Best execution and order handling policy

Policy purpose

The purpose of this policy is to set out The Asset Management Exchange (Ireland) Limited’s (“AMX’s”) approach to order execution and its arrangements for consistently achieving the best possible results for its clients and investors according to its best execution obligations.

Policy application

This policy applies to AMX Ireland in its capacity as a collective investment scheme portfolio manager to (AIFs and UCITS) (“Funds”) under its management.

What is best execution?

Best execution refers to the obligation to take all reasonable steps to obtain the best possible result for clients and investors when dealing in transactions on behalf of client portfolios, by either directly executing transactions on one or more execution venues or transmitting orders to third parties for execution.

AMX’s order execution arrangements

AMX Ireland delegates investment management to external third-party portfolio managers on a sub-fund-by-sub-fund basis. Hedging transactions are executed on AMX’s behalf by a third-party provider under AMX’s oversight. AMX takes reasonable steps to achieve best execution when third parties act on its behalf through its on-going due diligence process and through its on-going oversight and monitoring.

Due diligence process

All third parties executing orders on AMX’s behalf are subject to due diligence, both prior to their initial appointment and an on-going basis. AMX only delegates order execution to third parties who it has approved and who are able to demonstrate that they are able to meet AMX’s requirements.

AMX exercises due skill, care and diligence in the appointment of third party providers acting on its behalf. In particular, the due diligence process considers key aspects of the third party and their ability to consistently obtain the best possible results on behalf of AMX, the Funds under its management and its investors. The outcome of the due diligence assessment is fully documented and updates provided to the AMX Executive Committee (“ExCo”) and the AMX boards.

Ongoing monitoring and review

All third parties appointed to execute orders on AMX’s behalf are subject to on-going monitoring and review on a regular basis under the effective oversight of AMX.

In particular, regular analysis is performed of the adequacy of each third party’s execution arrangements and on at least an annual basis each third party is re-assessed against the due diligence criteria. Third party’s that fail to meet AMX’s requirements on an on-going basis are removed from AMX’s approved list and are no longer permitted to execute orders on its behalf.

Escalations

Any matters requiring escalation under this Policy are brought to the attention of the AMX Ex Co and the Board of AMX Ireland as necessary.

Reporting and record keeping

AMX will retain records that enable it to demonstrate that it and its delegates (as applicable) have executed orders in accordance with this order execution policy.

Policy review and approval

AMX will review its order execution policy on a regular basis (and at least annually, or where a material change occurs that affects AMX’s ability to continue to obtain the best possible result for each Fund or its investors) and will make any amendments as necessary.