Order Execution Policy
Introduction
Finanstilsynet (Danish FSA) requires a firm which provides portfolio management services to comply with the obligation to act in accordance with the best interests of its professional and retail clients when placing orders with other entities for execution that result from the decisions by the firm to deal in financial instruments on behalf of its client (“best execution”). The rules on best execution implement the requirements of the Markets in Financial Instruments Directive (“MiFID”).
Obligation to provide best execution
As part of the obligation Global Evolution A/S (“Global Evolution”) has in respect of best execution, we are required to provide our clients with this Disclosure Statement. This sets out an overview of the policy we have in place in order to ensure that we obtain the best possible results for our clients.
Execution factors
Subject to any specific instructions given by our clients, when placing orders on their behalf we will take all reasonable steps to obtain the best possible result for them by taking into account the following execution factors: price; costs; speed; likelihood of execution and settlement; size; nature; any other relevant consideration.
In the majority of cases we would typically expect that the most significant issue to be taken into account will be the total consideration to be paid or received in each case such that there will be greater weight on the price and costs associated with each trade. However, there will be occasions when other factors may be more important or relevant and, as discretionary managers, we may use our judgement and experience to give greater prominence to them. Execution of orders at a price other than the best price available at the prevailing time will not necessarily constitute a breach of the policy.
Global Evolution does not charge any commission for itself in respect of its discretionary investment management activities nor does it charge any transaction related commissions.
The relative importance of each of the execution factors will be determined by reference to the following characteristics:
• the client
• the classification of the client, including whether the client is retail or professional
• the client order
• the financial instruments that are the subject of that order
• the execution venues to which that order can be directed
To the extent that we have been specifically directed by a client to use a particular broker or execution venue, then Global Evolution is not required to take the steps mentioned above.
Execution venues
Our policy includes details of the various execution venues that we will use when placing orders with other entities for execution. These details primarily consist of brokers that we will use in respect of the various different instruments in which we may trade. Any execution venues which we may use, however, will be subject at all times to any relevant brokerage agreement(s) entered into by us and/or the client, as may be appropriate. The lists of venues to be used will be updated from time to time depending on the nature of any changes to the type of investments which we manage and in the light of experience. From time to time we may use execution venues that are not included on the list where we deem this to be appropriate in order to be able to continue to meet our obligation to obtain the best possible results for our clients.
In many circumstances, we may deal directly with a market maker rather than with a broker who is acting on an agency basis. For example, this would include situations where we make use of Direct Market Access systems or are dealing with an investment bank that is acting in a principal capacity as a market maker. We may also trade outside a regulated market or multilateral trading facility from time to time.
Client consent
We are required to obtain the prior consent of our clients to our execution policy. In addition, since we may also trade outside a regulated market or multilateral trading facility in respect of instruments admitted to trading by those means, we are also required to obtain our clients’ prior consent to this.
The required consents will be obtained by requiring our clients to sign and return a copy of the Agreement of which this Appendix forms part.
Monitoring and review
We will monitor on a regular basis the effectiveness of our execution policy and, in particular, the execution quality of the entities identified in that policy. Where the monitoring reveals the need for any changes or enhancements to be made, these will be implemented as appropriate.
We will review the execution policy on an annual basis and also whenever a material change occurs that affects our ability to continue to obtain the best possible result for our clients.
This order execution policy including any future changes will be available at www.globalevolution.com. Any changes take effect from when they are made public on www.globalevolution.com. Clients are therefore requested to keep themselves updated via Global Evolutions web page.
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Last update in May 2008