True Global Ventures 4 Plus Pte. Ltd. ("TGV")
1. Introduction
Under the MAS Notice and Guidelines on Execution of Clients’ Orders, holders of a Capital Markets Services licence that conduct the regulated activity of fund management must establish and implement written policies and procedures to place and execute orders on the best available terms (“Best Execution”), taking into account a range of factors. The factors may include price, costs, speed, likelihood of execution and settlement, size of order, or any other considerations relevant to the placement or execution of the order.
This document sets out TGV’s Best Execution policy and its approach to providing Best Execution when (either directly or through its agent) placing or executing orders for purchase or sale of any capital markets product on clients’ behalf. TGV may update or revise this document from time to time, without prior notice.
2. Scope
The Best Execution policy relates to client’s orders for the purchase or sale of any capital markets product given to TGV regardless of whether:
A client means:
(i) a person, other than an institutional investor, on whose behalf, TGV (either directly or through its agent) carries on or will carry on fund management; or
(ii) a collective investment scheme on whose behalf TGV (either directly or through its agent) carries on or will carry on fund management.
3. Best Execution Obligation
Best Execution obligation arises when TGV is ‘acting for or with a client’, when TGV is able to exercise discretion when executing or placing a client’s instruction or order (e.g. in discretionary fund management) and where the client is relying on TGV to protect its interest in relation to the order.
Best Execution is generally owed when TGV accepts an order to execute a transaction on client’s behalf, or place client’s order with, or place client’s order to, others for execution or in other circumstances where TGV otherwise expressly agreed to accept such Best Execution obligation.
TGV’s commitment to Best Execution does not mean that it owes its clients any fiduciary or other responsibilities beyond the specific regulatory obligations placed on it and may otherwise be contracted between TGV and any particular client.
4. Best Execution Factors
Where TGV has the obligation to provide Best Execution, it will execute a client’s order taking into consideration the following factors-
Some of the above factors are considered more important than others. However, there are situations where the relative importance of these factors may change in accordance with instructions that client provides or broader market conditions.
5. Application of Best Execution Factors
The above execution factors indicate the importance of being able to exercise appropriate judgements in the best interests of the client given the differing needs and requirements of each client’s transaction and the broader market.
TGV uses its expertise, commercial judgement and experience to determine the relative importance of each factor. For most orders, it will primarily be a case of achieving the best price, although other features of the order, like cost of execution, size, liquidity, speed of execution and other matters, may be considered where relevant. In determining the relative importance of the factors, TGV may take into consideration the following general criteria:
When placing or executing orders for clients, any specific execution factors specified by the client will be paramount in ensuring best execution is provided. TGV reserves the right to intervene in the execution if a client’s orders will result in adverse market movement (e.g. large orders).
6. Execution Venues or Third-Party Brokers
In meeting its Best Execution obligation, TGV will monitor which execution venues or third-party brokers are likely to provide, on a consistent basis, the best available terms for clients. Where TGV uses a third-party broker to execute transactions, it retains an overarching Best Execution obligation.
For certain capital market products, there may only be one execution venue available and in executing an order in such circumstances, TGV will assume that the selection of that venue satisfies the Best Execution factor for venue selection.
7. Monitoring and Review
TGV will review its Best Execution policy annually or whenever a material change occurs that affects its ability to obtain the best possible result for the execution of its orders on a consistent basis.
TGV will also monitor the effectiveness of its policy periodically to identify and where appropriate correct any deficiencies. TGV carries out monitoring of execution quality against the execution factors, which includes monitoring the continuing suitability of third-party brokers in light of their execution performance.
8. Disclosure
TGV’s Best Execution policy is provided to clients via TGV’s website.
9. Execution Principles in relation to Specific Capital Markets Products under Discretionary Fund Management Service
Although the relative importance of the execution factors may vary depending on the specific characteristics of the order, TGV generally expects price and costs to be the most important execution factors for the majority of client orders that it executes under its discretionary fund management service.
