3.1 Saxo Capital Markets identifies and seeks to obtain the most favorable terms reasonably available when executing an order on behalf of a client.



Similar documents
PACIFIC PRIVATE BANK LIMITED S BEST EXECUTION POLICY (ONLINE TRADING)

SAXO BANK S BEST EXECUTION POLICY

BEST EXECUTION AND ORDER HANDLING POLICY

ORDER EXECUTION POLICY

BEST EXECUTION AND ORDER HANDLING POLICY

1. Definitions of Terms

Index CFDs. Index CFDs are traded without order fee on index level with the following spreads:

Stockbrokers. Supplemental Terms. International Trader

ORDER EXECUTION AND CONFLICTS OF INTEREST MANAGEMENT POLICIES

BEST INTEREST AND ORDER EXECUTION POLICY

Order Execution Policy. Version: 4.0 Last approved: August 2013 Last updated: August 2013 Policy owner: Compliance

Price list. Forex trading rates and conditions Contract for Difference (CFD) trading rates and conditions... 3

Price list. Forex trading rates and conditions. Contract for Difference (CFD) trading rates and conditions. Index CFD trading rates and conditions

TRADING STOCKS ON THE SAXOTRADER PLATFORM

Vontobel Trading Venues

TRADING STOCKS ON THE SAXOTRADER PLATFORM

MANDATORY PROVIDENT FUND SCHEMES AUTHORITY

Best Execution of equity securities

1.5. DELTASTOCK cannot execute orders on behalf of clients without their prior agreement with this Policy.

BEST INTEREST AND ORDER EXECUTION POLICY

Standard commissions. Index Tracker CFD spreads. Index-tracking CFD contract details (continuous)

If you experience or suspect any errors with your order, you should contact Galt & Taggart immediately.

Interactive Brokers Quarterly Order Routing Report Quarter Ending March 31, 2013

R.J. O'Brien (UK) Limited BEST EXECUTION POLICY

Order Best Execution Policy

Best Execution Policy for transactions in Financial Instruments

Vontobel Trading Venues

SUMMARY BEST INTEREST AND ORDER EXECUTION POLICY

The World Federation of Exchanges is an international association comprised of the world s leading bourses. Its membership includes:

LuxeMbOurG Trading CenTre LisT Annex 1 to the s pecial terms and conditions for securities transactions Valid as from 1 January 2011

EXECUTION POLICY FOR ORDERS IN RESPECT OF FINANCIAL INSTRUMENTS

The Power of Pairs Spread Trading Stock Index Futures

SUMMARY BEST INTEREST AND ORDER EXECUTION POLICY

Consultation Paper on Proposed Amendments to Specified Stock and Futures Exchanges. February 2011

SAXO CAPITAL MARKETS UK LTD - EQUITY ACTIVE TRADER Rates and Conditions, valid from 1 July 2015

LuxeMbOurG Trading CenT re LisT Annex 1 to the special terms and conditions for securities transactions Valid as from 1 september 2011

Professional Clients Mai A. Introduction. Helaba Best Execution Policy

Execution policy Effective from 15th June 2015

Order Execution Policy

Goldman Sachs s Standard Spot Foreign Exchange Terms of Dealing

Order Execution Policy

Total Value of Share Trading in 2007 (in millions of U.S.$) $1,298,315.0 $1,378, ,998 All Ordinary Price BME Spanish

TRADING CFDs ON THE SAXOTRADER PLATFORM

INTERACTIVE BROKERS LLC A Member of the Interactive Brokers Group

Date Produced: August 2005

Trading in International Equities For Professional Advisers only - not to be relied upon by retail clients

Citibank Europe plc Hungarian Branch Office BEST EXECUTION POLICY

PERFORMANCE STABILITY CONNECTIVITY TIME TO MARKET. A Bloomberg offering

BEST EXECUTION POLICY

Dated January 2015 Advanced Execution Services. Crossfinder User Guidelines Asia Pacific

RealTick Data. International Securities Exchange BVSP Level 1. NASDAQ OMX UTP Regional TSX Level 1

Pictet Asset Management: Summary of Best Execution Policy

EXANE GROUP EXECUTION POLICY

WEEDEN & CO. LP 145 MASON STREET GREENWICH, CT

AMEX MKT Order Imbalances Free Free. AMEX Options Depth of Book USD USD ArcaBook for Equities USD USD

