Best Execution Policy

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The Company, since it has no direct access to market places, does not physically execute orders itself and uses other entities to fulfil this function. These entities, in turn, are also required to comply with the requirements of MiFID. Consequently, the trading venues through which all orders will be placed will be in accordance with the requirements set out by MiFID.

The Company acts in the best interests of the UCITS it manages when it places orders for execution with other entities, within the context of managing the portfolios. Thus, all reasonable measures are taken to achieve the best possible result for the UCITS’s taking into account price, cost, speed, size and type of order.

Large trades, particularly those involving financial instruments where trading volumes are limited, can move prices in the market against the interests of the UCITS. In these circumstances, a series of partial orders over a period of time are considered and can provide a better overall result than one large order. On the other hand, some financial instruments do not trade as frequently as others and/or volumes may be limited. In markets lacking sufficient liquidity, Best Execution may be limited to placing one large order.

For equities, if the securities are listed on more than one securities exchange, the Company places the order on the securities exchange most likely to offer the best price on a consistent basis (mostly on the Primary Market) as the bid and offer prices guarantee a higher turnover in terms of number of trades and volume and this ensures best execution for our clients.

Where clear cases of poor execution are identified, the Company will investigate promptly and take appropriate remedial action where necessary, which include requiring the executing broker to amend the transaction price if appropriate.