Dealing in Securities Issued by Unlisted Business Ventures or Companies
Due to the characteristics of securities issued by unlisted business ventures or companies, there is limited discretion in defining the parameters of execution of these orders, and the Best Execution obligations are considered to be fulfilled per se.
Dealing in Exchange-Traded Products
Unless specified otherwise by clients, price and speed/likelihood of execution are typically considered highly ranked execution factors for exchange-traded products (e.g. equity securities and exchange-traded derivatives, such as warrants) while the other execution factors (order size, likelihood of settlement, nature of order) will be considered depending on the circumstances of the trade. However, in more illiquid markets, the primary execution factors may vary and non-price factors such as likelihood and speed of execution and settlement as well as size or nature of the order may be as important as the price factor.
The client’s order will be placed to a third-party broker which has an agreement with TGV to execute the orders on the relevant exchange or market. TGV will take all reasonable steps to ensure that the third-party broker executes the orders in accordance with its policy in order to obtain the best possible result for the client, having regard to prevailing market practices and regulatory requirements associated with the market concerned.
1. Introduction
Under the MAS Notice and Guidelines on Execution of Clients’ Orders, holders of a Capital Markets Services licence that conduct the regulated activity of fund management must establish and implement written policies and procedures to place and execute orders on the best available terms (“Best Execution”), taking into account a range of factors. The factors may include price, costs, speed, likelihood of execution and settlement, size of order, or any other considerations relevant to the placement or execution of the order.
This document sets out TGV’s Best Execution policy and its approach to providing Best Execution when (either directly or through its agent) placing or executing orders for purchase or sale of any capital markets product on clients’ behalf. TGV may update or revise this document from time to time, without prior notice.
2. Scope
The Best Execution policy relates to client’s orders for the purchase or sale of any capital markets product given to TGV regardless of whether:
- TGV acts as an agent or principal to the client;
- clients’ orders are executed directly on an execution venue or placed with another 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;
- clients’ orders are executed on-exchange or off-exchange (such as for cross trades).
A client means:
(i) a person, other than an institutional investor, on whose behalf, TGV (either directly or through its agent) carries on or will carry on fund management; or
(ii) a collective investment scheme on whose behalf TGV (either directly or through its agent) carries on or will carry on fund management.
3. Best Execution Obligation
Best Execution obligation arises when TGV is ‘acting for or with a client’, when TGV is able to exercise discretion when executing or placing a client’s instruction or order (e.g. in discretionary fund management) and where the client is relying on TGV to protect its interest in relation to the order.
Best Execution is generally owed when TGV accepts an order to execute a transaction on client’s behalf, or place client’s order with, or place client’s order to, others for execution or in other circumstances where TGV otherwise expressly agreed to accept such Best Execution obligation.
TGV’s commitment to Best Execution does not mean that it owes its clients any fiduciary or other responsibilities beyond the specific regulatory obligations placed on it and may otherwise be contracted between TGV and any particular client.
4. Best Execution Factors
Where TGV has the obligation to provide Best Execution, it will execute a client’s order taking into consideration the following factors-
- Price – this is the price at which the order is executed, including execution venue fees, clearing and settlement costs and related fees.
- Speed of execution – this refers to the rate at which TGV is able to progress the order. Where client’s instructions dictate or imply a rate at which TGV should progress the order, TGV will follow such instructions unless there is an immediate and substantial conflict with the price. Where the instructions do not refer to speed, TGV will progress the order at a rate which TGV believes represents a balance between creating market impact and executing the order in a timely fashion so as to reduce execution risk. This factor increases in importance in situations where access to liquidity in the relevant instrument is constrained in some way. For example, if the security itself is illiquid or if client provides a limit price which is not marketable.
- Costs – costs incurred from entering into the transactions.
