The procedure concerning the placement, execution and handling of trading orders
In accordance with the provisions of Regulation no. 9/2014 concerning the authorisation and the operations of asset management companies, undertakings for collective investment in transferable securities and depositories, and with a view to ensure the fast and fair execution of all transactions in financial instruments in connection with the investment portfolios managed (i.e. open-end investment funds and individual investment portfolios), SAI ERSTE Asset Management SA (SAI ERSTE) has adopted an internal procedure concerning the placement, execution and handling of trading orders.
The purpose of the procedure is to ensure the best possible results for all investment portfolios under management, in terms of price, cost, speed and likelihood of execution and settlement, the size and nature of the trading orders.
Investment managers will place trading orders in connection with the investment portfolios managed by authorised investment intermediaries approved by the SAI ERSTE Management Board, with an eye on the high quality of order execution
Investment managers will place trading orders on the regulated market or the alternative trading system in Romania or on other regulated markets or alternative trading systems in EU Member States; order execution may also take place outside the regulated market or an alternative trading system. Investment managers will select trading venues with due care, focusing on the high quality of execution and settlement.
For best execution purposes, investment managers will consider the relevant investment policy, the features of trading orders, the type of financial instruments concerned, the information available on the market at the time, as well as the features of the trading venue where orders are placed. Trading orders concerning managed portfolios rank first in priority before SAI ERSTE’s own trading orders, and orders to the account of SAI ERSTE are always separate from orders concerning the investment portfolios managed by the same SAI ERSTE.
Execution of orders will always consider the best interest of the relevant investment portfolio, with focus on achieving the best possible results. Nevertheless, SAI ERSTE is in no position to guarantee the best possible result for each individual trading order.
SAI ERSTE will constantly observe the effectiveness of the procedure concerning the placement, execution and handling of trading orders, and will take the necessary actions to ensure the best possible results for the investment portfolios managed.