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..

2.3 Financial Instruments

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

• Fixed Income Bonds

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.

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.