated in more detail in the agreement concluded. Depending on the nature of the instructions, this may prevent the Company from delivering best execution in full or in part. The Customer s instructions take precedence over order execution under this policy. However, the Company will still attempt to execute the order in the best possible manner with due consideration of the Customer s instructions. 2 of 5

3 5. Aggregation and allocation of customer orders The Company can aggregate transactions (aggregation) before an order is placed on the market. The objective is to ensure best execution and it will only take place when the company believes it to be to the overall benefit of the Customer. Aggregation may however on occasion be disadvantageous to the Customer in relation to a specific order. The distribution of the total order (allocation) takes place at an average price for the combined order. If the combined order can only be executed in part, allocation will take place subject to proportionate settlement at the average price. The Company does not aggregate transactions placed by retail customers. 6. Execution venue & transaction counterparties The Company is not a member of a stock exchange, meaning that all transactions are effected directly with a securities broker as transaction counterparty for the Customer. The choice of transaction counterparties is essential for achieving best execution, and the transaction price weighs heavily in the Company s selection of transaction counterparties. For this reason, the Company carries out a thorough transaction counterparty selection procedure at fixed intervals. In practice, transaction counterparties are chosen for categories of financial instruments in order to achieve the best possible transaction. An approved counterparty list is available as an appendix to the Best Execution Policy and can be found at the Company s website at all times. 7. Control, registration and documentation The Company s compliance function regularly checks and verifies the compliance with this Best Execution Policy. Furthermore, the Company ensures that associated and related documents are stored in a manner that complies with applicable law at all times. If requested, the Company will provide Customers with documentation that orders have been executed in accordance with the Best Execution Policy. Prior to making changes to the Best Execution Policy, the Company must obtain the consent of the associations under management. The Company must verify, regularly and at least once annually, that the Best Execution Policy and the Company s other procedures for execution and provision of orders function efficiently, in accordance with the intentions and in accordance with applicable law. As Appendix: Counterparty list as of 9. May 2016 Adopted by the board of directors on 9. May of 5

4 Appendix Counterparties Counterparties Counterparty City Name Country name ABG Sundal Collier ASA Oslo Norway Alm. Brand Bank Copenhagen Denmark Bank of America Merrill Lynch International Limited London UK Barclays Bank PLC London UK BCP Securities Europe Madrid Spain BNP Paribas SA Paris France BTIG Limited London UK Carnegie Investment Bank AB Stockholm Sweden Citigroup Global Markets Limited London UK Credit Suisse Securities (Europe) Limited London UK CSLA (UK) London UK Danske Bank AS Copenhagen Denmark Deutsche Bank AG Frankfurt am Main Germany DNB Markets (part of DNB Bank ASA) Oslo Norway GMP Securities, LLC New York US Goldman Sachs International London UK Itaú BBA International PLC London UK Jefferies International Limited London UK JP Morgan London UK Jyske Bank AS Silkeborg Denmark Lind Capital Fondsmæglerselskab AS Aarhus Denmark Lloyds Banking Group PLC Edinburgh UK Morgan Stanley & Co International PLC London UK Nomura International PLC London UK Nordea Finland Helsinki Finland Nordjyske Bank Aalborg Denmark Nykredit Bank AS Copenhagen Denmark Oddo Et Cie Paris France Pareto Securities AS Oslo Norway RS Platou Markets AS Oslo Norway 4 of 5

5 RW Pressprich & Co New York US Sberbank CIB UK LImited London UK SC Lowy Hong Kong China SEB Sverige Stockholm Sweden SEB DK Copenhagen Denmark Societe Generale SA Paris France Spar Nord Bank AS Aalborg Denmark Stifel Nicolaus Europe Limited London UK Swedbank AB Stockholm Sweden Sydbank AS Aabenraa Denmark UniCredit Bank AG Munich Germany Wells Fargo Securities International London UK 5 of 5