ORDER EXECUTION POLICY (PROFESSIONAL CLIENTS)
|
|
- Junior Todd
- 8 years ago
- Views:
Transcription
1 ORDER EXECUTION POLICY (PROFESSIONAL CLIENTS) July 2015
2 1. Introduction Impax Asset Management Limited and Impax Asset Management (AIFM) Ltd ( Impax ) manages undertakings for collective investment in transferable securities ( UCITS ), segregated accounts and alternative investment funds ( AIFs ). In this policy the UCITS, segregated accounts and AIFs are referred to as Clients. Both Impax entities are jointly regulated by the Financial Conduct Authority (FCA) and the Securities and Exchange Commission (SEC). Impax Asset Management (Hong Kong) Limited is a registered institution with the Hong Kong Securities & Futures Commission (SFC). This policy applies to all clients of Impax. 2. Our Best Execution Obligations Impax is required by the EU Markets in Financial Instruments Directive (MiFID) and COBS 11.2 of the FCA Handbook to act in accordance with the best interests of its clients when placing orders with brokers for execution and to take all reasonable steps to obtain the best possible result for its clients and funds when directly executing orders with an Execution Venue on behalf of its clients. 3. Execution Factors & Venues In seeking to provide a client with best execution, we are required to take into account certain execution factors and decide on their relative importance when executing client orders. price; cost or commissions; speed of execution; the current liquidity for the relevant security; the size and nature of the order; the potential market impact of the transaction; likelihood of execution; responsibility and solvency of the counterparty; quality and efficiency of the settlement process; characteristics of the execution venues to which that order can be directed; characteristics of the client order. The relative importance of these execution factors will be judged on an order by order basis in line with our commercial judgement, in light with current market information. While price is often an important execution factor, there will be situations when this is not the priority when executing an order, examples include: smaller capitalized equities and less liquid stocks, the likelihood of execution and provision of liquidity may be more important than price; when raising cash to fund redemptions, speed may take priority over price; when executing a large order, being able to transact the whole order at a less favourable price may be more important than executing part of the order at a better price; the volatility of price may make timeliness a greater priority; the choice of execution venues may be limited for certain instruments; For our UCITS funds, the objectives, investment policy and risks specific to the UCITS scheme as indicated in the prospectus; where a portfolio manager gives a specific instruction for the execution of a client / fund order, then the order will be executed in accordance to those instructions. The portfolio managers when acting for our clients and funds should be aware that providing such instructions will prevent Impax from taking some of the steps above to obtain the best possible result for the execution of that transaction. 2
3 All brokers Impax use are authorised by the competent authority in their home state and have been contracted to provide us with best execution when dealing on our behalf. The approved brokers are reviewed on a regular basis at Impax by the portfolio managers and the dealing function. 4. Crossing between funds Should there be an opportunity to cross stock between funds, and where a market quote is available, the stocks will be crossed in the market at a mid-market price within VWAP/TWAP range to demonstrate best execution. Prior to any cross trade transaction, the trading desk will supply all relevant information relating to the trade to the Compliance Department for review. The Compliance team will consider whether all parties to the cross are being treated equitably, that no investment guidelines will be contravened, that there are no conflicting interests between the parties before approving or rejecting any request. Other factors considered include evidencing that the trade is not a means of providing improper liquidity support between funds. Such activity represents a conflict of interests between funds and is disallowed. Impax will also take into account any delays to trade and whether at any point up to actual execution it is beneficial for one fund to trade independently ahead of another. 5. Trade allocation Some orders may be aggregated where we have reasonable grounds to believe that this will work to the advantage of each of our clients concerned, for example, by achieving a more advantageous price through benefits of scale, or by achieving processing efficiencies at no disadvantage to clients. If we aggregate an order, the subsequent allocation will not give unfair preference to any client for whom we have dealt. Our trade allocation process ensures the fair allocation of aggregated orders between clients. When orders are aggregated from more than one client, the executed trades will be allocated in accordance with the company s trade allocation standard. Trade allocation must be determined on a basis that is fair, reasonable and equitable to all clients based on Impax s policies and client investment objectives and to avoid favouritism or discrimination among clients in favour of a preferred client or group of clients. Impax s trade allocation is in accordance with FCA requirements including: Timely allocation Fair allocation Re-allocation Combining two or more accounts in one trade regardless of the portfolio manager involved will be allocated on a pro rata basis for all outstanding orders at the time of the fill. Each account involved will receive a percentage of the executed portion of the partially filled order based upon each account s percentage of the entire order. The allocations will be made at the average execution price where there is more than one fill. 3
