Information on the Order Execution and Order Allocation Policy for UBS AG Jersey Branch, Wealth Management

Each of the terms which appear in bold below is defined in the section 16 'definitions' at the end of this document.

1. Purpose

We, UBS AG Jersey Branch, Wealth Management ('UBS', 'us', 'we') will take all sufficient steps in order to get the best possible results for our clients when executing, receiving and transmitting their orders.

The purpose of this document is to tell you about our order execution policy.

2. Scope of application

Our Order Execution and Order Allocation Policy is applied to financial instruments if we:

- receive and transmit client orders;

- execute orders on behalf of clients;  and

- provide portfolio management services.

The Order Execution and Order Allocation Policy is not applied if clients:

- are classed as an 'eligible counterparty' unless we have agreed with the eligible counterparty to treat them as a professional client or a retail client; or

- have concluded direct order handling agreements with a different entity in the UBS group.

We will follow any local rules and regulations that apply to the reception and transmission of client orders as well as to their execution.  If any provision of UBS' order execution policy is prohibited by applicable local law or regulation, the relevant provision will not apply.

3. Executing orders – getting the best possible result

Subject to any express instructions that may be given by you (see section 7), when executing orders in your name, when receiving and transmitting your orders, or when providing portfolio management services, UBS will take all sufficient steps to get the best possible result for you. This will take into account the execution criteria and total consideration – overall cost - in accordance with section 3.1 and 3.2. We will apply our commercial judgment and experience, and incorporate available market information.

3.1. Execution criteria

In addition to taking into account the total consideration (see Section 3.2), and unless you have told us otherwise, we will consider the following criteria when executing orders:

a) the client classification (either as a retail client or a professional client);

b) characteristics of the client order;

c) the financial instruments involved in the order; and

d) the execution venues or intermediaries to which that order can be directed.

3.2. Total consideration and other factors

In order to obtain best execution for our clients, the same approach is applied regardless of whether you are a retail or professional client.

This offers the highest level of protection and uses the overall cost, or total consideration as the primary guideline for attaining the best possible result for you.

The total consideration is made up of the price of the financial instrument and all related execution costs. We will look at other factors which could influence the outcome only if they could be instrumental in delivering the best possible result.

Total consideration and execution factors are made up of the following:

a) the price of the financial instruments offered by the intermediary or the execution venue; and

b) the direct and indirect costs which are connected to executing financial instruments, including:

i.  all expenditures that arise, which are directly connected with executing the order;

ii. fees relating to execution venues;

iii. clearing and settlement fees; and

iv. all other fees which are paid to third parties in connection with the execution of the  order;

c) speed;

d) the likelihood of the client order being executed and settled;

e) size and nature of the order; and

f) other relevant factors (such as market effects and implicit transaction costs).

4. Execution venues

A list of the execution venues which we have selected along with the respective class of financial instrument is included in the appendix to this document. This list is neither exhaustive nor fixed.

It includes all venues to which we commonly refer orders for execution which can be other entities in the UBS group. We reserve the right to use other execution venues if we determine that they are appropriate, after taking the criteria and factors listed in section 3 into consideration.

We monitor execution venues regularly in order to identify those which consistently enable the best possible result. The list is updated with any changes when required.

Where there is more than one competing venue to execute an order, we will take into account our own commissions and the cost of executing the order for each eligible execution venue.

We shall not receive any remuneration, discount or non-monetary benefit for routing client orders to a particular trading venue or execution venue.

5. Selection of a venue where orders are executed

Subject to any express instructions that may be given by you (see section 7), we use the following methodology when selecting a venue where orders are executed:

a) subject to the proper consideration of the execution factors mentioned above, another legal entity in the UBS group can act as an execution venue where orders are executed. This is based on our assessment that it is in your best interest (and/or at the very least, will not lead to any disadvantage for you);

b) subject to the above conditions, we select an execution venue that we deem the most appropriate in order to get the best possible result for you. This may include execution of trades outside a trading venue. There may be additional risks such as counterparty risk when executing in this way; and

c) there may also be regulatory requirements that require execution on a trading venue. As an example, certain derivative classes must be executed on a trading venue.

UBS may also use other entities within the UBS group as intermediaries to which UBS will route orders for subsequent execution on regulated markets. If so, this entity must consider all reasonably  available sources of information (including RMs, MTFs, systematic internalisers, OTFs, local stock exchanges, brokers and data providers) in order to get the best possible result for the order.

