The policy applies to the institutional clients of ANPHIKO Asset Management S.A. and to the execution of orders involving the following financial instruments: bonds and money market instruments.
ANPHIKO Asset Management will execute client orders as an agent.
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.
The execution factors to be taken in to account when executing client orders are as follows:
any other consideration relevant to the execution of the order.
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:
A list of execution venues at which we may execute a client order is set out below, although it is not exhaustive. It includes those venues on which we are most heavily reliant in order to achieve our aim of consistently obtaining the best possible result for the execution of client orders, i.e.:
The above list may change from time to time.
Subject to specific instructions from the client, 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 above may also be influenced by other additional criteria, although this is always conditional on obtaining the best possible result for our clients.
These additional criteria include:
Notwithstanding the above, ANPHIKO Asset Management reserves the right to execute a client order using a method or venue other than the methods or venues that we have specified, 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.
Where a client gives a specific instruction for the execution of a client order, the order will be executed in accordance with those instructions. The client should be aware that providing the instruction may prevent us from taking some of the aforementioned steps to obtain the best possible result for the execution of the 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.
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:
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.
MiFID – 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.