Ramek Asset Management Limited

Best Execution Policy

Version 2

December 2019

 

1       Overview

1.1      Introduction

This Best Execution Policy intends to provide the client with the information that the Firm believes they need in order to understand how the Firm will achieve the best possible results for the client in accordance with the Markets in Financial Instruments Directive 2014/65/EU (MiFID II).  This policy is available via the Firm’s website and copies can also be provided upon request.

1.2      What is Best Execution?

Best execution is the requirement for firms to take ‘sufficient steps’ to provide the client with the best possible overall results on a consistent basis, and not just by providing the best price for an individual trade.  To do this, the Firm will take into account execution factors such as price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration considered to be relevant to the execution of client’s order.  The importance that is placed on these execution factors depends on the characteristics of the client, the order, the financial instrument and execution venue and are discussed further on in this policy. When providing discretionary management and advisory services to clients, we must act in accordance with the best interests of our clients. This applies when placing orders with trading entities or using venues for the execution of trades which result from our investment decisions for clients. Reference to orders, where applicable, means both orders placed resulting from our investment decisions or where orders are received from the client

The Firm has a duty to act honestly, fairly and professionally in executing client orders and when passing orders to other entities for execution and the Firm will check the ‘fairness’ of the price proposed to the client.

1.3      Delivery of Best Execution

The Firm is responsible for executing orders and transmitting orders and as such is responsible for providing best execution and procuring best execution for those orders.

1.4      Executing outside of a ‘trading venue’

Where there is a likelihood that orders will be placed outside of a trading venue, the Firm will proceed with placing the order unless specifically told otherwise.

 

2       Scope

The Firm is authorised and regulated by the Financial Conduct Authority to offer clients the investment services and financial instruments mentioned in this policy.

2.1      Clients

This policy applies to Professional Clients.  In accordance with the Firm’s obligations to the client, it has notified the client of the client classification that applies to them.  Once the client has accepted their client categorisation, they may not elect to be re-classified for the purposes of a particular transaction as their categorisation must be consistent across all transactions that they undertake.

2.1.1.1      Total Consideration

2.1.2       Professional Clients

When dealing with Professional Clients, the Firm does not differentiate between an ‘elective’ Professional Client or a ‘per se’ Professional Client.  The Firm will apply best execution where it has agency or contractual obligations to the client and in circumstances where it can be demonstrated that the client is legitimately relying on the Firm in relation to the execution of the order.

2.2      Activities

Ramek Asset Management provides clients with fixed income investment management, advisory and execution Services in pure vanilla corporate bonds, high yield bonds and government debt / rates in hard Currencies EUR,USD,GBP. Geographic areas covered are Europe, USA , Emerging Markets , MENA region and Asia. We also provide clients with equity investment in European, US and Asia Stocks as well as IPO’s.

2.3      Financial Instruments

The following financial instruments are within the scope of this policy:

  • Fixed Income Bonds
  • Equities

2.4      Exemptions

Notwithstanding the intentions expressed above, the Firm does not undertake to provide “best execution” if the client falls within any of the following exemptions:

2.4.1       Client Instructions

Where the client provides the Firm with a specific instruction in relation to their order, or any particular aspect of their order, including an instruction for their trade to be executed on a particular venue, the Firm will execute the order in accordance with the client’s instructions.

However, please note that in following the client instructions, the Firm will be deemed to have taken all reasonable steps to provide the best possible result for the client in respect of the order, or aspect of the order, covered by their specific instructions.

 

3       Best Execution Obligations

3.1      Executing/Transmitting

In executing orders and transmitting orders, the Firm has a duty to act in the client’s best interests.  In doing so, the Firm will undertake to select venues where it has been able to demonstrate that it is able to deliver the best possible results for the client.

3.2      Execution Factors

In the absence of express instructions from the client, the Firm will exercise its own discretion in determining the factors that it needs to take into account for the purposes of providing the client with the best possible result.

These execution factors have been listed in order of priority and will include, but are not restricted to, the:

  • Liquidity (Venue that has the best Liquidity for the Bond or Stock in Question)
  • Price (Best Available Price)
  • Ability to Deal (size of transaction concerned)
  • Knowledge of Security (whether the liquidity provider trades the Bond/Stock)
  • Reputation (some execution venues or liquidity providers may specialise in particular Bonds or Stocks)
  • Speed of Execution

3.3      Execution Venues

The Firm has selected the following venue(s) on which to execute orders and to whom orders are transmitted:

Fixed Income Bonds – Bloomberg ALLQ, as a Multi-Lateral Trading Facility provides us access to the market where we will look to execute. A selection of counterparties are considered via Telephone or Bloomberg IB chat and message runs with the counterparty offering the best solution as determined by our execution factors chosen. At times we may use brokers to source us the best solution outside of the above arrangements.

