Order Execution Policy
As an investment firm which provides portfolio management services, Global Evolution Fondsmæglerselskab A/S and its subsidiaries (hereinafter “Global Evolution”) is required to act in accordance with the best interests of all clients when placing orders with other entities for execution that is a result of decisions by the firm to deal in financial instruments on behalf of such clients (“best execution”). These rules on best execution implement the requirements of the Markets in Financial Instruments Directive (“MiFID”) and the Danish Executive Order 811 as of June 30, 2011.
It is an a obligation on Global Evolution to provide its clients with its policy on best execution and as such this policy sets out an overview of the policies Global Evolution has in place to ensure that it obtains the best possible results for its clients.
The policy shall apply to the following financial instruments:
- Fixed income securities and money market instruments
- OTC derivatives, including but not limited to swaps and forwards
- Derivatives admitted to trading on a regulated market or multilateral trading facility (MTF), including but not limited to options and futures listed on a derivatives exchange
- Other instruments created by an intermediary.
3. Execution factors
Global Evolution will take all reasonable steps to obtain the best possible result for clients when placing or executing orders on their behalf. In doing so, Global Evolution will take into account the following execution factors: price, amount, costs, speed, likelihood of execution and settlement, nature or order and other relevant considerations. Clients may give specific instructions as to how orders, or a specific trade, should be handled, in which case Global Evolution may be prevented from obtaining best execution.
In the majority of cases Global Evolution will expect that the most significant matter to be taken into account will be the total consideration to be paid or received, hence there will be greater weight on the price and costs associated with each trade than the remaining factors. However, there may be occasions when other factors are more important or relevant and, as discretionary managers, we may use our judgment and experience to give greater prominence to such. 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 to its clients.
The determination of what is best execution will be based on the following:
- the client’s characteristics, including whether the client is classified as retail or professional
- the client order characteristics
- the characteristics of the financial instruments that are the subject of that order, and
- the characteristics of execution venues to which that order can be directed
Global Evolution is not required to take the steps mentioned above to the extent that a client has instructed the use of a particular broker or execution venue.
4. Trade aggregation and trade allocation
Global Evolution may aggregate a client order with orders for other clients if the aggregation of orders is overall perceived to be to the advantage of the clients whose orders are to be aggregated. The aggregation of orders could however be dis-advantageous to a client in relation to a specific order.
When aggregating orders, no client will be favored over any other client. Each client that participates in an aggregated order will participate at the average price for all Global Evolution’s transactions in that security with that counterpart on the given business day and transaction costs will be shared pro rata based on each client’s participation in the transactions.
If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the pre-trade allocation. If the aggregated order is partially filled, it will be allocated pro-rata among clients, subject however to allocation of a meaningful minimum size as determined by GlobalEvolution (which could result in a client receiving no allocation or a larger than pro-rata allocation) and to a minimum purchase size which may be imposed by an issuer in an offering.
5. Cross transactions
From time to time Global Evolution may seek to execute transactions between client accounts (including rebalancing trades between client accounts). Transactions between client accounts are not permitted if they would constitute principal trades or trades for which Global Evolution or its affiliates are compensated as counterparties.
To the extent that it is deemed to be in the best interest of both client accounts and it is reasonably considered to be in service of best execution to do so, transactions between client accounts may be completed, provided that an independent third party pricing source is used for such transactions and transactions are executed through a third party counterpart.
6. Counterparties and execution venues
The policy includes details of the various counterparties and execution venues that Global Evolution will use when placing orders with other entities for execution. These details primarily consist of counterparties that Global Evolution will use in respect of the various different instruments in which we may trade. Any counterparties and execution venues which may be used, however, will be subject at all times to any relevant brokerage agreement(s) entered into by Global Evolution and/or the client, as appropriate. The lists of approved counterparties and execution venues to be used will be updated from time to time depending on the nature of changes to the type of investments which are managed and in the light of selection criteria including:
- Institutions being subject to prudential supervision.
- Institutions comply with the best practice/best execution and investor protection rules under MifID or similar.
- Rating. A minimum rating of BBB- or similar is preferred, but counterparty below BBB- can be accepted. Most counterparties traded with have a minimum rating of A.
- Product offering. Counterparties with a broad product offering are prioritized.
- Research. The depth and quality of the counterparties’ analysts is continuously evaluated with respect to their ability and willingness to deliver real insight to the macroeconomic and political developments of emerging market countries and general market developments.
- Ability to consistently provide competitive prices and execution.
- The integrity, ethics and trustworthiness of the counterparty.
- Sufficient, competent counterparty personnel and support staff.
- The counterparty’s electronic and program trading capabilities and range of associated products.
- The efficient settlement of trades, including timely acknowledgement and correction of trade errors.
Global Evolution may deal directly with market makers where the company makes use of Direct Market Access systems or are dealing with an investment bank that is acting in a principal capacity as a market maker. Trading outside a regulated market or multilateral trading facility may also happen from time to time.
7. Monitoring and review
Global Evolution will monitor on a regular basis the effectiveness of its order execution policy and, in particular, the execution quality of the counterparties and execution venues used. Where the monitoring reveals the need for any changes or enhancements to be made, these will be implemented as appropriate. We will review the order 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. Changes and up-dates will be published on Global Evolution’s website and will come into effect from the day that they are published on the website.
This order execution policy including any future changes will be available from the front page of 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 Evolution’s web page.
8. Approved counterparties
The approved list of counterparties include the list of companies below, including all relevant subsidiaries and entities in the groups of the company: ABSA Bank, Banco Bilbao Vizcaya Argentaria S.A., Banco Santander, Bank of America Merrill Lynch, Bank of New York Mellon, Barclays Capital, BNP Paribas, Cantor Fitzgerald, Citigroup, Credit Suisse, Danske Bank, Deutsche Bank, Emerging Markets Bond Exchange Limited, Exotic Ltd, Freimark Blair, Frontera Capital, Goldman Sachs, Helaba Landesbank Hessen-Thüringen, ICBC Standard Bank, Industrial and Commercial Bank of China Financial Services LLC, HSBC, Iroko Securities, ING, Jefferies, Jyske Bank, JPMorgan, KAS Bank, Morgan Stanley, MUFG Securities, Nomura, Nordea Bank, Nykredit, MarketAxess Capital Limited, Oppenheimer & Co., Rand Merchant Bank, Royal Bank of Scotland, Rosbank, Seaport Global, SEB, Societe Generale, Standard Chartered, State Street, Stifel Nicolaus, TCX, UBS, Unicredit, VTB Capital.
This order execution policy including any future changes will be available at this website. Any changes take effect from when they are made public on this website. Clients are therefore requested to keep themselves updated via the Global Evolution website.