Best Execution Policy

This Best Execution Policy should be read in conjunction with our standard terms of business.

• Introduction

  BRUCE INVESTMENTS LTD (the "Company" or "We") is committed to conducting business with its clients honestly, fairly and professionally. We shall act in the best interests of our clients when executing client orders and shall take reasonable steps to achieve the best overall trading result for the clients. This means that we will aim to provide "best execution", subject to and taking into account the nature of client orders, the prices available to us in the market, the nature of the market in question and a reasonable assessment of the sometimes overlapping and conflicting execution factors (which are detailed below).

  Our intention is, so far as possible, to exercise consistent standards and operate the same processes across all markets, clients and financial instruments in which we operate.

  We also intend to provide our clients and other market participants with access to (where possible) tradable prices on a non-discriminatory basis. However, the diversity in those markets and instruments, and the kind of orders that they may place, mean that different factors will have to be taken into account in relation to any particular transaction.

• Exemptions from the provision of Best Execution

  Notwithstanding the intentions expressed above, we do not undertake to provide "best execution" if the order falls within any of the following exemptions:

  • Eligible Counterparties

    In the wholesale OTC derivatives and bond markets (and for the avoidance of doubt this would include derivatives in Equities, Energy and Commodities) in which the Company operates it is normal market practice for buyers and sellers to "shop around" by approaching several brokers/dealers for a quote.

    In these circumstances there is no expectation between the parties that the broker/dealer chosen will owe "best execution". As a sophisticated participant in the wholesale markets, unless the client advises us the contrary, we will assume that this is the client's normal trading behavior.

  • Client Instructions

    Where the client provides us with a specific instruction in relation to his/her order, or any particular aspect of his/her order, including an instruction for their trade to be executed on a particular venue, we will execute the order in accordance with their instructions.

    However, please note that in following their instructions, we will be deemed to have taken all reasonable steps to provide the best possible result for the client in respect of the order, or aspect of the order, covered by the specific instructions.

• Clients

  Because we intend to handle orders and expressions of interest in an equitable and consistent manner, once a client is classified, for the purposes of a particular instrument, that client may not then elect to be re-classified for the purposes of one transaction of a type it customarily undertakes.

  Exceptional circumstances may be taken into account at the time, with our consent (we may decline to provide a service should a reclassification be requested).

• Execution Venues

  This Best Execution Policy (the "Policy") sets out the venues on which we may transact the client's order. We will act as the sole execution venue for all client orders which are executed on an 'Over The Counter' (OTC) basis. We have identified those venues on which we will most regularly seek to execute the client's orders, as well as venues that we believe offer the best prospects for achieving the best possible results for the client, taking into account the factors detailed below.

  We are able to transact trades on behalf of the client via the following execution venues:

  • Our liquidity providers;
  • Regulated markets;
  • Where appropriate our customer base in the over the counter (OTC) markets;
  • Multilateral trading facilities operated by a third party; and
  • Systematic internalizers.

  When selecting the venue on which to transact trades we will take reasonable measures to ensure that the selected venue obtains the best possible trading result for our clients, subject to the following factors:

  • In the markets in which we operate, we can only give clients visibility to prices that have been communicated to us;
  • We will provide details of all tradable bids and offers (via the platform and subject to the other matters referred to below);
  • Time availability of prices – in many markets there are lulls and spikes in trading as negotiations align trading interests at different times and different parts of the curve, accordingly the "last traded" price may not always be available or act as a reliable indicator of current price;
  • We cannot allow clients to trade in a market unless we are reasonably satisfied that the client (via an agent or otherwise) is capable of settling the relevant trade; and
  • Fees may vary between clients, based on agreements and levels of activity.

• Execution Factors

  In the absence of express instructions from the client, we will exercise our own discretion in determining the factors that are needed in order to provide the client with the best possible execution result.

  These execution factors in the markets in which we operate will include, but are not restricted to the:

  • characteristics of the client;
  • size, nature and characteristic of the order;
  • likelihood and speed of execution;
  • price and costs of execution; and
  • settled block trades, or positions larger than standard market size, may be crossed at a particular stage in the trading day or kept anonymous to the majority of market participants; unless otherwise directed.

• Monitoring and review

  When executing orders, we will take all reasonable steps to obtain the best possible result under the circumstances for the client, taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.

  We will assess, on a regular basis, whether the execution venues, included in the order execution policy provide for the best possible result for our clients or whether we need to make changes to our execution arrangements and or providers.

  We are committed to the provision of "best execution" to our clients and are therefore committed to ensuring that the selection process of the liquidity providers is fair and based on the quality of service and delivery and their reputation as leading providers of deep liquidity within their respective markets, which will also include the provision of better pricing than its competitors or the provision of better liquidity. We shall also undertake periodic due diligence and review of the liquidity provider(s) and the quality of the service and execution that is provided.

  We will monitor the effectiveness of our order execution arrangements and order execution policy in order to identify and, where appropriate, incorporate any amendments to existing procedures. Additionally, we will review its order execution arrangements and procedures at least annually or whenever a material change occurs that affects our ability to continue to obtain the best possible result for the execution of client orders on a consistent basis using the venues included in its order execution policy.

• Order Management

  We provide trade processing on an execution basis only where transactions are automatically processed via 'Straight Through Processing' (STP). The prices that we publish on our trading platform and offer to the client are an indication of the prices at which we would be willing to buy from and sell to client. They are not firm prices and should not be treated as such.

• Churning

  Churning is the practice of executing trades for a customer's investment account by a broker or brokerage firm for the sole purpose of generating commissions. It occurs when a broker engages in excessive buying and selling in the clients' account that is unnecessary to fulfil the investment goal of the client.

  Statement on Churning:

  The Company will trade in securities as principle with the intention of reselling these to the public by adopting the following approaches:

  • When the Company acts as a broker, it connects person A with Bid order to person B with Ask order. In this case, the Company takes the commission for connecting them.
  • In case of principal, the Company acts as a dealer, where it has ownership of the security and if the customer is happy with the terms and the price, the Company will sell the security to the customer without searching for the liquidity on the market.

  POLICY AND PROCEDURES TO PREVENT CHURNING

  1. The Dealer Team will only execute order requested by the clients;
  2. The Company will enter into all trading transactions with its client on a principal-to-principal basis unless otherwise agreed with the client;
  3. The investment will be at consistent rates as agreed with the clients;
  4. The Dealer teams will ensure that the clients have been notified when the trade has been executed and that contract notes have been send to the clients;
  5. Client will have to abide to the "Client Agreement".

  Contract for Investment Dealer Team

  The contract of the Investment Dealer Team shall bear a clause about commissions from Clients to any member of the Team which is STRICTLY FORBIDDEN, and if same is reported and come to the Notice of the Management, it is a ground for dismissal.

• No Fiduciary Relationship

  Our commitment to provide the client with "best execution" does not mean that the Company owes the client any fiduciary responsibilities over and above the specific regulatory obligations placed upon it or as may be otherwise contracted between the client and the Company.

  The client remains responsible for his/her own investment decisions and we will not be responsible for any market trading loss suffered as a result of those decisions.