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Order Execution Policy

This is a summary of SEB Asset Management AB's (“SEB AM”) Order Execution Policy (the “Policy”), made available to retail customers in accordance with the requirements of Article 66 of the EU Commission Delegated Regulation (EU) 2017/565.

The Policy sets out the general principles under which SEB AM will seek to deliver best execution by taking the necessary measures to achieve the best possible results for its clients on an ongoing basis when either executing transactions on behalf of the client or when forwarding orders to other entities for execution.

While every effort will be made to achieve best execution, this does not necessarily mean achieving best price in each and every case, but rather the best price that can reasonably be expected given the information available during the execution process.

Specific client instructions

Where a client provides SEB AM with specific instructions on how all or part of their order should be executed, SEB AM will strive to execute transactions in accordance with these instructions while taking into account all other relevant factors not covered by the specific client instructions.

It is important to highlight that SEB AM will be deemed to have fulfilled its obligations by providing the best possible execution in relation to those aspects of the transaction covered by the instruction. A specific instruction from the client may therefore result in SEB AM not following the principles set out in this Policy to achieve the best possible results for the execution of the client's order. However, SEB AM will apply the principles set out in this Policy to those aspects of a transaction that are not covered by the instruction(s).

Obligation regarding best selection and best execution presupposes that the client has entered into relevant agreements, including with other brokers. SEB AM's obligations regarding best selection and best execution may be limited without such agreements.

Best execution framework

SEB AM is a securities company and does not generally have direct access to regulated markets. Therefore, SEB AM forwards orders on behalf of its customers to either an approved external broker or to a customer's depositary providing custodial services. This enables SEB AM to take advantage of available execution venues resulting in the best selection of brokers and best execution.

Brokers are selected by taking into account certain criteria relating to the execution of orders that enable SEB AM to ensure that the broker will provide best execution on a continuous basis, in other words by applying the performance factors set forth in the European Parliament and Council Directive 2014/65/EU (MiFID II).

Brokers' dependence on best execution

SEB AM ensures that the following is taken into consideration when executing customer orders by forwarding to a broker:

  • the broker's best execution policy complies with the requirements of MiFID II;
  • broker's ability to demonstrate best execution upon request;
  • the defined trading strategy of the algorithm provided by the broker; and
  • the trading venues on which the broker executes orders.

SEB AM will only forward orders to brokers that are on SEB AM's approved brokers’ list. This list is available on SEB AM's website sebgroup.com/sv/asset-management.

Selected execution venues

SEB AM will typically execute transactions on the following types of venues:

  • Regulated markets (RMs) and their non-EEA equivalents (by way of an authorised intermediary of SEB AM)
  • Multilateral trading platforms (MTFs) and their non-EEA equivalents
  • Organised trading platforms (OTFs) and their non-EEA equivalents
  • Systematic internalisers (SIs) and their non-EEA equivalents
  • Market makers (with a counterparty approved by SEB AM)
  • Other dealers (with a counterparty approved by SEB AM)

SEB AM can execute orders on behalf of clients or place orders with an entity that can execute orders outside a trading venue. In these cases, there is a risk that the selected trading venue cannot fulfil its obligations. This risk is reduced by transacting only with approved counterparties, ensuring proper documentation (for example ISDA Master Agreement), and a security interest if necessary.

The main venues on which SEB AM executes orders in each class of financial instruments are set out at sebgroup.com/sv/asset-management.

Best execution framework

Execution factors  

SEB AM strives to take the necessary measures to obtain the best possible result when executing orders on behalf of its clients or when placing orders with other entities to execute. To this end, SEB AM has implemented procedures that consider the following execution factors, including:

  • the price available on markets and trading venues that SEB AM has access to;
  • transaction costs, including venue execution charges and settlement costs;
  • speed of execution;
  • the likelihood of execution and settlement, as impacted by market liquidity;
  • the size and nature of the transaction; and
  • any other circumstances that SEB AM considers relevant.

Total consideration

Under MiFID II, the best possible outcome is normally determined in terms of total compensation representing the price of the financial instrument and the costs incurred in executing the client's order.

Costs include all expenses incurred by the client that are directly related to the execution of the order, such as execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. Speed of execution, likelihood of execution and settlement, size and nature of the transaction, market impact, and other implicit transaction costs may be given precedence over the immediate price and cost consideration only to the extent that they contribute to providing the best possible result in terms of the total consideration for the retail customer.

Trading relationship test

The EU Commission has established a relationship-based “four-fold test” that can be used to determine whether a customer is legitimately relying on a firm in a specific transaction:

  • Who initiates the transaction
  • The typical market practice and the existence of a convention to “shop around”
  • The relative levels of price transparency within a market
  • The information provided to the client and any agreements entered into

This test is used to determine whether it is likely that the client is seeking to rely on SEB AM to protect their interests. As the criteria may vary depending on the specific asset class, Appendix 1 of the Policy elaborates further on how these criteria are applied.

Implementation criteria

SEB AM’s assessment of the relative importance of each of the above factors will take into account the following criteria as part of the overall execution strategy (in addition to any specific instructions that a client may provide, see Specific Client Instructions below).

  • Client characteristics, including its classification as a retail or professional customer.
  • Type of transaction (including size and likely market impact).
  • The financial instrument being traded.
  • The trading venues to which the transaction may be directed.
  • All other circumstances that SEB AM deems relevant.

Aggregated orders

SEB AM may aggregate a client’s order with those of other clients for the same financial instrument in order to ensure fair and equitable treatment of all clients in compliance with MiFID II requirements. Aggregated orders must be advantageous (or unlikely to be disadvantageous) to all clients whose orders are to be aggregated.

Allocation of orders

Orders must be allocated in accordance with advanced allocation documentation provided by the portfolio managers.

In the event of partial allocations, orders must be allocated based on the original pro rata, taking into account the characteristics of the financial instruments in question (minimum tradable amount, an increase, etc.) and the specific instructions of the clients.

SEB AM sets out the distribution of orders in advance, and as soon as SEB AM is aware of the execution, the exact and final distribution is transmitted to the depositary/account holder.

This Policy ensures that orders are distributed fairly among customers.

Cross-trading

Cross-trading can arise when SEB AM, on behalf of several clients, executes purchase and sale transactions simultaneously for the same financial instrument. SEB AM can execute cross-trading transactions, to the extent permitted by the applicable regulations, between clients' portfolios in order to achieve the best possible results for each client, in particular with respect to costs (lower brokerage costs or trading at an intermediate price).

Cross-trading between SEB AM's clients is carried out externally through approved brokers or trading venues.

Monitoring and Review

If a client wishes to receive formal documentation regarding how SEB AM followed the principles set forth in the Policy with regard to one or more orders, the client should refer the matter to their usual SEB contact and explicitly request a written response.

SEB AM has introduced arrangements to monitor and regularly review the application of the Policy.

SEB AM will review its Policy at least once a year, and the most recently updated version of the Policy will be made available at sebgroup.com/sv/asset-management.

In the event of a material change, a communication to clients will be published on the website.

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