RHB BANK BERHAD SINGAPORE BEST EXECUTION POLICY (“DISCLOSURE STATEMENT”)

1. INTRODUCTION

Pursuant to the Monetary Authority of Singapore

Notice SFA 04-N16 on Execution of Customer’s Orders; and
Guidelines SFA 04-G10 to MAS Notice SFA 04-N16 on Execution of Customers’ Orders,

we (“RHB Bank Berhad Singapore”) are required to put in place a Best Execution policy “Execution Policy” and to take all reasonable steps to obtain the best possible results (where possible) for our clients (henceforth referred to as “client”, “you”, “your”) when executing orders on your behalf or placing your orders with, or passing your orders to others for execution. This overarching obligation to obtain the best possible result for you is referred to, in this document, as our obligation of “Best Execution”.

2. SCOPE AND APPLICATION OF BEST EXECUTION

Best Execution is generally owed when we accept an order to execute a transaction on your behalf, or place your order with others for execution or in other circumstance where we have otherwise expressly agreed to accept such best execution obligation.

2.1 CAPACITY

The Best Execution obligation is applicable when we are acting in a principal capacity and you are placing an order or submitting a trade with us for products identified under the Securities and Futures Act (SFA).

2.2 PRODUCTS

The Best Execution applies to all capital markets products as prescribed by the regulators in the locations RHB is operating, which include but not limited to the following:

Over-the-Counter Derivatives
Structured Products
Foreign Exchange (Forwards and NDFs)
Bonds & Fixed Income

2.3 CUSTOMERS AND APPLICATION

2.3.1 Best Execution will apply to you if you are placing your order with us as a person, and not as an Institutional Investor.

2.3.2 If you are dealing with us as an Accredited or Expert Investor, we will determine whether you are placing a legitimate reliance on us to provide best execution to you based on the following criteria:

(i) Party initiating the transaction – If you initiate the transaction, it is less likely that you are placing legitimate reliance on us.
(ii) Market practice and your ability to obtain quotes from various providers – Where you will have ready access to obtain quotes from various providers, it is less likely that you are placing legitimate reliance on us.
(iii) Relative levels of price transparency within the market – Where pricing information are transparent and it is reasonable that you have access to such information, it is less likely that you are placing legitimate reliance on us.
(iv) Information provided by you and any agreement reached – Where any agreements or arrangements with you (including provisions under this Disclosure), indicate or suggest that an understanding has been reached that you will not place any legitimate reliance on us.

3. SPECIFIC INSTRUCTIONS

3.1 Where you give us a specific instruction in relation to an order, we will follow that instruction so far as is reasonably possible when executing the trade on principal basis. By following your specific instruction, we will have satisfied the obligation to provide you with best execution in relation to that transaction.

3.2 If the specific instruction cannot be carried out by us, we will inform you.

4. BEST EXECUTION FACTORS

4.1 In order to secure the best possible Best Execution result for you, while acting in capacity as principal, we consider the following factors:

Price – This is the price at which the order is executed
Speed – The time it takes to execute your order
Likelihood of execution – The likelihood that we will be able to complete your order
Size – The size of the order may affect the price of execution
Nature of the order – Characteristics of your order which can affect how best execution is received

4.2 We may also take into consideration the following general criteria when determining how to achieve Best Execution of the order:

The characteristics of the client (including the categorization of the client);
The characteristics and nature of the order, including any specific instruction received;
The characteristics of the capital market products that are subject of the order; and
The characteristics of the execution venues or brokers to which the order can be directed.

4.3 For Retail Customers, we will process your trade application on a First-In-First-Out (FIFO) basis for as long as you have provided the necessary information for processing. All charges or fees will be disclosed to you prior to your trade application.

4.4 For the activities relating to Initial Public Offerings (IPO) and Private Placements (PP), we may not be able to guarantee your placement as it depends on the Issuer’s confirmation where factors such as timing of order, investor’s profile may be considered.

4.5 We reserve the right to intervene in the execution if such orders would result in adverse market movement (e.g. large orders).

5. EXECUTION VENUES

5.1 Our deals transacted in are traded on a principal basis, therefore, you will be dealing with either us or one of our other offices (or affiliates/ Group). As such, the execution venues we use are generally to clear our own market risk.

5.2 In meeting its Best Execution obligation, we will monitor which venues are likely to provide, on a consistent basis, the best available terms for our clients. We, may, however not connect to all venues or sources of liquidity.

6. MONITORING OBLIGATIONS

6.1 In ensuring that Best Execution is carried out consistently, we perform period effectiveness testing such as order execution is monitored during pre- and post-trade and is subject to nature, scale and complexity of products, and characteristics of clients.

6.2 We will assess whether the entities to which we transmit orders or execution provide the best possible result for you on a consistent basis.

If you require further clarification on our Execution Policy, you may contact your Relationship Manager or Sales Representative for more details.