4 Transactions are allocated promptly, on the trade date, and no reallocations are permitted from one account to another except where the original allocation was done in error. Re-allocation is subject to the approval of the Head of Compliance and reasons should be documented within one business day. A revised allocation may be made where an order is only partially executed resulting in an uneconomic allocation to some clients; in such a case we will take reasonable steps to ensure that a re-allocation is in the best interests of the clients for whom we have dealt. Stock would not be allocated to a client if it would be uneconomic or prohibitive, from a dealing cost point of view, for the client. An allocation would be regarded as uneconomic or prohibitive if the administrative cost of the transaction was disproportionate to the value of the stock allocated. 6. Commission Sharing Agreements CSAs Impax does acquire research from providers with no links to the executing broker. This is paid for via the use of commission sharing arrangements. Under such an arrangement, Impax instructs the broker to pay a part of the full commission to a third party research provider for research services that have assisted the portfolio managers in investment decisions for client portfolios. Impax will only pay for research that supports the portfolio managers decision process. This process enables us to accurately track expenditure on research services and identify the best providers of the research services we receive. The quality of all research received is analysed by the portfolio managers and our research teams as part of our investment process. An online voting session is then organized by portfolio managers on the quality of the financial research and the value of the services they received in relation to our strategies. The CSA Committee which comprises the Head of Compliance, the Head of Listed Equities and the Head of Trading. Other attendees can include Portfolio Managers and Operational team members as appropriate. The Committee meets quarterly to examine the results of the vote and to ensure they are correctly understood. The CSA Committee validates rankings which allow it to monitor against the budgets set for the research services. 7. Monitoring & Review Impax will monitor the effectiveness of its Order Execution Policy and its execution arrangements to identify any shortcomings in execution quality. We use the services of a third party to provide us with quarterly transaction cost analysis (TCA). Their findings, broker performance and selection of brokers are discussed quarterly by the Best Execution Committee which comprises of Head of Listed Equities, Head of Dealing, Head of Compliance and the Chief Operating Officer of Listed Equities. On CSA arrangements, the Compliance function maintains oversight over the voting and allocation process. 4
5 8. Client Consent, Unexecuted Limit Orders and Modifications to the Order Execution Policy Under the FCA regulations, Impax requires your prior consent to this Order Execution Policy, and for Impax to deal in un-regulated or non-eu markets or MTFs. By appointing Impax as your discretionary portfolio manager, you are deemed to have provided such prior express consent. Where we are unable to execute Limit Orders under prevailing market conditions, we are required to make such Orders public. This is not in your best interests and we will use our discretion as to whether or not we make such orders public unless otherwise notified. 5
6 Appendix A List of commonly used execution venues The brokers or dealers that we have execution arrangements with include: UBS Liquidnet Merrill Lynch & Co Inc Credit Suisse Group ITG Robert W. Baird & Co Morgan Stanley CLSA Asia-Pacific Markets SEB Group Liberum Capital Goodbody Stockbrokers Panmure Gordon UK Ltd National Bank Financial Standard Chartered Bank KBC Peel Hunt Arden Partners Libertas Capital Securities Ltd Berenberg Bank Instinet Europe Ltd Russell Investments Our policy for order execution will be reviewed regularly and any material changes notified to our clients via our website. 6
Pictet Asset Management: Summary of Best Execution Policy
Pictet Asset Management: Summary of Best Execution Policy January 2015 1. Introduction The Markets in Financial Instruments Directive ( MiFID ) requires all investment firms when executing orders on behalf
More informationOrder Execution Policy
Order Execution Policy 1 Overview The purpose of this document is to provide clients of Stocktrade ( Stocktrade or we or us ) with information about our Order Execution Policy and to seek your consent
More informationCredit Suisse Asset Management Limited UK Order Execution Policy December 2013
Credit Suisse Asset Management Limited UK Order Execution Policy December 2013 Table of Contents 1. General information about this Policy 1 2. CSAML s Core Best Execution Obligations 2 3. Placing Orders
More informationSummary of Scotiabank London Best Execution Policy
1. Introduction Summary of Scotiabank London Best Execution Policy 1.1 The Bank of va Scotia ( BNS ) is authorised and regulated by the Office of the Superintendent of Financial Institutions in Canada.
