Best Execution & Order Allocation Policy for Wise Asia-Pacific Pte Ltd
Overview of Best Execution requirement
The Securities and Futures Act (Cap. 289) (“SFA”) applies to all capital markets intermediaries as defined in Notice SFA 04-N16 on Execution of Customers’ Orders (the “Notice”) which requires Wise Asia-Pacific Pte. Ltd. (“WISE”) to ensure the placement and execution of customers’ orders are on the best available terms (“Best Execution”). These will need to take into account a range of factors which include price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the placement and/or execution of the order. WISE will at all times strive to act in accordance with the best interests of its clients when transmitting client orders to other entities for execution.
In order to comply with the overarching best execution requirement (above), WISE will ensure that appropriate execution policies and/or arrangements are effectively implemented for the carrying out of all orders.
WISE however is not under an obligation to obtain the best possible result for each individual order; rather we will apply our execution policies to each aggregated order with a view to obtaining the best possible result in accordance with the execution policy.
The detailed policy for order execution contained below will be reviewed regularly and clients will be informed of any material changes to the policy. Terms not otherwise defined in this policy will have the meanings given in the Assets Customer Agreement.
Best Execution Policy
This policy is intended, in as clear a way as possible, to demonstrate how WISE operates and provides best execution in the best interest of its clients.
Order Placement
All orders are placed through the Wise App/via the website. No orders can be taken via telephone or email.
Order Execution Factors
The decision of which execution venue is used for any one trade will be reached based on price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of an order.
Where there is only one execution venue to place your order, we will be required to use that venue irrespective of the above factors. This is usually the case when you place an order within a collective investment scheme (i.e. Unit Trust or Funds). This venue will be ‘Direct with Fund Manager’.
When executing an order, WISE will generally treat price and speed as the highest priority for ensuring best execution. Only under exceptional circumstances would this not be the case.
In order to calculate the price, WISE will pay due attention to the ‘total consideration’. This is represented by the price of the financial instrument and the costs related to execution, which must include all expenses incurred by the client which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.
Execution Venues
An ‘execution venue’ includes a regulated market, capital markets intermediary or a person who is licensed, authorised, regulated or otherwise exempted in relation to dealing in capital markets products in a foreign jurisdiction, for execution.
If there is more than one execution venue or broker available to place or execute the client’s order, considerations will be taken based on the respective merits of each venue or broker, and the basis for selecting the venue(s) or broker(s).
The below table shows the securities that WISE is executing for client orders and which execution venue is used.
| Securities | Execution Venues/Broker |
|---|---|
| Units in Collective Investment Scheme | Direct with the Fund Manager |
WISE believes that the execution venue above is appropriate to providing best execution to you as our service is offering a single venue product. This enables WISE to obtain on a consistent basis the best possible result for the execution of client orders. The charges passed down to the client are consistent with the cost of dealing with the Fund Manager.
Execution Criteria
When executing a client order, we will take into account the following considerations for determining the relative importance and/applicability of the factors above:
- the type of the client, whether it is a retail client;
- the characteristics of the client order;
- the type of capital market products for which it accepts, places or executes orders;
- the characteristics of the execution venue or brokers to which that order can be directed.
Best execution obligations apply to all capital market products irrespective of whether they are executed on-exchange or off-exchange.
Selecting an Execution Venue
As we are only offering a single venue product, all executions will take place directly with the Fund Manager.
Conflicts of Interest/Inducements
WISE will not receive any remuneration, discount or non-monetary benefit for routing client orders to a particular trading venue or execution venue which would infringe the requirements on conflicts of interests.
Order Allocation
Scope
WISE is required to ensure that all purchases and sales of units should be allocated accurately and fairly across all clients. WISE may aggregate transactions for a client with those of other clients, and will allocate such transactions on an accurate, fair and reasonable basis. When WISE aggregates a client order with an order for another client it must do so in accordance with this policy and ensure that it is consistently applied. WISE will aggregate transactions only where it is unlikely that the aggregation of orders and transactions will work overall to the disadvantage of any client whose order is to be aggregated.
WISE will ensure that the policy is effectively implemented, providing for the fair allocation of aggregated orders and transactions. When aggregating an order, WISE may execute the order in part if it does not prove possible to execute the order in full. When WISE aggregates a client order with an order for another client, and part or all of the aggregated order has been filled, it must promptly allocate the designated securities concerned in accordance with the policy.
If the aggregated order is partially executed, WISE shall allocate the related trades to the client in priority to any other non-client account orders. Aggregation may delay the execution of a transaction, and it may operate to a client’s disadvantage in relation to a particular order.
WISE’s Aggregation Process
As part of WISE’s execution model, WISE will be routinely aggregating all client buy orders and all client sell orders. The order to the fund will be submitted in WISE’s name and will always be a matched position to the aggregate of all of the customers orders.
WISE’s clients are very unlikely to ever be disadvantaged by the aggregation of orders as there is a single cut off time for the Fund in which WISE will be buying or selling units. Therefore all clients’ trade orders fulfilled on any given trading day would receive the same valuation for their investment provided the order has been submitted before cut-off time on the relevant trading day.
Cancellation
We reserve the right to cancel a transaction without notice where we believe there is sufficient justification. If for operational, legal or regulatory reasons (or any other reason outside of our control) your order cannot be executed on a given trading day, WISE shall use its best endeavours to facilitate the execution of that order on the next available trading day.
By selecting to continue, you declare that you have read and understood the above and give consent to this Best Execution & Order Allocation Policy for WISE.