Equities – We use brokers to execute our equity trades and therefore in these circumstances we transmit order to the chosen broker for them to execute.

When selecting the Firm take reasonable measures to ensure that they obtain the best possible trading result for its clients, subject to the following factors. The firm have a process in place for all brokers and counterparties. This will typically include a due diligence process which involves regulatory checks and a review of the firm’s execution policy and processes

 

4       Monitoring

The Firm will monitor the effectiveness of its order execution arrangements and order execution policy in order to identify and, where appropriate, incorporate any amendments to procedures.  The Firm will monitor the prices available in the wider market to make sure that its executing parties are offering fair prices and that they continue to provide the best results for clients.

The Firm will assess, on a regular basis, whether the execution venues included in the order execution policy provide for the best possible result for clients or whether it need to make changes to its arrangements.

The Firm will review its order execution arrangements and order execution policy at least annually or whenever a material change occurs that affects its ability to continue to obtain the best possible result for the execution of client orders on a consistent basis using the venues included in its order execution policy.

 

5       Material Changes

The Firm will notify clients of any material changes to its order execution arrangements or order execution policy as described above by posting the information on its website.

 

6       No Fiduciary Relationship

The Firm’s commitment to provide clients with “best execution” does not mean that it owes clients any fiduciary responsibilities over and above the specific regulatory obligations placed upon it or as may be otherwise contracted between the Firm and clients.

Clients remain responsible for their own investment decisions and the Firm will not be responsible for any market trading loss clients suffer because of those decisions.

 

Ramek Asset Management Limited

Conflicts of Interest Policy

 

Version: 2.0

December 2019

 

1       Purpose

This policy details how Ramek Asset Management (the Firm) will identify and manage conflicts of interest in respect of its business activities.

The Firm is authorised by the Financial Conduct Authority (FCA) and, as such, will act in accordance to the Conflicts of Interest rules as defined in the FCA Handbook, which will take precedence over the requirements of this policy.

2     Review of Policy

This policy will be reviewed regularly, at least once a year, and amended as considered necessary by the Firm’s Management Body in the event of changing circumstances or regulations.

3      Responsibilities

The CEO of the Firm is responsible for ensuring that its systems, controls and procedures are able to identity, manage and control or prevent any potential and actual conflicts of interest that may arise.

4      Definition

A conflict of interest is a situation in which someone in a position of trust to the client has competing professional or personal interests. Such competing interests can make it difficult for individuals to fulfil their duties to their clients impartially.  A conflict of interest may exist even if no unethical or improper act results from it.

Conflicts of interest arise when in the course of providing a service to a client, the Firm, or its employees:

  • Are likely make a financial gain or avoid a loss at the expense of the client
  • Have an interest in the outcome of the service provided which is distinct from the client’s interest
  • Have a financial or other incentive to favour the interests of another client over the interests of the client
  • Carry on the same business as the client
  • Receive, from a person other than the client, an inducement in relation to the service provided to the client, other than the standard commission or fee for that service

5       Identifying, managing and preventing conflicts of interest

The Firm has reviewed its business model and has identified the following potential conflicts of interest:

  • Employee Roles and Responsibilities
  • Management of Employees
  • Remuneration
  • Business interests
  • Connected persons
  • Inducements including Gifts and Hospitality
  • Personal account dealing
  • Customer orders versus firm business

The Firm will regularly review its business model to ensure any new potential conflicts of interest are noted and managed or prevented effectively.

5.1      Employee Roles & Responsibilities

The Firm maintains a clear segregation of roles and responsibilities within the Management Body to maintain an effective control environment and to avoid conflicts of interest in roles wherever possible. The governance structure is as follows:

 

 

5.2      Supervision and Management of Staff

Staff will be based in London. Due to the number of UK based employees, it is not possible to physically segregate staff with access to sensitive data that may give rise to conflicts of interest at this time, however, as the business grows the requirement to establish such controls will be considered.

Employees will receive training on understanding their obligations in this area.