More informationFUND MANAGER CODE OF CONDUCT
FUND MANAGER CODE OF CONDUCT First Edition pursuant to the Securities and Futures Ordinance (Cap. 571) April 2003 Securities and Futures Commission Hong Kong TABLE OF CONTENTS Page INTRODUCTION 1 I. ORGANISATION
More informationNew Conduct of Business Sourcebook. Chapter 11. Dealing and managing
New Conduct of Business Sourcebook Chapter Dealing and managing COBS : Dealing and managing Section.1 : Application.1 Application.1.1 eneral application This chapter applies to a firm. (1) [deleted] (2)
More informationAMP Capital Investors Limited ABN 59 001 777 591 AFSL 232497. > Trade Management Policy
AMP Capital Investors Limited ABN 59 001 777 591 AFSL 232497 > Trade Management Policy 27 APRIL 2015 Contents 1. AMPCI Trade Management Policy 2 1.1 Objective 2 1.2 Application of this Policy 2 1.3 Roles
More informationJ.P. Morgan Asset Management Institutional Order Execution Policy Disclosure
J.P. Morgan Asset Management Institutional Order Execution Policy Disclosure 1 Introduction and scope The rules of the Financial Services Authority ( FSA ), in implementing the Markets in Financial Instruments
More informationBest Execution Policy
Black Pearl Securities Limited "the Firm" Best Execution Policy This Best Execution Policy is applicable to Matched Principle Broker (MPB) services provided to you by the Firm and it should be read in
More informationThis is a guide to how funds and managed accounts work, how they are regulated and the pros and cons of each.
GUIDE TO FUNDS AND MANAGED ACCOUNTS This is a guide to how funds and managed accounts work, how they are regulated and the pros and cons of each. Glossary These are some of the common words used in this
More informationTerms of Business. 03 March 2014. Authorised and regulated by the Financial Conduct Authority
Terms of Business 03 March 2014 Authorised and regulated by the Financial Conduct Authority Our Particulars The full name of our firm is Winterflood Securities Limited ( Wins ) The address of our registered
More informationCLIENT RELATIONSHIP DISCLOSURE STATEMENT
A. INTRODUCTION CLIENT RELATIONSHIP DISCLOSURE STATEMENT Securities legislation in Canada requires Deans Knight Capital Management Ltd. ( Deans Knight or the firm ) to provide you with certain information
More informationORDER EXECUTION POLICY
ORDER EXECUTION POLICY Saxo Capital Markets UK Limited is authorised and regulated by the Financial Conduct Authority, Firm Reference Number 551422. Registered address: 26th Floor, 40 Bank Street, Canary
More informationHow To Manage Conflicts Of Interest At Barings
Barings conflicts of interest policy SECTION A: INTRODUCTION Business activities & organisational structure of Barings The Barings companies provide discretionary investment management services. They also
More informationPOLICY. Best-Selection Policy. LAST UPDATED March 2014. Best Selection Policy March 2014 1
POLICY Best-Selection Policy LAST UPDATED March 2014 Best Selection Policy March 2014 1 Best-Selection Policy SUMMARY 1. Objective 3 2. Scope 3 3. Criteria for the selection of intermediaries and brokers
More informationmeans the Eligibility Criteria set forth in clause 4 of these Rules.
LIQUIDNET EUROPE LIMITED ( LIQUIDNET ) LIQUIDNET EUROPE FIXED INCOME MTF PARTICIPATION RULES 1 Glossary Term Competent Authority EEA Eligibility Criteria Erroneous Order Erroneous Trade FCA FCA Rules FSMA
More informationCREDITEX BROKERAGE LLP BEST EXECUTION POLICY
CREDITEX BROKERAGE LLP BEST EXECUTION POLICY Version 1.1 The Execution Policy is applicable to broker services provided by Creditex Brokerage LLP ( CBL ). Introduction When providing brokerage services
More informationEXANE GROUP EXECUTION POLICY
EXANE GROUP EXECUTION POLICY DISCLAIMER Exane 2015. All rights reserved. No part of this document may be reproduced in any form or by any means - electronic, mechanical, photocopying, recording or otherwise
More informationDesignator author. Selection and Execution Policy
Designator author Selection and Execution Policy Contents 1. Context 2 2. Best selection and best execution policy 3 2.1. Selection and evaluation of financial intermediaries 3 2.1.1. Agreement by the
More informationAct on the Management of Alternative Investment Funds
FINANSTILSYNET Norway Translation March 2015 This translation is for information purposes only. Legal authenticity remains with the official Norwegian version as published in Norsk Lovtidend. Act on the
