BEST EXECUTION POLICY DISCLOSURE STATEMENT
This disclosure statement by Singapore Consortium Investment Management Limited (“SICIM”) provides relevant customers with information on order execution as required under the Monetary Authority of Singapore (“MAS”) Notice on Execution of Customers’ Orders (SFA 04-N16). It summarises our Best Execution Policy (“Policy”) and is provided to our clients so that they are made aware of the approach taken by us to achieve best execution.
SICIM is committed to take all sufficient steps to obtain the best available terms under the relevant circumstances when executing transactions on clients’ behalf in the types of financial instruments set out in this Policy.
Scope of the Policy
The Policy covers trading by SICIM in the following financial instruments:
• Equities: including shares and depositary receipts;
• Debt instruments: including money market instruments and corporate bonds;
• Derivatives: including interest rate derivatives, credit derivatives, currency derivatives, equity derivatives, and commodities derivatives; and
• Units or shares in collective investment schemes.
Application of Execution Factors
In seeking to achieve best execution with respect to a particular order, SICIM will take into account relevant factors including the following:
• price: this is the price a financial instrument is traded at;
• costs: this includes all fees and costs related to order execution, including implicit costs such as possible market impact, and explicit costs such as broker fees;
• speed: this is the time it takes to execute a transaction;
• likelihood of execution and settlement: this is the likelihood that we will be able to complete the transaction and that the transaction will settle;
• size: this is the size of the transaction; and
• nature of the transaction or any other consideration relevant to the execution of the transaction: this is how the particular characteristics of a transaction can affect best execution.
SICIM will determine the relative importance of each of these execution factors by using our commercial judgment and experience in light of market information reasonably available and taking into account a number of criteria, namely:
• The investment intent of the order;
• The characteristics of financial instruments that are subject to that order, e.g., equity or debt instrument;
• The types of venues through which dealing can be carried out;
• The characteristics and nature of the client order, including whether any specific instructions are given;
• The categorisation of SICIM’s clients; and
• Market conditions, such as the degree of liquidity and volatility in the market.
When placing an order with a broker for execution, SICIM will consider not only these factors and criteria but also the broker’s ability to fulfil the obligations to seek best execution.
Order Aggregation and Cross Trades
When SICIM deems the purchase or sale of the same security to be in the best interest of two or more of its portfolios, it may, but shall be under no obligation to, aggregate to the extent permitted by applicable law and regulations the securities to be purchased or sold in order to seek more favourable prices or more efficient execution, or to take steps to ensure fairness across our clients. In relation to particular orders, the effect of aggregation may work to your disadvantage, although all reasonable steps are taken to protect the interests of all clients. In particular, we only aggregate orders where we consider that such aggregation should work overall to the benefit of all clients whose orders are to be aggregated.
On rare occasions, SICIM may decide it is in the best interests for client accounts under its discretion to transact in a financial instrument with one another, which is also called a “cross transaction.” Cross transactions between accounts may be possible depending upon clients’ guidelines.
Venue Selection
When placing your orders with or transmitting your orders to execute, SICIM will take all sufficient steps to obtain on a consistent basis the best available result for its clients. For each transaction, SICIM considers the importance of the execution factors when choosing an execution venue and method of trading. In meeting our obligation to take all sufficient steps to obtain on a consistent basis the best available result for the execution of clients’ orders, SICIM may use a wide variety of trading venues.
Client Specific Instructions
If you provide SICIM with a Specific Instruction in relation to an order, SICIM will follow that instruction so far as is reasonably possible when executing the trade. By following your Specific Instruction, we will have satisfied the obligation to provide you with best execution in relation to that transaction or in relation to the part or aspect of the order to which your instructions relate. However, where you have given us a Specific Instruction that covers only one part or element of an order, we will still owe you best execution in relation to the rest of the order (i.e., the part not covered by the Specific Instruction). Examples of such instructions may include but are not limited to requests to execute on a particular venue or type of venue. You acknowledge that a Specific Instruction from you may prevent SICIM from taking the steps that we have designed and implemented in the Policy to obtain the best available result for the execution of those orders in respect of the portion of the trade covered by your Specific
Instruction.
Fees and Costs
Otherwise than as explicitly agreed with you from time to time, SICIM will not apply any additional SICIM fees and costs for order execution, but we will pass on the fees, costs and charges applied by third parties such as brokers, dealers and execution venues.
Monitoring and Reporting
SICIM has adopted a number of procedures to ensure compliance with the Policy. We will review our order execution arrangements and the Policy whenever a material change occurs that affects our ability to obtain the best available result for the execution of your orders on a consistent basis. We will notify you of any material changes in writing from time to time. A change is to be considered material where its disclosure is necessary to enable the client to make a properly informed decision in relation to the Policy as it applies to that client’s trades. In these cases, SICIM will reissue the Policy to clients and seek one-way deemed consent to those changes.
Last updated May 2021