For certain instruments, there may be only one venue where orders are executed. For these financial instruments, we transmit the orders to this single venue. In order to ensure that best execution is achieved we will use benchmark pricing, with properly defined thresholds, and provide client disclosure of internally-generated fees and costs.

6. Execution methods

Subject to any express instructions that may be given by you (see section 7) we will execute an order by one of the following methods or combination of methods:

a) outside of trading venue by means of:

i. a different legal entity in the UBS group which itself acts as an execution venue where orders are executed; and/or

ii. execution by a different broker or market maker;

b) directly in a regulated market, MTF  or OTF, if we are not a direct participant in the relevant regulated market,  MTF or OTF; and/or

c) with a third party, if there is an agreement for executing orders in this regulated market or MTF with this party.

7. Express instructions of the client

If you give express instructions for executing an order (e.g. direct market access orders which are entered via an electronic system), we will execute the order in accordance with these. If your instructions only relate to part of the order, we will still apply our policy for executing orders to the part not covered by your express instructions.

Please note that under certain circumstances your express instructions for executing an order may affect our ability to get the best possible result for that order.

8. Receipt and forwarding of orders

Subject to any express instructions that may be given by you (see section 7), we can transfer an order to another legal entity in the UBS group or to a third party (e.g. an external broker) for execution. We would do this if the intermediary can prove that it has principles for executing orders which allow us to fulfill our best execution obligations to you. After checking the execution policies and methods of potential execution locations, we have decided that the execution venues listed in the appendix to this document best enable us to comply with our best execution obligations. We reserve the right to use other intermediaries if we deem these suitable.

9. Processing orders

We ensure that client orders are immediately and fairly executed in relation to other client orders and our trading interests. When executing orders, we ensure that:

a) all executed orders are immediately and accurately documented and assigned;

b) similar orders are executed immediately and in the sequence in which they are received, unless the order characteristics or the prevailing market position makes this impossible or the interests of the client require a different procedure; and

c) where practical, orders which are entered via several different media are processed with the aim of handling them in the sequence in which they are entered.

10. Limit orders

If you provide an instruction to place an order at a specific price limit or better, and/or for a specific size (a limit order), then it may not always be possible to immediately execute that order under prevailing market conditions. We are required to make client orders of this type public (disclose to the market) unless you expressly instruct us otherwise.

The Execution and Order Handling clause in our Terms and Conditions contains your express instruction. This means that by signing our Terms and Conditions you expressly instructed us not to make such orders public immediately unless you issue specific instructions to the contrary or we consider publication will be in your best interest.

11. Aggregation and allocation of orders

Client orders or transactions will not be carried out in aggregation with another client order unless:

a) aggregation of orders and transactions does not disadvantage any client whose order is to be aggregated; or

b) each client involved has been informed that the effect of aggregation may work to their disadvantage in relation to a particular order; and

c) the provisions relating to order allocation set out in our internal policies have been complied with.

In respect of market orders and limit orders, we should not withdraw or withhold client orders for our own convenience, or for the convenience of any other party. If we aggregate an order with one or more other orders and the aggregated order is partially executed, we must allocate the related trades promptly and fairly in accordance with our relevant internal policies.

12. New issues procedures (IPOs)

It is our policy that all clients are treated in a fair and transparent way when allocating new issues. Where new issues are oversubscribed and allocation is cut back, reallocation will generally take place on a pro-rata basis. Allocation will always be in the best interests of all relevant clients and reallocation will be done on a fair and reasonable basis.

13. Monitoring and review

We will regularly monitor how well we are following our arrangements for executing orders. If deficiencies are identified they will be corrected.

The policy and arrangements are reviewed annually and whenever a material change happens which might affect our ability to continue getting the best possible result for you. We will notify you of any material changes to the execution arrangements or our execution policy.

14. Top five execution venues publication

We will publish the following on an annual basis (for the preceding year):

a) the top five execution venues for each class of financial instrument, and;

b) the top five execution venues in terms of trading volumes for executed client orders, and;

c) information on the quality of execution obtained.

Please visit the UBS Wealth Management website and search 'best execution' for this information.

15. Client consent

This document provides information on the Order Execution and Order Allocation Policy we have put in place to meet our best execution obligations. You understand and accept the arrangements we describe within this document when you next place an order for execution with us. Where you only wish to receive discretionary portfolio management services, you understand and accept at the point you ask us to provide these services.