- Likelihood of execution and settlement – this refers to the likelihood that the order will be filled, or at least a substantial part of it, in its entirety and whether TGV expects executed transactions to settle in a timely fashion. If TGV becomes aware that a particular execution strategy may compromise the likelihood of execution and settlement, that strategy may not be pursued even if it would result in a better price.
- Order size – the size of the order may affect the price of execution.
- Any other relevant considerations: e.g. relevant to the efficient execution of the client's order such as the nature of the relevant market, local regulatory requirement, prevailing market conditions, potential market impact and what might have been agreed with the client.
Some of the above factors are considered more important than others. However, there are situations where the relative importance of these factors may change in accordance with instructions that client provides or broader market conditions.
5. Application of Best Execution Factors
The above execution factors indicate the importance of being able to exercise appropriate judgements in the best interests of the client given the differing needs and requirements of each client’s transaction and the broader market.
TGV uses its expertise, commercial judgement and experience to determine the relative importance of each factor. For most orders, it will primarily be a case of achieving the best price, although other features of the order, like cost of execution, size, liquidity, speed of execution and other matters, may be considered where relevant. In determining the relative importance of the factors, TGV may take into consideration the following general criteria:
- the types of the client (including the regulatory categorization of client);
- the types of capital market products that are the subject of the order. For example, for transactions in illiquid securities, the likelihood of execution and settlement becomes more important; and
- the characteristics of the execution venues or brokers to which the order can be directed.
When placing or executing orders for clients, any specific execution factors specified by the client will be paramount in ensuring best execution is provided. TGV reserves the right to intervene in the execution if a client’s orders will result in adverse market movement (e.g. large orders).
6. Execution Venues or Third-Party Brokers
In meeting its Best Execution obligation, TGV will monitor which execution venues or third-party brokers are likely to provide, on a consistent basis, the best available terms for clients. Where TGV uses a third-party broker to execute transactions, it retains an overarching Best Execution obligation.
For certain capital market products, there may only be one execution venue available and in executing an order in such circumstances, TGV will assume that the selection of that venue satisfies the Best Execution factor for venue selection.
7. Monitoring and Review
TGV will review its Best Execution policy annually or whenever a material change occurs that affects its ability to obtain the best possible result for the execution of its orders on a consistent basis.
TGV will also monitor the effectiveness of its policy periodically to identify and where appropriate correct any deficiencies. TGV carries out monitoring of execution quality against the execution factors, which includes monitoring the continuing suitability of third-party brokers in light of their execution performance.
8. Disclosure
TGV’s Best Execution policy is provided to clients via TGV’s website.
9. Execution Principles in relation to Specific Capital Markets Products under Discretionary Fund Management Service
Although the relative importance of the execution factors may vary depending on the specific characteristics of the order, TGV generally expects price and costs to be the most important execution factors for the majority of client orders that it executes under its discretionary fund management service.
Dealing in Securities Issued by Unlisted Business Ventures or Companies
Due to the characteristics of securities issued by unlisted business ventures or companies, there is limited discretion in defining the parameters of execution of these orders, and the Best Execution obligations are considered to be fulfilled per se.
Dealing in Exchange-Traded Products
Unless specified otherwise by clients, price and speed/likelihood of execution are typically considered highly ranked execution factors for exchange-traded products (e.g. equity securities and exchange-traded derivatives, such as warrants) while the other execution factors (order size, likelihood of settlement, nature of order) will be considered depending on the circumstances of the trade. However, in more illiquid markets, the primary execution factors may vary and non-price factors such as likelihood and speed of execution and settlement as well as size or nature of the order may be as important as the price factor.
The client’s order will be placed to a third-party broker which has an agreement with TGV to execute the orders on the relevant exchange or market. TGV will take all reasonable steps to ensure that the third-party broker executes the orders in accordance with its policy in order to obtain the best possible result for the client, having regard to prevailing market practices and regulatory requirements associated with the market concerned.