More informationItem 2 Material Changes
Item 1 Cover Page Prutzman Wealth Management, LLC dba Prutzman Wealth Management 201 W. Liberty Street, Suite 207 Reno, NV 89501 (800) 865-4202 www.prutzmanwm.com 8/31/2015 This Brochure provides information
More informationManaged Fund Service. Terms and Conditions
Managed Fund Service Terms and Conditions Important Information These are the Terms and Conditions for your Balkerne Asset Management Managed Fund Service. You are advised to read them carefully. The terms
More informationJohanson Financial Advisors, Inc. 2105 South Bascom Avenue, Suite 255 Campbell, CA 95008. Firm Contact: Lynda Tu Chief Compliance Officer
Part 2A of Form ADV: Firm Brochure Item 1: Cover Page June 2015 Johanson Financial Advisors, Inc. 2105 South Bascom Avenue, Suite 255 Campbell, CA 95008 Firm Contact: Lynda Tu Chief Compliance Officer
More informationExecution Policy. Page 1
Execution Policy The intention of this document is to set out Edinburgh Partners (EP) policies and procedures in relation to the management of trading and its associated costs on behalf of clients. This
More informationPVM Execution Policy. A tullett prebon company. PVM Oil Associates Ltd. PVM Oil Futures Ltd. London
PVM Execution Policy This document details how we handle orders for our customers and strive to obtain the best possible outcome each time we deal on their behalf., NJ and PVM Oil Associates Ltd & PVM
More informationPACIFIC PRIVATE BANK LIMITED S BEST EXECUTION POLICY (ONLINE TRADING)
PACIFIC PRIVATE BANK LIMITED S BEST EXECUTION POLICY (ONLINE TRADING) 1 INTRODUCTION 1.1 This policy is not intended to create third party rights or duties that would not already exist if the policy had
More informationMERRION STOCKBROKERS LIMITED TERMS OF BUSINESS
MERRION STOCKBROKERS LIMITED TERMS OF BUSINESS Merrion Stockbrokers Limited is regulated by the Central Bank of Ireland and is a member firm of the Irish Stock Exchange and the London Stock Exchange. o
More informationHUME EUROPEAN OPPORTUNITIES FUND. SUPPLEMENT TO THE PROSPECTUS FOR EUROPEAN WEALTH INVESTMENT FUND plc
HUME EUROPEAN OPPORTUNITIES FUND SUPPLEMENT TO THE PROSPECTUS FOR EUROPEAN WEALTH INVESTMENT FUND plc This document supplements the current prospectus for European Wealth Investment Fund plc (the Company)
More informationTransaction Reporting - What is Changing Under MiFID II
MiFID II Understanding and Practical Preparation Transaction Reporting - What is Changing Under MiFID II Transaction Reporting This paper forms part of MiFID II: understanding and practical preparation
More informationRBS Collective Investment Funds Ltd Derivatives Risk Management Policy. Part 1: Authorised Corporate Director ( ACD ) Overarching Arrangements
RBS Collective Investment Funds Ltd Derivatives Risk Management Policy Part 1: Authorised Corporate Director ( ACD ) Overarching Arrangements Contents Page Policy Statement 3 Derivatives Defined 3 Credit
More informationICAP Execution Policy
ICAP Execution Policy August 2013 This Execution Policy is applicable to broker services provided to you by ICAP Group and/or any of its relevant group companies, as notified to you from time to time (
More informationOld Mutual Global Investors Order Execution Policy
Old Mutual Global Investors Order Execution Policy Old Mutual Global Investors (UK) Limited ( OMGI ) manages undertakings for collective investment in transferable securities ( UCITS ) including those
More informationIMPORTANT DISCLOSURES AND CONSIDERATIONS FOR INVESTORS IN AUCTION RATE SECURITIES
IMPORTANT DISCLOSURES AND CONSIDERATIONS FOR INVESTORS IN AUCTION RATE SECURITIES Goldman, Sachs & Co., as a Broker-Dealer of Auction Rate Securities, provides the following important information about
More informationSummary Order Execution Policy Terms of Use
Summary Order Execution Policy Terms of Use 0 Summary Order Execution Policy 1. Introduction 1.1 In accordance with MiFID guidelines and the Financial Conduct Authority (FCA) rules concerning its implementation
More informationCMC SPREADBET PLC Order Execution Policy Summary. for Financial Betting. January 2015. Registered in England. Company No. 02589529
CMC SPREADBET PLC Order Execution Policy Summary for Financial Betting January 2015 Registered in England. Company No. 02589529 Authorised and regulated by the Financial Conduct Authority. Registration
More informationOrder Execution Policy
