Order Execution Policy - Citco Bank Nederland N.V.

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1 Order Execution Policy - Citco Bank Nederland N.V. 1. Objective of Policy The objective of the Policy is to summarize the arrangements that Citco Bank Nederland N.V. ( CBN ) has established in order to obtain the best possible result for its clients when executing orders in financial instruments on a client s behalf and to act in its clients best interest when executing such orders. 2. Scope The Policy applies to Professional Clients and to the following financial instruments described hereunder: 2.1 Client orders in UCITS and other non-ucits investment funds: These orders constitute the majority of CBN s trading activities and are generally sent to the transfer agent or administrator as listed in the offering document or prospectus of the particular fund in question. Therefore when executing such orders, due to the nature of the characteristics of the orders, CBN (and thus its clients) always receives the best possible Execution Factors and Execution Criteria as described below in sections 4 and 5 respectively. 2.2 Client orders in other financial instruments: Where more than one execution venue is available in the market, CBN will determine the relative importance of the Execution Factors (as described in section 4) and take into account the Execution Criteria (as described in section 5) when selecting which execution venue to use. CBN will use its professional and commercial judgment, in addition to available market information, in making this decision. 3. Execution Venues CBN will execute orders that are related to financial instruments mentioned in section 2.2. above, on a stock exchange, multilateral trading facility or systematic internaliser. Depending on the nature of the financial instrument, the size and the nature of order, CBN may use the services of a broker in order to obtain the best possible result for its clients. For these types of financial instruments CBN has selected a number of execution venues, mentioned in Appendix 1, that meet its criteria for delivering best execution in these particular financial instruments. The selection criteria used by CBN when selecting brokers is set out in CBN s operating procedures, and CBN will assess its relationship with brokers on at least an annual basis to determine whether the execution arrangements and approach of those brokers provide CBN with the best possible result for the underlying transactions. 4. Execution Factors When executing client orders (except for specific instructions as mentioned in section 7 below), CBN will take reasonable steps to seek and obtain the best possible result for its client, taking into account the following execution factors set out below: Citco Bank Nederland N.V., January 2011 (version 3.2) Page 1 of 5

2 price; cost; speed of execution; speed of settlement; likelihood of settlement; size of order; nature of order; any other consideration relevant to the execution of the order. 5. Execution Criteria in relation to a particular trade The Execution Criteria that will be taken into account are the particular characteristics of: the Client; the Order; the Financial Instruments; and the Execution Venues. 6. Scope of the Financial Instruments The Policy covers the following financial instruments: a) Transferable Securities: 1. UCITS and other investment funds (covered in section 2.1) 2. Other transferable securities (such as Equities, Exchange Traded Funds) b) Money Market Instruments c) Derivatives in Currencies The execution of financial instruments mentioned in a)2., b). and c). is covered in section 2.2 and section 3 above. 7. Specific Instructions Where a client gives CBN a specific instruction in relation to the execution of a particular order CBN will, (if appropriate for that type of financial instrument), execute the client order in accordance with such specific instruction. Please note however that a specific instruction may prevent CBN from following the Policy in obtaining the best possible result for the client. 8. Review and Monitoring CBN will review the Policy and the Execution Venues used, at least quarterly, or in the event of a material change occurring to an Execution Venue. Compliance with the Policy will be monitored, on a sample basis, to ensure that the resulting transaction has delivered the best possible result. Citco Bank Nederland N.V., January 2011 (version 3.2) Page 2 of 5

3 Any updates to the Policy or the Execution Venues will be posted under the Banking Policies section on CBN s website: 9. Client Order Handling Rules In the event that there is a conflict regarding the execution of an order between the Policy and the Brokerage and Custody/Service Level Agreement with a client, the terms and conditions of the signed Brokerage & Custody/Service Level Agreement(s) with the client will prevail. Disclaimer This document does not constitute legal advice. You are advised that you should take independent legal advice on issues that are of concern to you. Please note that CBN will not necessarily offer all services referred to in the Policy to each of its clients. Citco Bank Nederland N.V., January 2011 (version 3.2) Page 3 of 5

4 Appendix 1 Below is an overview of execution venues which CBN may use when executing financial instrument orders as mentioned in section 2.2 and section 3 above. Please be advised that this is not an exhaustive list of execution venues and is subject to change due to market conditions. Money Market Instruments and New Zealand Banking Group Melbourne Banco Santander S.A. Madrid Spain Bank Nederlandsche Gemeenten N.V. Bank of Montreal Montreal Bank of Nova Scotia Barclays Capital Plc BNP Paribas SA Commonwealth Bank of Sydney Den Danske Bank, & Copenhagen, Denmark Deutsche Bank AG DnB NOR Bank ASA Oslo Norway Dutch Treasury State Agency European Investment Bank German State Agency HSBC Group New York United States JP Morgan Chase New York United States KFW Bankengruppe Landwirstcharftliche Rentenbank Ministry of Finance National Bank (The) Melbourne Nederlandsche Watersachapsbank Nordea Bank AB NRW Bank Duesseldorf Pohjola Bank Plc. Helsinki Finland Rabobank Utrecht Standard Chartered Bank Svenska Handelsbanken AB Sumitomo Mitsui Banking Corporation Tokyo Japan Dominion Bank (The) Citco Bank Nederland N.V., January 2011 (version 3.2) Page 4 of 5

5 Derivatives in Currencies Barclays Capital Plc BNP Paribas SA ING Bank N.V. Rabobank Utrecht Other Transferable Securities Astaire & Partners Limited Bank Austria Creditanstalt Austria Banque Cantonale Vadoise Banque Société Générale Banque SYZ BMO Nesbitt Burns Inc. Brown Brothers Harriman & Co. Clearstream International Corner Banca Lugano Danske Bank Copenhagen Denmark Den Norske Bank Oslo Norway Deutsche Bank Erste Group Bank AG Vienna Austria Euroclear PLC Euronext N.V. Fidulex Management Inc HSBC Private Bank (Monaco) SA Monaco HSBC Republic Bank Kas Bank SEB SG Private Bank UBS AG Citco Bank Nederland N.V., January 2011 (version 3.2) Page 5 of 5