Credit & Debit Card Payments User Guide

Execution Venues Traiding places provided by UBS Switzerland AG

A New Episode in the Stock Exchange Mergers Saga: Intercontinental Exchange (ICE)/New York Stock Exchange (NYSE)

The #1 portfolio simulation for university finance classes and trading rooms

Credit Suisse Asset Management Limited UK Order Execution Policy December 2013

Overview of Major World Exchanges Trading Hours

Plus500CY Ltd. Order Execution Policy

WGM Services Ltd Authorisation No: 203/13

FORM F1 Calculation of Excess Working Capital. Firm Name. Capital Calculation (as at with comparative figures as at )

Prices of AbleFeed REAL-TIME DATA SERVICES * Service may include an esignal Administration Fee

Hargreaves Lansdown Spread Betting/ Hargreaves Lansdown CFDs Trade & Order Execution Policy

2013 WFE Market Highlights

FEATURES LIST OF THE SYSTEMS FOR SMART ORDER ROUTING AND THE APPLICABLE TERMS AND CONDITIONS

Monthly Exchange Fees US Dollar

Form F1 Calculation of Excess Working Capital. Capital Calculation (as at with comparative figures as at )

Order Execution Policy

Identifying High Probability Forex Trades Using Median Lines, Trend Lines & Fibonacci Retracements Timothy Morge, President Blackthorne Capital

Market leading multi-bank/multi-asset trading platform, independent from market maker banks

FINRA and MSRB Issue Guidance on Best Execution Obligations in Equity, Options and Fixed Income Markets

Goldman Sachs Electronic Trading India: Algorithmic Trading. FIXGlobal Face2Face Electronic Trading Forum - India

Chapter II Transactions at Eurex Deutschland and Eurex Zürich (Eurex Exchanges)

The shift in equity shares trading pattern in terms of Number of Trades and Turnover

亞 洲 資 本 市 場 的 合 作 契 機 與 挑 戰 Capital Market Cooperation in Asia: To Do, or Not to Do

Best Execution Policy

RealTick Data. International Securities Exchange BVSP Level 1. NASDAQ OMX UTP Regional TSX Level 1

Interactive Brokers Order Routing and Payment for Orders Disclosure

GAIN Capital FOREX.com Australia Pty Limited EXECUTION POLICY for the Dealbook Suite of Platforms

February 22, 2015 MEMORANDUM

When trading Index-Tracking CFDs with G&T TRADER, you do not pay a separate commission. The only cost you will incur is the bid/ask spread.

A stock is a share in the ownership of a company. Stock represents a claim on the company s assets and earnings.

LUXEMBOURG TRADING CENTRE LIST

NEONET SECURITIES The European Specialist in Execution Services

Market Making for Exchange Traded Funds. Corporates & Markets

The economic analysis in the LSE/Deutsche Börse/Euronext merger inquiry

International Finance Prof. A. K. Misra Department of Management Indian Institute of Technology, Kharagpur

Guidance on Best Execution and Management of Orders

Stock Exchange Date Holiday / Event Settlement Information Trading Information Comment Moscow Exchange New Year's Day No Settlement No

J.P. Morgan Asset Management Institutional Order Execution Policy Disclosure

Stock Exchanges Holiday Schedule. Availability for Single Stock Futures Contracts for the remainder of 2014

SaxoTrader iphone App Quick Start Guide

RATES & CONDITIONS. 21 st September Forex CFDs Stocks Futures Contract Options Single Stock Options ETFs Bonds

NASDAQ Asia ex Japan Dividend Achievers TM Index Methodology

BEST INTEREST POLICY

Ch. 6 The Foreign Exchange Market. Foreign Exchange Markets. Functions of the FOREX Market

Summary of Scotiabank London Best Execution Policy

Transcription:

SAXO LEGAL SINGAPORE Saxo CAPITAL MARKETs Best Execution Policy 1

1. introduction 3. SAXO CAPITAL MARKETS APPROACH TO BEST 1. INTRODUKTION EXECUTION 1.1 1.2 1.3 1.4 1.5 2.1 This policy is not intended to create third party rights or duties that would not already exist if the policy had not been made available and it does not form part of any contract between Saxo Capital Markets (or any of its affiliates) and any client or prospective client. What follows is an overview on how trades and orders are executed, the factors that can affect an execution s timing and the way in which market volatility plays a part in handling orders when buying or selling a financial product. Upon acceptance of a client order and when there is no specific client instruction regarding the execution method, Saxo Capital Markets will endeavor to execute that order in accordance with the Best Execution policy. Nevertheless, whenever there is a specific instruction from a client Saxo Capital Markets shall execute the order following the specific instruction. In fact, any specific instructions from a client may prevent Saxo Capital Markets from taking the steps that it has designed and implemented in the execution policy to obtain the best possible result for the execution of those orders in respect of the elements covered by those instructions. This Policy is available to clients upon request and is also made available on our website at: (http://www.saxomar kets.com.sg). Saxo Capital Markets reserves the right to amend or supplement this Policy at any time. 2. FINANCIAL PRODUCTS TO WHICH THIS POLICY APPLIES The financial products to which this Policy applies are: Stocks, Bonds, Exchange Traded Funds, Futures, Foreign Exchange Forwards, Foreign Exchange Options and OTC securities (i.e. Contracts for Difference). Spot FX does not fall within the scope of this Policy. 2.2 The trading conditions of the above products are available on Saxo Capital Markets website: (http://www.saxomar kets.com.sg). 3.1 Saxo Capital Markets identifies and seeks to obtain the most favorable terms reasonably available when executing an order on behalf of a client. 3.2 To do this, Saxo Capital Markets relies on three basic components: (i) state-of-the-art technology for routing, monitoring and executing orders; (ii) careful consideration of the elements of order execution; (iii) regular and rigorous examination of the overall execution quality. 3.3 When executing a buy or sell order, Saxo Capital Markets always considers: the classification of the client as retail or professional; the nature of the client order; the characteristics of the financial instruments that are subject to that order; the characteristics of the execution venues to which that order can be directed. 4. THE ROLE OF TECHNOLOGY IN EXECUTING CLIENTS ORDERS 4.1 Saxo Capital Markets uses automated systems to route and execute client orders. When a client order is received by Saxo Capital Markets, it is automatically routed to an execution venue that Saxo Capital Markets believes will provide the best execution or kept in-house for products which Saxo Capital Markets through Saxo Bank, trades against its own proprietary desk (e.g. OTC products). 4.1.1 For listed securities (i.e. Cash Stocks and Futures), Saxo Capital Markets always routes orders to an exchange or to a third party for execution. 4.1.2 For OTC securities, Saxo Capital Markets may through Saxo Bank trade against its own proprietary desk or will route the orders to other market-maker firms. Orders are only sent to firms that comply with limit order display and Manning limit order protection rules. Many of these firms also provide automated executions for orders. 4.1.3 For FX forwards and FX options client orders are automatically routed internally by Saxo Capital Markets against Saxo Bank s own book in its capacity as market maker. 2

