Guidelines for best execution

ODIN undertakes to implement all reasonable measures to achieve best execution for the mutual funds it manages and for its customers when carrying out orders. ODIN Forvaltning has guidelines in place to ensure best execution. Below is a summary of guidelines.

In the case of investment decisions made on behalf of the mutual funds or individual customers, ODIN Forvaltning is to conduct a specific assessment of how and where the order is to be executed in order to achieve the best possible result. When choosing the method of execution, the price, costs, promptness, likelihood of execution and settlement, size, nature and any other relevant conditions will be taken into account.

When ODIN Forvaltning carries out orders on behalf of customers, the following elements will be taken into consideration in the assessment:
• the customer’s knowledge and experience (retail or professional client)
• the properties of the customer’s order
• the properties of the financial instruments to which the order refers
• the properties of the trading systems in which the order may be placed

When ODIN Forvaltning carries out orders on behalf of the mutual funds, the following elements will be taken into consideration in the assessment:
• the mutual fund’s objective, investment policy and risks as these are stated in the prospectus and possibly articles of association
• the nature of the order
• the properties of the financial instruments stated in the order
• the properties of the trading systems in which the order may be placed

ODIN Forvaltning will carry out orders for customers and/or mutual funds in one of the following ways:
• by placing the order in a trading system (regulated market, MTF, market maker, etc)
• by transmitting the order to an investment firm
• by buying from or selling to other customers (reciprocal trading)
• by subscribing for mutual fund units with the party that the fund has selected to receive subscriptions

ODIN Forvaltning has a separate routine for selecting brokers, and chooses investment firms based on such considerations as the firm’s expertise and commercial conditions, including the price compared to the service provided. A payment (commission) will not necessarily cover the same services in different investment firms, so ODIN Forvaltning is not obliged to always choose the firm with the lowest commission. If a firm provides a wider or better service that is better suited to the customer’s or fund’s needs than the firm with the lowest commission, the consideration of best execution may lead to the cheapest firm not being chosen. The assessment is to consider what is the best possible result for the customer or the mutual fund as a whole.

If ODIN Forvaltning is to both buy and sell the same financial instrument on behalf of customers and/or a mutual fund and the orders can be matched internally, ODIN Forvaltning will normally enter into contracts on behalf of the customers and/or the mutual funds. ODIN Forvaltning will safeguard the parties’ interests with the utmost care and determine the price in accordance with further defined rules. A prerequisite for such an internal trade being executed is that it must be possible to document the sales and purchase needs of the customers/funds involved.

ODIN Forvaltning has several internal control mechanisms governing assessments of best execution and choice of method of execution.