Order Execution Policy 1 Overview The purpose of this document is to provide clients of Stocktrade ( Stocktrade or we or us ) with information in relation to our Order Execution Policy. The Order Execution
More informationHargreaves Lansdown Spread Betting/ Hargreaves Lansdown CFDs Trade & Order Execution Policy
/ Hargreaves Lansdown CFDs Trade & Order Execution Policy Effective from: 1st November 2007 www.hlmarkets.co.uk Telephone: 0117 988 9915 1 Trade & Order Execution Policy 1. Introduction This policy explains
More informationCollective Investment Undertakings of the Closed-Ended Type
P a g e 1 Listing Conditions Chapter 14 Collective Investment Undertakings of the Closed-Ended Type 1 P a g e 2 14.1 APPLICATION This chapter applies to securities issued by collective investment undertakings
More informationLevel One Disclosure Policy
Level One Disclosure Policy Fund Partners (FP) operates as an independent Authorised Corporate Director (ACD) for UK Regulated funds. FP s business is focused on ensuring good customer outcomes through
More informationIndividual Savings Account Supplementary Terms
Individual Savings Account Supplementary Terms Individual Savings Account Supplementary Terms and Conditions for Stocktrade Retail Clients forming part of the Agreement between Stocktrade (a division of
More informationExecution-Only Service Terms. (and related documentation)
Execution-Only Service Terms (and related documentation) Please note that this booklet includes the Execution-Only Service Terms, the Appendices, the Risk Disclosure Statement, the Order Execution Policy,
More informationImportant Information about Brokerage and Investment Advisory Services
Robert W. Baird & Co. Incorporated Important Information about Brokerage and Investment Advisory Services Understanding Brokerage and Investment Advisory Relationships Baird is registered with the Securities
More informationBEST EXECUTION AND ORDER HANDLING POLICY
BEST EXECUTION AND ORDER HANDLING POLICY 1. Introduction 1.1. This Summary Best Execution and Order Handling Policy ( the Policy ) is provided to you (our Client or prospective Client) in accordance with
More informationRBS Collective Investment Funds Limited
Derivatives Risk Management Policy RBS Collective Investment Funds Limited Derivatives Risk Management Policy Part 5 Funds Managed by Standard Life Investments Ltd 1. Policy Statement This policy document
More informationZurich Stocks and Shares ISA. Terms and conditions
Zurich Stocks and Shares ISA Terms and conditions Contents Introduction 3 The Terms and conditions 3 Roles and responsibilities 3 Risks 3 Terms and conditions 4 21) Your contract with us 4 22) Roles and
More informationPreparing to become a Hedge Fund/Open-ended Fund AIFM. May 2013. March2013. Preparing to become an AIFM 1
Preparing to become a Hedge Fund/Open-ended Fund AIFM May 2013 March2013 Preparing to become an AIFM 1 Complying with AIFMD We are pleased that the text of the implementing measures has been published.
More informationCode of Conduct for Securities Dealers. governing securities transactions
Code of Conduct for Securities Dealers 008 governing securities transactions Contents Preamble... 3 A General guidelines to the Code of Conduct... 4 Art. Legal basis... 4 Art. Scope... 5 B Duty of disclosure...
More informationMARKETING FUNDS IN EUROPE - A PRACTICAL LOOK AT AIFMD AND OTHER REGULATORY REQUIREMENTS
MARKETING FUNDS IN EUROPE - A PRACTICAL LOOK AT AIFMD AND OTHER REGULATORY REQUIREMENTS Foreword One of the original aims of AIFMD was to harmonise the management and marketing of AIFs in the so that a
More informationDiscretionary Investment Management Agreement. Premier SEP IRA. Ameritas Investment Corp. 5900 "O" Street Lincoln, NE 68510-2234
Discretionary Investment Management Agreement Premier SEP IRA Ameritas Investment Corp. 5900 "O" Street Lincoln, NE 68510-2234 DISCRETIONARY INVESTMENT MANAGEMENT AGREEMENT Ameritas Investment Corp. By
More informationExecution-Only Service Terms
Execution-Only Service Terms Please note that these Execution-Only Service Terms include and incorporate the Terms & Conditions, the Appendix, the Risk Disclosure Statement, the Order Execution Policy,
More informationORDER EXECUTION POLICY
ORDER EXECUTION POLICY Table&of&Contents& 1.#INTRODUCTION# 2! 2.! SCOPE#AND#SERVICES# 2! 3.#BEST#EXECUTION# 2! PRICE! 3! COSTS! 3! CURRENCY!!CONVERSION! 3! SPEED!!OF!!EXECUTION! 4! LIKELIHOOD!!OF!!EXECUTION!
