Best execution policy

Version 1.0, valid from 15. september 2022

Best execution policy encompasses how Orders placed by Fundvest Clients are processed and transmitted for execution and measures that allow Fundvest to achieve the best execution result for its Clients. Fundvest with all its capacity aims to achieve that Orders are executed at the best price. Additional factors are taken into account when choosing Execution broker as described further in this policy.

As the scope of the services provided by Fundvest is limited to the reception and transmission of Orders, Fundvest uses third parties (such as other financial brokerage firms and commercial banks) for the execution of Orders. They make their own decision on selection of a specific Execution venue based on their own execution policy. Fundvest will closely monitor the quality of execution and will take appropriate remedial actions if any deficiencies are detected.

In case of any technical disruptions, e. g. errors, failures or loss of access to technical systems, where it is not possible to transmit an Order for execution in any of the ways described in this policy, Fundvest will take all reasonable measures in order to achieve the best possible result for the client. If Executing broker takes any actions in relation to changing or cancelling an Order of a Client of Fundvest, the Client will be bound by these measures, regardless if Fundvest has already accepted the Order and the Order has been transmitted for execution.

Additional factors that are used when selecting Executing brokers:

1. Regulatory status of the institution. Regulatory status will tell if the rules that institution is following are in line with the regulatory environment where Fundvest is licensed itself and if Fundvest is able to ensure the maximum compliance with applicable regulations.
2. Ability to deal with large volume of orders. Fundvest is going to check and ensure that the institution can handle large volume of Orders and Orders of any size.
3. General competitiveness. Fundvest will seek to establish multi-service commercial relations with Executing brokers. Also, Fundvest will seek to enhance them in order to stay competitive and achieve the best possible result for its Clients.
4. Technical resources (APIs). Fundvest will investigate the technical resources of Executing brokers and will seek to have the latest technology stack deployed and used to ensure the smooth and swift Order transmission and execution.
5. Reputation. Fundvest will enter into partnerships only with institutions that are with perfect reputation and have no outstanding regulatory or compliance issues.
6. Number of venues to which institution has access to. Fundvest will check if potential partner has access to sufficient amount of venues for intended execution.