SSGMIL Order Execution Policy 2017 Jan

SSGMIL Order Execution Policy 2017 Jan

Order Execution Policy State Street Global Markets International Limited State Street Global Markets International Limited (‘SSGMIL’) provides trading services in equities, fixed income, futures and options, and foreign exchange within State Street Global Markets, a division of State Street Corporation, one of the world’s leading providers of financial services to institutional investors. When executing or transmitting your order(s) we take all reasonable steps to provide you with the best possible result on a consistent basis by taking into account any specific instructions 1 we receive from you and a range of execution factors in accordance with the principles described in this Order Execution Policy (‘Policy’). 1. Scope Our obligation to consistently provide you with the best possible result in accordance with the Policy applies in respect of any order you may give us in any financial instrument as defined by the Markets in Financial Instruments Directive (‘MiFID’), regardless of whether the execution takes place on a venue in the European Economic Area, an equivalent venue in a third country or on an over-the-counter basis. The Policy only applies where we have categorised you as a Professional client and owe you a contractual or agency obligation. The duty to provide best execution does not apply to transactions involving Eligible counterparties and therefore where we have categorised as such the Policy will not apply. SSGMIL does not deal with Retail clients. 2. Execution factors When executing and/or transmitting your orders we will take into account different execution factors including, but not limited to: ° Price; ° Costs; 1 See Section 4 below. State Street Global Markets International Limited Pa ge 1 ORDER EX ECUTION POLICY ° Speed; ° Likelihood of execution; ° Likelihood and reliability of settlement; ° Size; ° Nature of an order; and ° Other relevant considerations, such as: o Liquidity (relative order size or financial instruments underlying liquidity); o Market Impact; o Nature of the available execution venue (regulated versus unregulated market venue);and o Nature of the financial instrument. Our traders use their experience and judgment to determine the importance of each of these factors on a case by case basis to assist in achieving of the best possible result on a consistent basis in respect of your orders. 3. Execution criteria In determining the relative importance of the execution factors, when we are executing and/or transmitting your orders, we will take into account the following execution criteria: ° The extent to which we believe you are relying upon us to provide you with the best possible result; ° The characteristics of your order(s); ° The characteristics of the financial instrument; ° The characteristics of the available execution venues; and ° If your order is subject to any specific instructions that you have given us. 4. Specific client instructions Whenever you have given us a specific instruction regarding an order or an aspect of an order, we will execute or transmit such order or aspect thereof following your specific instruction. We will then apply this Policy and take reasonable steps to obtain the best possible result for the elements of the order not subject to or limited by your instructions. State Street Global Markets International Limited Pa ge 2 ORDER EX ECUTION POLICY In the event that we feel that your instructions may have become unduly limiting to the execution of your order, such as where market conditions have changed, we would aim to discuss this with you and agree a suitable course of action. 5. Relative importance of the execution factors While price is generally a key factor, the overall value to a client of a particular transaction may be affected by the other factors listed above. The relative importance of each of the factors will differ depending on: ° The characteristics of your order; ° The characteristics of the financial instruments to which the order relates, as certain instruments are easier to execute than others; ° The characteristics of the execution venue(s) to which we are able to direct and execute your order and the conditions for safe settlement associated with those venues; and, ° Consideration of potential market impact, taking into account any instructions you might give us on participation levels and having analysed the liquidity and relative size of the order. 6. Further information on asset-class specific execution arrangements a. Equity instruments SSGMIL’s preferred method of executing your orders for equity instruments is for our traders to directly execute your order in the market as your agent using a combination of techniques ranging from manual to fully automated. We may also use smart order routers and algorithms in order to allow us to work your order(s) across multiple venues in the most efficient manner possible; we may also cross your order with another SSGMIL client or with another market counterparty or liquidity provider. Where facilities for direct execution are not available to us we will transmit your order to a suitable third-party or affiliated broker for execution 2. In such cases we will closely monitor the performance of the order in so far as is possible and will apply the principles described in section 7 of the Policy. In Appendix I of this Policy we provide you with an indicative list of the execution venues and illustrate our access arrangements, broadly these comprise the following categories of venue: ° Regulated markets and third country equivalents; ° Multilateral trading facilities (‘MTF’) and third country equivalents; 2 Please refer to Appendix I and see further in section 7 of this Policy. State Street Global Markets International Limited Pa ge 3 ORDER EX ECUTION POLICY ° Systematic internalisers; ° Internal and external crossing networks; and ° Market-makers, brokers, banks and other liquidity providers. You may of course instruct us to execute your orders using particular venues or combinations thereof. Subject to regulation and acceptance by SSGMIL, you may instruct us to direct your order to specific counterparties for execution. From time-to-time we may determine that it is beneficial to your order to execute it outside of a regulated market or MTF. Provided that you have given us your express prior consent and we believe it is consistent with this Policy to do so, we will execute your orders in such a manner. b. Fixed Income instruments SSGMIL typically executes your orders in fixed income instruments directly with other market counterparties (also known as dealers), because the use of trading venues is traditionally limited in fixed income markets. When seeking prices from such market counterparties we will look to obtain quotes from the key dealers for the particular instrument and would aim to gain at least three quotes where the instrument permits this and rarely more than five. There may be limited circumstances where, based on our expertise and judgment, your best interests may be better served by seeking prices from fewer or more market counterparties. The choice of counterparties varies based on the specific instrument. When selecting counterparties to seek prices from, in addition to the execution factors, we will consider the following characteristics of available counterparties: ° Electronic execution capability and ability to quote a market via Bloomberg functionality; ° The quality of indicative bids and offers and associated spreads; ° Previous executions performed with the counterparty; ° Status of the counterparty as a: o lead manager of the applicable issuance of the instrument; and/or, o known specialist in the instrument or sector. c. Futures and options In the absence of specific instructions, when we are executing or transmitting your orders in futures, we exercise our own discretion, based on our experience, judgment, and the nature of your order(s) to provide you with the best possible result and we take into account the following execution factors: State Street Global Markets International Limited Pa ge 4 ORDER EX ECUTION POLICY ° Price; ° Market impact; ° Size of the order; ° Speed/ likelihood of execution; ° Market depth and liquidity in the contract; and, ° Any specific instructions you may give us.3 d. Foreign Exchange SSGMIL will typically transmit your orders in foreign exchange derivatives for execution to a suitable third- party or affiliated broker-dealer for execution 4, subject to jurisdiction. SSGMIL acts as your agent; however, the relevant third-party or affiliate may become your counterparty to the trade, depending on the specifics of the transaction. Additionally, at your request we will route your orders to a specific counterparty of your selection. When deciding where to transmit your orders, SSGMIL will act in your best interests when exercising our professional judgment to select an affiliate or third-party dealer based on our assessment of that firm’s ability to satisfy the various execution factors related to your order and taking into account any instructions you may have given us. Finally, in respect of any orders in foreign exchange which do not constitute a financial instrument (i.e. spot contracts and certain forward contracts), whilst the obligation for best execution of orders under MiFID does not apply, we will seek to apply the principles of this Policy as we believe this serves your general best interests. 7. Other important matters a. Use of third-parties and affiliates In order to gain access to certain markets where we do not have a membership

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