1. Scope

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.

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.

3. Best execution factors

The execution factors to be taken in to account when executing client orders are as follows:

• price
• cost
• 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

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.:

• 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 operators.
• Crossing the order with a recognised 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 recognised third party tool for price discovery and execution with a 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.

6. Execution Venue Selection

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:

• quality of research
• financial screening
• suitability of counterpart
• liquidity concentration

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.

7. Client Instructions

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.

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:

• authorised by the client
• the characteristics of the client orders make them suitable for aggregation and
• if in our opinion the aggregation of client orders will not be 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 – 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.