Policy on order procurement, placement and allocation (extract of the Policy)
This policy shall ensure that Jyske Invest Fund Management A/S (JIFM) acts in the interest of the managed associations and funds when executing decisions to procure, invest and allocate financial instruments.
The policy does not comprise funds for which portfolio management agreements have been signed since JIFM does not make decisions to trade in these.
The purpose of the order procurement is to secure best execution whereas the order placement concerns the passing on of orders. Finally, the purpose of allocation of orders is to ensure equal treatment of investors across all funds.
JIFM must – cf. chapters 12 and 13 of the Executive Order on the management and control of UCITS as well as articles 27 and 29 of the FAIF directive - take all reasonable measures to obtain the best possible result for the managed associations and funds when account is taken of price, costs, speed, implementation and calculation probability, scope, nature etc. of the transactions that are executed.
When deciding how to procure trading orders, account must also be taken of the fund’s investment strategy and risk profile, the characteristics of the trading order, the characteristics of the instruments as well as the characteristics of the trading system used.
1. Order procurement
The purpose is attained through day-to-day collaboration with securities brokers. JIFM does not have permission as a securities broker and does therefore not make any transactions itself but passes them on to securities brokers.
All securities brokers must present and obtain approval of a detailed and sufficient order execution policy before a collaboration is entered into.
2. Order placement
All trading orders shall be registered and allocated immediately and properly. In addition, it shall be secured that the placing of comparable trading orders takes place simultaneously and that such orders are settled on an ongoing basis unless the nature of the order or the market conditions make this impossible or unless it is evidently in conflict with the interest of the managed funds.
3. Order allocation
JIFM and related securities brokers shall be allowed to aggregate transactions on behalf of several associations and funds provided that it will not be to the detriment of any of the managed associations and funds.
Transactions in the same instrument shall be placed simultaneously for all funds involved if the investment decision was made at the same time.
Orders subject to partial settlement shall basically be allocated in relation to the individual funds' proportion of the total placement of orders.
JIFM shall not be allowed to aggregate transactions on its own account with one or more trading orders for the managed associations or funds.
JIFM shall only be allowed to make transactions between the funds of the managed associations if this is in the interest of the buying as well as the selling fund.
4. Control and documentation
At least once a year, JIFM controls that this policy is observed; including whether requirements and procedures on order procurement, placement and allocation are complied with.