5. THE ELEMENTS OF OUR BEST EXECUTION POLICY 6. REGULAR REVIEW OF EXECUTION QUALITY AND OF EXECUTION VENUES 5.1 Routing determinations are mainly based on four criteria and are regularly reviewed by Saxo Capital Markets. Hence to determine the best way to execute an order for a client Saxo Capital Markets takes into consideration: 6.1 Saxo Capital Markets regularly evaluates the overall quality of its order executions. Saxo Capital Markets studies the quality of executions for listed and OTC retail market orders. 5.1.1 5.1.2 5.1.3 5.1.4 5.1.5 5.2 Speed and Likelihood of the Execution. Due to the levels of volatility affecting both price and volume, Saxo Capital Markets seeks to provide client orders with the fastest execution reasonably possible. Price Improvement and Overall Consideration of Costs. Orders in OTC and listed securities are routed to market makers and/or market centers where opportunities for price improvement exist. The criteria to be used by other market-makers and/or market centers include: automatically matching incoming market and limit orders to pending limit orders, crossing transactions where price improvement is offered to one or both sides of the trade. Size Improvement. In routing orders, Saxo Capital Markets seeks markets that provide the greatest liquidity and thus potential for execution of large orders. Saxo Capital Markets also seeks opportunities for client orders to benefit from order-size guarantees offered by exchanges and other dealers. Overall Execution Quality. When determining how and where to route or execute an order, Saxo Capital Markets traders draw on extensive day-to-day experience with various markets and market makers, focusing on prompt, sequential and reliable execution. Clients specific instructions. Saxo Capital Markets will always execute client orders in accordance with the instructions given by that client or on its behalf. Consequently, if a client requires an order to be executed in a particular manner and not in accordance with Saxo Capital Markets best execution principles set forth herein, the client must clearly state his/her desired method of execution when he/she places the order. To the extent that a client instruction is not comprehensive, Saxo Capital Markets will determine any non-specified components of the execution in accordance with these best execution principles. Saxo Capital Markets invites the clients to bear in mind that the duty of best execution not only relates to price but also involves the consideration of various factors including cost, speed and likelihood of execution and settlement. Even if a trade appears not to have been executed at the best possible price, it does not necessarily constitute a violation of the duty of best execution. 6.2 Saxo Capital Markets Management periodically evaluates the execution quality and makes recommendations regarding order routing practices. 7. LIST OF EXECUTION VENUES CURRENTLY CHOSEN 7.1 Saxo Capital Markets through Saxo Bank uses the regulated markets when trading stocks and CFDs as chosen venues for trading. All trades are benchmarked to the pricing and liquidity in the primary regulated market for a selected company. 7.2 Stock brokers are used as order routing facilitators and in some cases an order will be filled internally or at another trading venue than the regulated exchange, if this will result in a better execution of the trade than if it was routed to the regulated market. 7.3 The venues currently chosen are: American Stock Exchange, Euronext Amsterdam, Australian Stock Exchange, Athens Stock Exchange, Euronext Brussels, OMX Copenhagen, Frankfurt/Xetra Stock Exchange, Hong Kong Stock Exchange, OMX Helsinki, Euronext Lisbon, London Stock Exchange SETS Markets, Milano Stock Exchange, NASDAQ Global Markets, NAS- DAQ Capital Markets, New York Stock Exchange, Oslo Stock Exchange, Euronext Paris, Singapore Exchange Securities Trading Limited, Sistema De Interconexion Bursatil Espanol, OMX Stockholm, Swiss Exchange, Tokyo Stock Exchange, Wiener Börse (Vienna) Stock Exchange SWX Europe (formely Virt-X), Warsaw Stock Exchange, Electronic Chicago Board of Trade, Eurex, Euronext Derivatives, Globex, ICE Futures Europe, ICE Futures U.S. (NYBOT), Borsa Italiana SpA, Spanish Official Exchange Osaka Securities Exchange, Sydney Futures Exchange Corp. Ltd., Singapore Exchange Derivatives Trading Ltd., OMX Stockholm, Tokyo Stock Exchange. 7.4 As order routing vendors Saxo Capital Markets through Saxo Bank uses: Goldman Sachs, Dresdner Kleinwort Wasserstein, Deutsche Bank, Lehman Brothers, Marex Financial and UBS. 3