16. Definitions

execution venue - describes a regulated market, a MTF, an SI, an OTF, a market maker or different liquidity provider and/or an entity that performs a similar function.

financial instrument(s) – include, but are not limited to:

a) equities and stock market-traded investment funds (so called ETFs);

b) bond issues and money-market instruments;

c) securitised derivatives;

d) non-securitised and non-standardised derivatives traded on the open market; and

e) shares in open investment funds.

In order to rule out misunderstandings, "Financial instrument(s)" does not include "spot transactions".

MiFID II means Directive 2014/65 EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU.

multilateral trading facility ("MTF") - means a multilateral system, operated by an investment firm or a market operator, which brings together multiple third-party buying and selling interests in financial instruments – in the system and in accordance with non-discretionary rules – in a way that results in a contract in accordance with MIFID II.

organised trading facility ("OTF") - means a multilateral system which is not a regulated market or an MTF and in which multiple third-party buying and selling interests in bonds, structured finance products, emission allowances or derivatives are able to interact in the system in a way that results in a contract.

regulated market ("RM") - means a multilateral system operated and/or managed by a market operator, which brings together or facilitates the bringing together of multiple third-party buying and selling interests in financial instruments – in the system and in accordance with its non-discretionary rules – in a way that results in a contract, in respect of the financial instruments admitted to trading under its rules and/or systems, and which is authorised and functions regularly and in accordance with MIFID II.

systematic internaliser ("SI") - means an investment firm which, on an organised, frequent, systematic and substantial basis, deals on own account when executing client orders outside a regulated market, an MTF or an OTF without operating a multilateral system.

trading venue means a regulated market, MTF or an OTF.

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Appendix: execution venues provided by UBS entities

UBS AG Jersey Branch, Wealth Management may route orders to another UBS entity for execution therefore the list of execution venues below includes those also used by other UBS entities.

Note that this list of execution venues is neither exhaustive nor fixed. It will be kept under review and updated in accordance with our order execution policy. We reserve the right to use other execution venues additional to those listed here where it is deemed appropriate in accordance with our order execution policy.

Where a UBS entity has received an order for execution, it will consider all sources of reasonably available information, including MTFs, local exchanges, brokers and data vendors to obtain the best possible result for the order. This list of execution venues applies to both retail and professional clients as we do not distinguish between categories of client when selecting an execution venue. 

Execution Venues as of September 2017

Country / Liquidity Pool

Execution Venue Name

Europe

 

Austria

Wiener Börse

Belgium

Euronext Brussels

Cyprus

Cyprus Stock Exchange

Denmark

NASDAQ OMX Nordic Exchange - Copenhagen

Finland

NASDAQ OMX Nordic Exchange - Helsinki

France

Euronext Paris

Germany

Börse Berlin

Germany

Börse Düsseldorf

Germany

Börse Hamburg

Germany

Börse Hannover

Germany

Börse Frankfurt

Germany

Börse München

Germany

Börse Stuttgart

Germany

Deutsche Börse Xetra

Greece

Athens Exchange

Ireland

Irish Stock Exchange

Italy

Borsa Italiana

Luxembourg

Bourse de Luxembourg

Netherlands

Euronext Amsterdam

Norway

Oslo Bors (incl. NFF (OTC))

Portugal

Euronext Lisbon

Spain

Bolsa de Madrid

Sweden

NASDAQ OMX Nordic Exchange - Stockholm (incl. NGM (OTC))

Switzerland

BX Berne Exchange

Switzerland

SIX Swiss Exchange

United Kingdom

London Stock Exchange (plus IOB)

Eastern Europe

 

Bulgaria

Bulgarian Stock Exchange

Croatia

The Zagreb Stock Exchange

Czech Republic

Prague Stock Exchange

Estonia

NASDAQ OMX Baltic  - Talinn

Hungary

Budapest Stock Exchange

Latvia

NASDAQ OMX Baltic  - Riga

Lithuania

NASDAQ OMX Baltic  - Vilnius

Poland

Warsaw Stock Exchange

Romania

Bucharest Stock Exchange

Russian Federation

Moscow Exchange

Serbia

Belgrade Stock Exchange

Slovakia

The Bratislava Stock Exchange

Slovenia

Ljubljana Stock Exchange

Middle East & Africa

 

