- Introduction & Purpose
This document outlines the Wrise Group’s Best Execution policy, which mandates the establishment of written policies and procedures to:
- execute customers’ orders on the best available terms; and
- execute, as the case may be, comparable customers’ orders promptly based on the order receipt time.
These practices are collectively known as “Best Execution”.
This disclosure statement details our considerations and approach to ensure optimal order execution for our customers across all Group entities and locations.
By maintaining your relationship with the Wrise Group and its entities, you are presumed to have read and understood this policy.
- Definition and Scope
Best Execution refers to the placement and execution of customers’ orders for capital markets products, considering various factors, to secure the most favorable terms available.
This policy applies when any Wrise Group entity directly places your orders on an execution venue or through another capital markets intermediary or entity dealing in capital markets products.
- Execution of Orders
Depending on the specific product and location, we may execute your orders directly with an Approved Counterparty or an Approved Issuer, both of which meet our internal selection criteria set in accordance with the applicable regulatory requirements and undergo periodic reviews. In exceptional circumstances, we may use execution venues or counterparties beyond our pre-approved list, where it is allowed as per the applicable local regulatory requirements. Nevertheless, we always strive to secure the best possible execution outcome.
If we encounter material difficulties affecting the proper execution or transmission of orders, such as execution system disruptions or extraordinary market conditions, we will promptly notify you and take appropriate action best suited for you.
For certain asset classes or investment products (e.g., structured products or fixed income), we may solicit multiple quotes for your order(s). Where multiple quotes are not available, we will exercise our professional judgment to determine if the quote is fair and reasonable. For certain investment products, there may only be one execution venue available and in executing a trade in such circumstances, we will assume that the selection of that venue satisfies the Best Execution factors for venue selection.
- Client Order Handling
We will execute orders in sequence based on their time of receipt with an Approved Counterparty. Exceptions may apply if order characteristics or market conditions make sequential execution unfeasible, or if your best interests warrant an alternative approach.
We may choose to consolidate your order with transactions from other clients during the execution process to secure more favorable pricing or minimize transaction expenses. We will only aggregate clients’ orders when we are confident that such aggregation will be advantageous for all clients involved, ensuring that no client is put at a disadvantage.
For orders received outside normal exchange hours, we will promptly transmit them once trading resumes.
- Execution Factors
To ensure the best possible execution outcome, we consider various execution factors relevant to order placement and execution. While some factors may carry greater weight depending on the circumstances, the relative importance of these factors may change in accordance with the instructions provided by you or the general broader market conditions.
The execution factors we consider (not in any particular order) are:
- Price: The execution price of a capital markets product;
- Costs: This includes all fees and costs related to order execution, including implicit costs such as possible market impact and explicit costs such as brokers fees;
- Likelihood of execution and settlement: The probability of order completion;
- Speed: The time it will take to execute your order;
- Size and Nature: Order size and its characteristics, influencing the approach to Best Execution;
- Any other circumstance relevant to order execution, as determined by our professional judgment.
Specific Instructions – When you provide specific instructions for executing or transmitting an order in a particular way, we fulfil our Best Execution obligation by adhering to your instructions. These instructions may include selecting a specific venue or timeframe. If your instruction covers only part of the order, we continue to apply Best Execution principles to the remaining aspects. We will use our professional judgement in considering the relevant factors and take sufficient steps to achieve the best possible result for you.
- Execution Venues and Approved Counterparties
We choose Approved Counterparties (such as brokers or investment firms) or Approved Issuers based on a comprehensive selection process that considers qualitative factors, including but not limited to:
- Creditworthiness, Credit Rating and reputation;
- Capital and Financial Resources, Group Structure
- Regulatory status and history
- Access to execution venues;
- Range of products and pricing competitiveness;
- Connectivity and market coverage;
- Other considerations such as local laws including that of the insolvency regime in place, research support and access to IPOs and new issues.
We regularly conduct due diligence and monitoring on Approved Counterparties and Approved Issuers. We also monitor affiliates, connected parties, or third parties engaged in execution and continuously assess execution outcomes.
- Monitoring and Controls
Controls and monitoring are in place to review the quality of execution and to detect and address anomalies. Trade exceptions and any issues related to best execution such as delays in execution, deviations in execution outcomes when compared against benchmarks, execution failures of engaged third parties, etc will be brought to management’s attention for timely review.
- Updates to Best Execution Policy
Our Best Execution Policy undergoes periodic reviews, and we retain the right to update it as necessary. If you require further information about our Best Execution Policy, please contact your dedicated Client Adviser at the relevant Wrise Group entity