More informationOverview of the LOYAL3 Platform: How It Works + Specific Risks
Dated September 2015 Subject to Change for Future Offerings Overview of the LOYAL3 Platform: How It Works + Specific Risks NOTE: THIS IS NOT THE PROSPECTUS. The Information Below is Specific to the LOYAL3
More informationVarius Global Equity Fund
Varius Global Equity Fund Supplement to the Prospectus dated 12 May 2016 for Platform Capital UCITS ICAV An umbrella fund with segregated liability between sub-funds This Supplement contains specific information
More informationCLSA GLOBAL PORTFOLIO TRADING SERVICES ANNEX. In this Annex, the following capitalised terms have the following meanings:
CLSA GLOBAL PORTFOLIO TRADING SERVICES ANNEX 1. Definitions and Interpretation In this Annex, the following capitalised terms have the following meanings: "Affiliates" shall mean members of the CLSA Group;
More informationMERCHANT NAVY OFFICERS PENSION FUND STATEMENT OF INVESTMENT PRINCIPLES
MERCHANT NAVY OFFICERS PENSION FUND STATEMENT OF INVESTMENT PRINCIPLES Introduction The main purpose of the MNOPF is the provision of pensions for Officers in the British Merchant Navy on retirement at
More informationBest Execution Policy
Best Execution Policy 1. General provisions 1.1. Aktsiaselts LHV Varahaldus (hereinafter Management Company) manages portfolios of investments for pension funds, LHV World Equities Fund and offers portfolio
More informationBEST EXECUTION POLICY - FINANCIAL INSTRUMENTS
BEST EXECUTION POLICY - FINANCIAL INSTRUMENTS BEST EXECUTION POLICY - FINANCIAL INSTRUMENTS This Best Execution Policy (the Policy ) sets out the overall principles that Danske Bank International S.A.
More informationComprehensive Financial Planning, Inc.
Comprehensive Financial Planning, Inc. 3950 Fairlane Drive Dacula, Georgia 30019 (770) 904-0490 This brochure provides information about the qualifications and business practices of Comprehensive Financial
More informationSECTION I. GENERAL EXECUTION
EXECUTION POLICY for spread betting SECTION I. GENERAL EXECUTION Introduction 1 The Applicable Regulations and our regulators, Financial Conduct Authority, require us to take all reasonable steps to obtain
More informationRBS Collective Investment Funds Limited
Derivatives Risk Management Policy RBS Collective Investment Funds Limited Derivatives Risk Management Policy Part 4 Funds Managed by BlackRock Policy Statement This policy document describes the use of
More informationMALTA TYPES OF COLLECTIVE INVESTMENT SCHEMES
MALTA TYPES OF COLLECTIVE INVESTMENT SCHEMES The Investment Services Act (Chapter 370 of the Laws of Malta) ( ISA ) defines the term collective investment scheme as follows: "collective investment scheme"
More informationClient Order Execution Policy
Client Order Execution Policy Client Order Execution Policy Application The EU Markets in Financial Instruments Directive ( MiFID ) and corresponding rules of the Financial Conduct Authority ( FCA ) requires
More informationDividend Reinvestment Plan Service Terms and Conditions
Dividend Reinvestment Plan SHARE REGISTRATION EMPLOYEE BENEFITS INVESTMENT SERVICES BUSINESS PROCESS OUTSOURCING Dividend Reinvestment Plan Service Terms and Conditions PARTNERSHIP THROUGH INSIGHT, INTEGRITY
More informationAIFMD means Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers, as amended.
Glossary Accounting Period means the annual accounting period for the Company ending on 31 December in each calendar year. The first annual accounting period will end on 31 December 2015. Acts means the
More informationCollective Investment Schemes
Collective Investment Schemes Collective Investment Schemes Introduction A collective investment scheme ( CIS ) is defined by law. According to section 235(1) of The Financial Services and Markets Act
More informationDISCRETIONARY INVESTMENT ADVISORY AGREEMENT
DISCRETIONARY INVESTMENT ADVISORY AGREEMENT This Discretionary Investment Advisory Agreement (this Agreement ) is between (the "Client") and LEONARD L. GOLDBERG d/b/a GOLDBERG CAPITAL MANAGEMENT, a sole
More informationCAIA Ireland Educational Workshop. 9 th October 2015. Driving the Governance Agenda in Alternatives
CAIA Ireland Educational Workshop 9 th October 2015 Driving the Governance Agenda in Alternatives Dr Margaret Cullen CEO Certified Investment Fund Director Institute Overview 1. Agency Problem 2. Conflicts
More informationF I R M B R O C H U R E
