Best Execution Policy

1. Introduction

1.1 We refer to MAS Notice No. SFA02-N03 on Execution of Orders by Market Operators issued on 3 September 2020 (SFA02-N03). Pursuant to SFA02-N03:

A locally-incorporated market operator which may exercise discretion in placing or executing orders or both, as the case may be, on its organised market must establish and implement written policies and procedures that are commensurate with the nature, scale and complexity of its business –

I. to place or execute or both, as the case may be, orders on the best available terms; and

II. to place or execute or both, as the case may be, comparable orders in accordance with the time of receipt of such orders.

1.2 This Policy sets out how Chintai complies with its best execution obligations under SFA02-N03.

2. Best execution principles 

2.1 Participants can initiate an Investment purchase or sale by placing a respective order on the Platform and letting the matching engine automatically match the orders in the order that those orders were received, in accordance with SFA02-N03 and the general principles of best execution for execution factors that are within Chintai’s control, specifically, Chintai performs its best execution obligation to take all sufficient steps to obtain consistently the best possible results for Participants when executing/placing/transmitting client orders by assessing the relative weight and importance of various execution factors and other relevant considerations under the particular circumstances including:

2.1.1 characteristics of the financial instrument;

2.1.2 price of the relevant financial instrument net of fees and other applicable execution costs;

2.1.3 costs incurred in execution of the transaction;

2.1.4 likelihood of execution and settlement;

2.1.5 size of the order;

2.1.6 nature of the order; and

2.1.7 any other relevant factors.

2.2 The relative importance of the execution factors for individual orders varies depending on the characteristics of the order, the financial instrument or placement of that order and the specific market conditions at the time of the trade, such as signals (e.g., indications of interest or axes) about the availability of natural liquidity.

2.3 An order which, for any reason, is not received by Chintai in a manner in which it can be processed, including a failure of the Platform to accept or process such an order, shall be deemed as not received by Chintai, any reliance or claims by Participants on the applicability of Best Execution principles would not apply to the order. If Chintai subsequently becomes aware of such orders, it will notify affected Participants of any potential further steps.

2.4 Matching orders are executed in the order that those orders were received according to the principles of Best Execution, including any partial fills where orders are matched based on matching or better prices in multiple sizes with other orders until they are fully filled or cancelled. Other orders are also entered to the Platform in time order of receipt.

2.5 The execution arrangements and this policy will be reviewed at least annually or when material change occurs that affects the ability to obtain the best result for execution of client orders.