This disclosure statement summarises PineBridge Investments’ best execution policy and is provided by PineBridge Investments Singapore Limited (“the Manager”) to clients so that they are made aware of and receive key information on how the Manager seeks to achieve best execution for its clients. The Manager may update this disclosure statement from time to time.
The Manager provides discretionary investment management and advisory services to its clients, during the course of which it will execute orders on behalf of clients when dealing in the client’s investments.
The Manager has a fiduciary duty to seek best execution when effecting transactions on behalf of its clients and also require that any counterparty, with whom it places an order, provides the clients with best execution. To fulfill this obligation, the Manager will not only seek for each transaction the most favorable commission costs or price under the circumstances, but also the best qualitative execution, subject to any limitations placed by the client on the manner in which the Manager executes the transaction, e.g. limit order. The Manager will consider a number of factors, described further below, in choosing and evaluating executing counterparty in light of its best execution obligations.
The Manager’s best execution policy applies to financial instruments for which the Manager trades, including but are not limited to:
Where the Manager executes client’s orders, it will ensure that orders are:
When the Manager deems the purchase or sale of the same security to be in the interest of two or more of its portfolios, it may, 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 its clients. The Manager only aggregates orders where it considers that such aggregation should work overall to the benefit of all clients whose orders are to be aggregated. The executed orders are allocated to the clients fairly and equitably.
In the absence of specific instructions from clients, the following execution criteria will be taken into account by the Manager for the purpose of determining best execution:
The Manager will use its market knowledge and experience, together with an assessment of current market conditions, to assess each execution criteria for each client order. The objective being the best possible execution result for each client order.
The Manager will generally merit a higher relative importance to price in obtaining the best possible result for clients. Liquidity in the market will also count as a significant factor. However, under certain circumstances the Manager may decide that other factors are more important in determining the best possible execution result for the client. For example, for some instruments price volatility may mean the timeliness of execution is a priority, whereas in other markets that have low liquidity the fact of execution may itself constitute best execution. The relative importance of each factor will be determined using the following criteria:
Client orders will ordinarily be carried out via placement of the order with a counterparty (typically an executing broker) and thereafter will be executed by the counterparty selecting an appropriate execution venue.
The Manager will endeavour to employ the following considerations for this selection process for each of the relevant execution venues chosen:
The Manager’s executing brokers may choose one or more of the following venue types when executing orders such as regulated market/exchange, multi-lateral and organised trading facilities, third party brokers, counterparties and/or affiliates acting as a Market Maker, or other liquidity providers.
For some financial instruments, there may be only one possible execution venue. The Manager takes the view that the counterparty has provided the best possible result in respect of venue for these types of financial instrument.
Where a client provides specific instruction either in relation to an order, or any particular aspect or part of that order, including direction to execute on a particular venue, the Manager will ensure execution of the order in accordance with those instructions.
Clients are required to provide specific instructions to the Manager in writing and may be required to further clarify any instructions provided. Provision of specific instructions may prevent the Manager from compliance with the Policy. In following instructions, the Manager will be deemed to have taken all reasonable steps to provide the best possible result in respect of the order or aspect of the order covered by the specific instructions.
In cases where the Manager does not owe a duty of best execution due to specific instructions or other circumstances, it will however still be required to treat the client fairly, act in the best interests of the client and to appropriately manage conflicts of interests.
The Manager utilizes preferred brokers who have the skills, resources and capabilities to provide best execution and conducts independent due diligence prior to any broker being approved and added to the approved broker list.
The Manager only places orders to be executed with approved brokers. The approved brokers are assessed on an ongoing basis to ensure they consistently offer the best results for clients.
The Manager has adopted appropriate procedures to ensure a high standard of execution is maintained aligned to internal governance procedures:
Governance framework and control process is put in place to manage counterparties with whom the Manager has engaged. The Manager’s trading system only permits trading with approved counterparties. In addition, counterparty risk is monitored and overseen by the Counterparty Approval Committee.
A TCA is regularly carried out to enable the Manager to measure implicit trading costs where applicable, such as marketing impact, timing and opportunity cost to assess quality of the execution by the brokers.
The Manager monitors best execution regularly by reviewing sampled trades to check that the price achieved appears reasonable given other trades in the market around the time of execution, competing quotes have been obtained where relevant and that exceptions are reviewed where applicable, for example where the best quotes have not been selected.
The Manager shall ensure that, as part of its best execution and conflicts of interest monitoring, it undertakes an analysis of fees, costs and charges that are paid by the Manager as part of its execution arrangements. The Policy shall ensure that any fee, cost or charge does not unduly influence the Manager’s selection of execution venue or third party broker.
Singapore