Part 2A of Form ADV: F I R M B R O C H U R E Dated: 03/24/2015 Contact Information: Bob Pfeifer, Chief Compliance Officer Post Office Box 2509 San Antonio, TX 78299 2509 Phone Number: (210) 220 5070 Fax
More informationSAXO BANK S BEST EXECUTION POLICY
SAXO BANK S BEST EXECUTION POLICY THE SPECIALIST IN TRADING AND INVESTMENT Page 1 of 8 Page 1 of 8 1 INTRODUCTION 1.1 This policy is issued pursuant to, and in compliance with, EU Directive 2004/39/EC
More informationInvestment Management & Funds Practice. AIFMD Client Memorandum
Investment Management & Funds Practice AIFMD Client Memorandum April 2012 INDEX PARAGRAPH PAGE 1 INTRODUCTION... 1 2 HOW DO YOU IDENTIFY THE AIFM?... 1 3 IS THE AIFMD APPLICABLE TO YOU?... 2 3.1 Scope
More informationPlus500CY Ltd. Order Execution Policy
Plus500CY Ltd. Order Execution Policy Order Execution Policy This Order Execution Policy forms part of the Client Agreements as defined in the User Agreement. 1. CONDUCTING BUSINESS 1.1. We have a general
More informationAIFMD investor information document Temple Bar Investment Trust PLC
AIFMD investor information document Temple Bar Investment Trust PLC Temple Bar Investment Trust PLC (the Company ) was incorporated in 1926 with the registered number 214601. The Company carries on business
More informationAIMA NOTE. Analysis of divergences between the EU Commission s draft regulation implementing the AIFMD and the ESMA advice
AIMA NOTE Analysis of divergences between the EU Commission s draft regulation implementing the AIFMD and the ESMA advice April 2012 Analysis of divergences between the EU Commission s draft regulation
More informationBerry Insurance Brokers
Berry Insurance Brokers Terms of Business - Personal Insurance F Berry (Leyland) Ltd trading as Berry Insurance Brokers,149 Towngate, Leyland, Preston, Lancashire, PR25 2LH is an independent broker. We
More informationTERMS OF BUSINESS AGREEMENT - INSURANCE BROKING
1. BROKER INFORMATION TERMS OF BUSINESS AGREEMENT - INSURANCE BROKING Stephenson s (2000) Ltd T/As Cooke & Mason, Manor House 3 Low Moor Road Lincoln LN6 3JY is an independent Chartered Insurance Broker.
More information2015 H1 European Cash Equity and ETF Broker Rankings. Calculated by Markit MSA
2015 H1 European Cash Equity and ETF Rankings Calculated by Markit MSA Markit is a leading, global financial information services company. Markit delivers over 40 products and services designed to reduce
More informationST IVES PLC ST IVES LONG TERM INCENTIVE PLAN 2010. Approved by shareholders of the Company on. Adopted by the board of the Company on
DISPLAY VERSION ST IVES PLC ST IVES LONG TERM INCENTIVE PLAN 2010 Approved by shareholders of the Company on Adopted by the board of the Company on The Plan is a discretionary benefit offered by St Ives
More informationHow to start a Hedge Fund
How to start a Hedge Fund How to start a Hedge Fund Introduction When setting up a hedge fund, you will need to consider the following matters: Jurisdiction Fund structure Eligible investors Authorisation
More informationFinancial Conduct Authority. Best execution and payment for order flow
Financial Conduct Authority Thematic Review TR14/13 Best execution and payment for order flow July 2014 Best execution and payment for order flow TR14/13 Contents 1 Executive summary 3 2 Introduction
More informationTerms and conditions of the New Generation Personal Pension SIPP Option execution-only stock broking and fund supermarket. Reference MPEN8/D 09.
Terms and conditions of the New Generation Personal Pension SIPP Option execution-only stock broking and fund supermarket Reference MPEN8/D 09.14 Contents Page Our appointed stockbroker 3 Responsibility
More informationSSAS Pension Trading Account
Stockbrokers SSAS Pension Trading Account Terms and Conditions 2 Important notice We instruct us to buy and sell investments held by you in respect of the SSAS. If you wish to use the Service, please complete
More informationHSBC Specialist Funds Limited. Short Duration Fixed Income Fund Supplement 2 November 2015
HSBC Specialist Funds Limited Short Duration Fixed Income Fund Supplement 2 November 2015 HSBC Specialist Funds Limited Short Duration Fixed Income Fund Supplement 2 November 2015 This document (the Short
More informationChapter 10 EQUITY SECURITIES RESTRICTIONS ON PURCHASE AND SUBSCRIPTION
Chapter 10 EQUITY SECURITIES RESTRICTIONS ON PURCHASE AND SUBSCRIPTION Restrictions on Preferential Treatment of Purchase and Subscription Applications 10.01 Normally no more than ten per cent. of any
More informationOrder Execution Policy
