Execution Policy

Valeurs Capital Limited (‘VCL) is required by best international practice, to provide information regarding our order execution policy to our clients. VCL will strive to ensure that reasonable steps are taken and processes in place to obtain the best possible result (“best execution”) for our clients. This document sets out information on the execution policy of VCL and its affiliates and is intended to cover all asset classes that we may manage for our clients.
2.1 Influencing Factors
VCL will be responsive to client benefit while executing a trade. There may be certain factors that our clients need to consider, before seeking to obtain best execution.
VCL may consider the below mentioned factors before proceeding with an order transaction.
VCL reserves the right to decide the relative importance of these factors to determine the ‘Best Execution Policy’. VCL may also design the policy by considering matters including the characteristics of the portfolio manager’s order, the characteristics of the financial instruments that are subject to that order. Further, VCL may use different execution strategies on a trade-by-trade basis dependent on factors such as market conditions, liquidity, investment strategy and client guidelines, the type of product to be traded, the rationale for the trade and other appropriate considerations.
In cases where VCL receives specific client instructions, it will conclude transactions in accordance with those instructions. Such client instructions may include but are not limited to; directed brokerage and/or restrictions on trading with certain counterparties including affiliates. In the client’s interest, VCL will also consider all other relevant factors not covered by the specific client instructions in achieving the best possible result for the client. However, VCL and its affiliates, are not permitted to induce a client to instruct execution in a way. In case client, specific instructions may prevent VCL from complying with its fiduciary and regulatory regulations it will take steps to implement the measures that it has designed to obtain the best overall result for its client and VCL.
3.1 Order Handling
VCL agrees to take any reasonable step to obtain the best possible execution result for its clients, having regard to the execution factors mentioned above. Further VCL, while it handles client’s orders either on a client’s behalf or as part of its portfolio management activities, it must ensure that orders are:
  • executed promptly
  • recorded accurately and promptly and
  • executed sequentially unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the client require otherwise.
We look to minimize the impact of our trades on the market and keep trading costs low by aggregating trades for our clients. We monitor trade prices against industry benchmarks where available, with the assistance of exception reports to determine if best execution has been achieved. In the case of equities, we may use several post trade analytical tools to monitor the costs of individual transactions where possible.
We will review our execution arrangements and policy at least annually, and additionally where there is a material change to our execution arrangements. We review annually the technology providers, information sources and brokers with whom we place orders for execution and may notify our clients of material changes.
VCL and its affiliates will make every effort to provide appropriate information to clients about their execution policies in good time before entering a relationship with a client. 'Appropriate' means sufficient, comprehensible information for a client to understand the service proposed and make an informed choice between the services offered by different firms.
Clients hereby undertake to read and understand our most relevant and recent execution policy before placing an order with us.