PAM's Best Execution Policy

Information about Pictet Asset Management's Best Execution Policy.

1. Scope

The policy applies to the Professional Clients of Pictet Asset Management Limited (PAM Ltd) and Pictet Asset Management S.A. (PAM SA) and to the execution of orders in the following Financial Instruments:

Equities
Bonds
Money Market Instruments
Exchange Traded Derivatives
OTC (Over the counter) Derivatives
Forward Foreign Exchange / NDF
Collective Investment Schemes

PAM Ltd and PAM SA will execute Client Orders as agent except for Bond OTC Derivatives where PAM SA may act as principal.

2. Order execution

When executing Client Orders we will act in the best interests of our clients at all times and will take all reasonable steps to obtain the best possible result for our clients taking into account the criteria and factors set out below, subject to any instruction given by our client (see section 7).

3. Best execution factors

The execution factors to be taken in to account when executing Client Orders are as follows:

Price
Costs
Speed
Likelihood of execution
Likelihood of settlement
Size of the trade
Nature of the trade
Any other consideration relevant to the execution of the order.

4. Best execution criteria

When we execute an order on behalf of our clients, we will determine the relative importance of the aforementioned best execution factors based on our experience and judgement, per product type, with respect to available market information at the time and taking into account the following best execution criteria:

The characteristics of the client (including its categorisation)
The characteristics of the Client Order
The characteristics of the Financial Instruments which are the subject of the Client Order
The characteristics of the Execution Venues to which the Client Order can be directed.

5. Execution Venues

The list of execution venues on which we may execute a Client Order is set out below, but it is not exhaustive. It includes those venues on which we place significant reliance in our aim to obtain on a consistent basis the best possible result for the execution of Client Orders.

Broker execution – placing the order with a third party, including an affiliate, with whom we have entered into an agreement for handling Client Orders. This includes, but is not limited to, agency sales trading, algorithmic trading, capital commitment, and scheme operator.

Crossing the order with a recognized third party crossing network with whom we have entered into an agreement for handling Client Orders. With client consent, this would include a matching order from another client.

Liquidity Aggregator – Using a recognized third party tool for price discovery and execution with pre-determined list of third parties.

On Exchange – directly with a Regulated Market (Direct Market Access) or Multilateral Trading Facility (MTF) or using a third party participant with whom we have entered into an agreement for handling Client Orders.

The above list may change from time to time, and for details of the current list of Execution Venues, please refer to the section on the right-hand side column.

6. Execution Venue Selection

Subject to any specific client instructions (see section 7 below), the selection of an Execution Venue for the execution of an order will be based solely upon the Execution Criteria and Execution Factors referred to above.

However, the decision to use any of the venues set out in section 5 may also be influenced by other additional criteria, although this is always conditional upon obtaining the best possible result for our clients.

These additional criteria include:

Quality of research
Financial Screening
Suitability of counterpart
Liquidity concentration

Notwithstanding the above, PAM Ltd and PAM SA reserves the right to execute a Client Order using a method or venue other than the methods or venues that we have indicated, where we consider this to be in the best interests of our client. In such cases, we will endeavour to execute based on the same best execution principles as summarised in this document.

7. Client Instructions

Where a client gives a specific instruction for the execution of a Client Order then the order will be executed in accordance with those instructions. The client should be aware that providing that instruction may prevent us from taking some of the aforementioned steps to obtain the best possible result for the execution of that Client Order (to the extent of the instructions). We will be treated as having satisfied our best execution obligation in respect of the part or aspect of the order to which the instructions relate.

8. Order Handling

We are required to execute Client Orders in an expeditious and fair manner for all clients.

Client orders will be aggregated with other Client Orders, if:

the characteristics of the Client Order make them suitable for aggregation and
if in our opinion the aggregation of Client Orders will not work to the disadvantage of any client and
we comply with our order allocation procedures.

9. Monitoring and Review

We will review this best execution policy at least annually and whenever a material change occurs that affects our ability to continue to obtain the best results for our clients. Any material changes will be posted on this website.

We will monitor the effectiveness of our best execution policy and execution arrangements to identify and where appropriate correct any deficiencies. This will include an assessment of whether the Execution Venues included in this policy continue to provide the best possible result for our clients.

10. Definitions

MiFID – the directive 2004/39/EC Markets in Financial Instruments

Professional Clients – as per Annex II of MiFID

Financial Instruments – as listed in section 1

Client Orders – an instruction to buy or sell a Financial Instrument, including orders initiated by PAM Ltd or PAM SA as a discretionary investment manager.

Execution Factors – as listed in section 3

Execution Criteria – as listed in section 4

Execution Venue – as listed in section 5

Derivatives – options, futures, financial contracts for difference and swaps on underlying equity, bond or money market instrument, forward rate agreements and other derivative contracts related to securities, currencies, interest rates or yields, indices or commodities.

NDF – Non-deliverable Forward Foreign Exchange contract

MiFiD Contact

Execution

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