5.3      Remuneration

The remuneration of staff will be assessed annually in accordance with the Firm’s appraisal process and usually consists of a retainer and performance related profit share.  The Firm strives to ensure our employees remain motivated whilst at the same time ensuring that this remuneration scheme does not encourage inappropriate behaviour.  In order to prevent a conflict of interest, the remuneration of employees is linked to profits and the remuneration structure takes into account a number of different factors including a good standard of compliance.  The Firm’s Remuneration Policy is in place and will be adhered to.

5.4      Business Interests

The Firm recognises that our current and future employees may have an interest, relationship or arrangement whereby they act as a trustee, hold power of attorney or have a Directorship that may potentially create a conflict of interest.  The Firm requires its employees to declare any such interests and will take the appropriate steps to manage or prevent any conflicts of interest that are identified.  To manage such conflicts, the Firm requires its employees to disclose Directorships and interests in other companies and to disregard the interest, relationship or arrangement concerned when acting on behalf of clients.

5.5      Connected Persons

The Firm is aware of its duty to avoid a conflict of interest arising where an employee has an indirect interest through a connected person (e.g. adult child or spouse).  Relevant employees are required to disclose any potential conflicts of interest through connected persons. To manage such conflicts the Firm requires its employees to disclose the interests and to disregard the interest when acting on behalf of clients.   

5.6.         Inducements including Gifts and Hospitality

The Firm has a strict policy, which specifically prohibits employees from soliciting or accepting any inducements to conduct business in a specific manner that would give rise to a detriment to a client or to favour the interests of one client over another.

The Firm recognises that Gifts and Hospitality can lead to potential conflicts of interest.  Employees are not permitted to accept, or give to, any person any gift or other benefit that cannot properly be regarded as justifiable in all circumstances or may give rise to the perception that in doing so, decisions may be influenced or may not be impartial.  All employees are expected to act with the highest standards of integrity to avoid any allegations of conflicts of interests.

The Firm requires any employee who is offered any kind of gift or payment over an agreed limit from either inside or outside the Firm to report this to the Firm’s Nominated Officer for recording on the Gifts & Hospitality Register.  In addition, any indications of expectation of support following a gift or hospitality of any value should be reported to the Nominated Officer.

The Nominated Officer will regularly review the Gifts & Hospitality Register to identify any conflicts of interest that may be occurring.

The Firm’s Gifts and Hospitality Policy contains further information and the agreed value limits set by the Management Body.

5.7      Personal Account Dealing Policy

The Firm recognises that employees dealing on their own personal account may present conflicts of interests. In order to manage actual or potential conflicts that may arise from personal account dealing, the Firm has a Personal Account Dealing Policy in place.

5.8      Customer Orders

The Firm’s Best Execution Policy requires employees to take all reasonable steps to achieve the best overall trading result for clients; to exercise consistent standards; and operate the same processes across all markets, clients and financial instruments in which it operates.

There may be occasions when clients’ orders may have a material effect on a relevant price. In order to ensure that a broker does not take advantage of the situation by dealing on his/her own account or encouraging a third party to deal, the Firm has a strict “no front running” policy.

In order to ensure a fair and orderly dealing environment within the market, the Firm requires its employees to comply with its Market Conduct Policy, as well as the relevant FCA Rules, which aim to prevent insider trading, the misuse of information and market manipulation.

6       Disclosure or declining to act

Conflicts of interest that the Firm cannot manage or prevent will be logged on the Conflicts of Interest Register (Annex 1) and the Firm will either inform the client or decline to act for the client.  The Conflicts of Interest Register will be provided to the Management body for review at least annually.

6.1      Disclosure

As a last resort, where there is no other means of managing the conflict or where the measures in place do not, in the view of the Firm, sufficiently protect the interests of clients, the conflict of interest will be disclosed to clients, to enable an informed decision to be made by the client as to whether they wish to continue doing business with the Firm in that particular situation.

The disclosure will be in writing and will include:

  • A statement that the arrangement in place by the Firm are not sufficient to ensure that the risk of damage to the interests of the client will be prevented
  • A description of the specific conflict of interest
  • An explanation of the risks to the client that arise as a result of the conflict of interest
  • Sufficient detail to enable the client to make an informed decision as to whether to proceed or not.

6.2      Declining to Act

Where the Firm considers that it is not able to manage the conflict of interest in any other way, it may decline to act for a client.

7     Breaches of Conflicts of Interest Policy

Any breaches of the Conflicts of Interest rules will be recorded on the Firm’s breach log in conjunction with its Regulatory Breach procedure.