8. PRICE VOLATILITY 8.1 Volatility is one factor that can affect order execution. When clients place a high volume of orders with brokers, order imbalances and backlogs can occur. This implies that more time is needed to execute the pending orders. Such delays are usually caused by the occurrence of different factors: (i) the number and size of orders to be processed, (ii) the speed at which current quotations (or last-sale information) are provided to Saxo Capital Markets and other brokerage firms; and (iii) the system capacity constraints applicable to the given exchange, as well as to Saxo Capital Markets and other firms. 8.2 The client s orders may, at the discretion of Saxo Capital Markets but still in compliance with the best execution principles, be aggregated with Saxo Capital Markets own orders, orders of any of Saxo Capital Markets associates and/or persons connected with Saxo Capital Markets (including employees and other clients). Furthermore, Saxo Capital Markets may split the client s orders as well as aggregate orders before executing such. Although orders will only be aggregated or split where Saxo Capital Markets reasonably believes it to be in the overall best interest of its clients, aggregation and split may on some occasions result in the client obtaining a less favorable price than if the client s orders had been executed respectively separately or mutually. In such case, Saxo Capital Markets gives priority to factors affecting execution other than simply price, like the overall consideration of costs or the size and nature of the order or the likelihood of execution and settlement. 8.3 Electronic orders are not always executed simultaneously; some orders placed through online trading systems may be sent over the internet to an employee, who then determines where to route the order for execution. When high traffic in electronic orders causes a backlog, Saxo Capital Markets, as well as market makers to which orders are sent for execution, must sometimes discontinue normal automatic execution procedures and turn to manual execution, leading to further delay. 8.4 In order to minimize such a risk, Saxo Capital Markets has in place procedures and arrangements which to the furthest extent possible provide for the prompt, fair and expeditious execution of client orders. 9. EFFECTS ON ORDER EXECUTION Execution at a substantially different price from the quoted bid or offer or the last reported sale price at the time of order entry, as well as partial executions or execution of large orders in several transactions at different prices. Delays in executing orders for securities that Saxo Bank Group must send to external market maker and manually routed or manually executed orders. Opening prices that may differ substantially from the previous day s close. Locked (the bid equals the offer) and crossed (the bid is higher than the offer) markets, which prevent the execution of client trades. 10. ALTERNATIVE TYPES OF ORDERS 10.1 Given the risks that arise when trading in volatile markets, you may want to consider using different types of orders to limit risk and manage investment strategies. 10.1.1 Market order. With a market order the client instructs a broker to execute a trade of a certain size as promptly as possible at the prevailing market price. Financial institutions are required to execute market orders without regard to price changes. Therefore, if the market price moves significantly during the time it takes to fill a client s order, the order will most likely be exposed to the risks outlined above, including execution at a price substantially different from the price when the order was entered. Certain exchanges* do not support market orders. If you place a market order in these markets, Saxo Bank Group will automatically translate the order to an aggressive limit order within a certain percentage limit in the money **. It is the clients own responsibility to check if the order is traded in the market after order entry. If you experience or suspect any errors with your order you should contact Saxo Capital Markets immediately. *Exchange **Percentage Limit American Stock Exchange (AMEX) 2.50% Australian Stock Exchange (ASX) 1% Athens Stock Exchange (AT) 2% Oslo Stock Exchange (OSE) 2.50% OMX Copenhagen (CSE) 2.50% OMX Helsinki (HSE) 2.50% OMX Stockholm (SSE) 2.50% Singapore Exchange (SGX-ST) 1% 9.1 Clients should be aware of the following risks associated with volatile markets, especially at or near the open or close of the standard trading session: Some of our execution brokers may choose to translate market orders on various markets into aggressive limit orders 3% in the money. This is often a result of internal compliance requirements applied to protect clients from 4

bad fills. Saxo Capital Markets cannot be held responsible for missing fills due to such translation performed by third party execution brokers. 10.1.2 Limit order. With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future. Limit orders may be routed to an exchange without human intervention. 10.1.3 Stop order. Different from a limit order, a stop order allows selling below the current market price or buying above the current market price if the stop price is reached or breached. A stop order is therefore a sleeping order until the stop price is reached or breached. When the stop price is reached or breached, the stop order is converted to a market order. See section 10.1.1 for market orders. 10.1.4 Trailing Stop Order. The trailing stop order is a stop order as described in 10.1.3 but the trailing stop price moves according to parameters set by the client. This way the trailing stop can be used to sell if price drop more then a specified distance from the highest price traded or to buy if the price trades above a set level from the lowest traded price. 11. SAXO CAPITAL MARKETS GENERAL BUSINESS TERMS 11.1 Saxo Capital Markets Best Execution policy specifies the terms and conditions that already constitute an integral part of its General Business Terms. Hence the policy is to be read and understood in light of the General Business Terms. 5

S A X O L E G A L S I N G A P O R E This policy is effective from April 1, 2009 and shall remain effective until a more recent version is released. The prevailing version of the policy is always available at www.saxomarkets.com.sg SERIOUS TRADING. WORLDWIDE. 6 SAXO CAPITAL MARKETS PTE. LTD. Co. Reg. No.: 200601141M 3 Church Street # 30-00 Samsung Hub Singapore 049483 Main Line: +65 6303 7800 Fax: 65 6303 7808 Web: www.saxomarkets.com.sg