Israel

Tel Aviv Stock Exchange

Kuwait

Kuwait Stock Exchange

Morocco

Casablanca Stock Exchange

Qatar

Qatar Stock Exchange

South Africa

Johannesburg Stock Exchange

Turkey

Borsa Istanbul

United Arab Emirates

Abu Dhabi Securities Exchange

United Arab Emirates

NASDAQ Dubai

United Arab Emirates

Dubai Financial Market

North America

 

Canada

Toronto Stock Exchange

Canada

TSX Venture Exchange

United States

NASDAQ

United States

NYSE - New York Stock Exchange

United States

NYSE American

United States

NYSE Arca

United States

OTC Bulletin Board

Latin America

 

Brazil

BM&FBOVESPA

Chile

Bolsa Comercio Santiago

Mexico

Bolsa Mexicana de Valores

Peru

Bolsa de Valores de Lima

Asia & Pacific

 

Australia

Australian Securities Exchange

China

Shanghai Stock Exchange

China

Shanghai Stock Exchange - Hong Kong Stock Connect

China

Shenzhen Stock Exchange

China

Shenzhen Stock Exchange - Hong Kong Stock Connect

Hong Kong

Stock Exchange of Hong Kong

India

The Stock Exchange, Mumbai // National Stock Exchange

Indonesia

Indonesia Stock Exchange

Japan

Nagoya Stock Exchange

Japan

Tokyo Stock Exchange

Korea, Republic of

Korea Exchange

Malaysia

Bursa Malaysia

New Zealand

New Zealand Stock Market

Philippines

The Philippine Stock Exchange

Singapore

Singapore Exchange

Sri Lanka

Colombo Stock Exchange

Thailand

The Stock Exchange of Thailand

Multilateral Trading Facilities

 

Aquis Exchange

 

BATS Europe

 

BATS Europe Dark

 

Bloomberg MTF

 

Chi-X

 

Chi-X Dark

 

Tradeweb MTF

 

Turquoise

 

Turquoise Dark

 

UBS MTF

 

Systematic Internalisers

 

UBS AG - PIN

 

Exchange Traded Funds

Country / Liquidity Pool

Execution Venue Name

Where instruments listed, same as Cash Equities markets

(see Cash Equities)

Bloomberg MTF

Tradeweb MTF

Fixed Income – Cash Bonds

Country / Liquidity Pool

Execution Venue Name

OTC

 

Various liquidity providers in the OTC-market as well as non-MIFID trading platforms and liquidity pools

European MTFs (RFQ-based)

 

Bloomberg MTF

MarketAxess MTF

Tradeweb MTF

European RMs/MTFs (CLOB-based)

 

Austria

Wiener Börse

Germany

Börse Berlin

Germany

Börse Düsseldorf

Germany

Börse Hamburg

Germany

Börse Hannover

Germany

Börse Frankfurt

Germany

Börse München

Germany

Börse Stuttgart

Germany

Deutsche Börse Xetra

Italy

Borsa Italiana (selected segments only)

Italy

EuroTLX

Netherlands

Euronext Amsterdam (selected segments only)

Switzerland

SIX Swiss Exchange

Securitised Derivatives & Convertible Bonds

Country / Liquidity Pool

Execution Venue Name

OTC

 

Interdealer-broker market (OTC) including UBS AG 

Bloomberg MTF

Tradeweb MTF

Europe

 

Austria

Wiener Börse

Belgium

Euronext Brussels

Finland

NASDAQ OMX Nordic Exchange - Helsinki

France

Euronext Paris

Germany

Börse Berlin

Germany

Börse Düsseldorf

Germany

Börse Frankfurt

Germany

Börse München

Germany

Börse Stuttgart

Greece

Athens Exchange

Italy

Borsa Italiana

Italy

EuroTLX

Netherlands

Euronext Amsterdam

Norway

Oslo-Bors

Portugal

Euronext Lisbon

Sweden

NASDAQ OMX Nordic Exchange - Stockholm

Switzerland

SIX Swiss Exchange

United Kingdom

London Stock Exchange

North America

 

Canada

Toronto Stock Exchange

Non-securitised Derivatives excluding ETD's

Country / Liquidity Pool

Execution Venue Name

OTC

 

Interdealer-broker market (OTC Closed Architecture)