Order Execution Policy March 2015 Table of Contents 1. INTRODUCTION... 2 2. SCOPE AND SERVICES... 2 3. BEST EXECUTION... 7 4. EXECUTION VENUES... 10 5. MONITOR AND REVIEW... 11 6. CLIENT CONSENT... 11
More informationinvesting in the Company (including, without limitation, investment in securities and other interests in the Company);
The Trust Deed is a complex document and the following is a summary only. Recipients of this prospectus and all prospective investors should refer to the Trust Deed itself to confirm specific information
More informationORDER EXECUTION AND BROKER SELECTION POLICY - PROFESSIONAL - ING INVESTMENT MANAGEMENT
ORDER EXECUTION AND BROKER SELECTION POLICY - PROFESSIONAL - ING INVESTMENT MANAGEMENT 17 December 2013 INFORMATION SHEET Target audience: Employees of ING IM International (legally represented by ING
More informationRISK DISCLOSURE STATEMENT PRODUCT INFORMATION
This statement sets out the risks in trading certain products between Newedge Group ( NEWEDGE ) and the client (the Client ). The Client should note that other risks will apply when trading in emerging
More informationSTATUTORY INSTRUMENTS. S.I. No. 257 of 2013 EUROPEAN UNION (ALTERNATIVE INVESTMENT FUND MANAGERS) REGULATIONS 2013
STATUTORY INSTRUMENTS. S.I. No. 257 of 2013 EUROPEAN UNION (ALTERNATIVE INVESTMENT FUND MANAGERS) REGULATIONS 2013 2 [257] S.I. No. 257 of 2013 EUROPEAN UNION (ALTERNATIVE INVESTMENT FUND MANAGERS) REGULATIONS
More informationTransaction Cost Analysis and Best Execution
ATMonitor Commentary July 2011 Issue Transaction Cost Analysis and Best Execution 10 things you wanted to know about TCA but hesitated to ask Foreword This is not an academic paper on theoretical discussions
More informationTerms and Conditions
Terms and Conditions Contents 1 About Brooks Macdonald 3 2 The Client Agreement and commencement of Services 3 3 Understanding these Terms 3 4 Relationships with Professional Advisers 5 5 Client categorisation
More informationNavigating the Regulatory Maze. AIFMD Impact on Service Providers
www.pwc.com Navigating the Regulatory Maze Navigating the Regulatory Maze AIFMD Impact on Service Providers January 2011 AIFMD Impact on Service Providers The Alternative Investment Fund Managers Directive
More informationStocks & Shares ISA Transfer form Cazenove Investment Fund Company - B Class shares
Stocks & Shares ISA Transfer form Cazenove Investment Fund Company - B Class shares For your own benefit and protection you should read carefully Cazenove Investment Fund Company s Key Investor Information
More informationTerms and conditions of the smart + Trading Account from AXA Self Investor
Terms and conditions of the smart + Trading Account from AXA Self Investor Terms and conditions of the smart + Trading Account 02 Introduction These Terms and conditions of the smart + Trading Account
More informationBEST EXECUTION AND ORDER HANDLING POLICY
BEST EXECUTION AND ORDER HANDLING POLICY 1. INTRODUCTION 1.1 etoro (Europe) Ltd (the Company ) is an Investment Firm regulated by the Cyprus Securities and Exchange Commission ( CySEC ) with license number
More informationORDER EXECUTION AND CONFLICTS OF INTEREST MANAGEMENT POLICIES
ORDER EXECUTION AND CONFLICTS OF INTEREST MANAGEMENT POLICIES Best execution policy of Orey Financial, Instituição Financeira de Crédito, SA, hereinafter the "Company". 1 Introduction 1.1. This policy
More informationCLSA ASIA-PACIFIC SECURITIES DEALING SERVICES: AUSTRALIA MARKET ANNEX
CLSA ASIA-PACIFIC SECURITIES DEALING SERVICES: AUSTRALIA MARKET ANNEX IMPORTANT NOTICE CLSA Singapore Pte Ltd (ARBN 125 288 271, a company incorporated in Singapore) is permitted to provide certain financial
More informationKey Features of the Stocks and Shares ISA
Key Features of the Stocks and Shares ISA Copyright Notice This document is the property of Investment Funds Direct Limited and cannot be copied, modified, or stored on a computer system without the company
More informationBEST INTEREST AND ORDER EXECUTION POLICY
Page 1 of 8 Leverate Financial Services Ltd. (Regulated by the Cyprus Securities & Exchange Commission) BEST INTEREST AND ORDER EXECUTION POLICY 2015 Page 2 of 8 SUMMARY BEST INTEREST AND ORDER EXECUTION
More informationVIRGIN STOCKS & SHARES ISA CONDITIONS
VIRGIN STOCKS & SHARES ISA CONDITIONS 1 PLEASE MAKE SURE YOU READ THESE CONDITIONS AS THEY CONTAIN INFORMATION YOU NEED TO KNOW This agreement is governed by the Individual Savings Account Regulations
More information