Best Execution Policy

DBS Bank Ltd
Best Execution Policy (Consumer Banking Group – DBS Wealth Management & Retail)

Introduction & Purpose

Reference is made to the MAS Notice on Execution of Customers’ orders (SFA 04-N16), in respect of the implementation of written policies and procedures for the following:
1. to place or execute customers’ orders on the best available terms; and
2. to place or execute comparable customers’ orders in accordance with the time of receipt of such orders,
commonly referred to as “Best Execution”.
This disclosure statement provides relevant customers with information on order execution under our Best Execution policy, including the considerations and approach taken by us to provide Best Execution for our customers in the execution of relevant trades.
To the extent that you maintain your trading relationship with the Consumer Banking Group division (DBS Wealth Management (Private Banking/Treasures Private Client/Treasures) or DBS Retail), it will be on the basis that you have read and understood this policy.

Definition and Scope

Best Execution refers to placement and execution of customers’ orders for capital markets products on the best available terms (taking into account a range of factors).
Best Execution applies when we place your orders directly on an execution venue, or with another capital markets intermediary or person dealing in capital markets products, for execution.
This policy applies to you as a DBS Wealth Management (Private Banking/Treasures Private Client/Treasures) or DBS Retail client.

Execution of orders

Depending on the type of product, we execute your orders directly with an intermediary or counterparty approved by us (“Approved Counterparty”) or an issuer approved by us (“Approved Issuers”). These counterparties and issuers are approved in accordance with our internal selection criteria and are subject to periodic reviews.
In certain exceptional circumstances (e.g. trading on a provisional basis, or to accommodate your request to trade in an unusual instrument), we may use execution venues or counterparties other than our pre-approved list of venues or counterparties. In such cases, we will nevertheless take steps to obtain the best possible execution outcome taking into account the various execution factors set out below.
If we experience material difficulty relevant to the proper execution or transmission of orders, we will inform you promptly upon becoming aware of the difficulty. Sometimes, due to exceptional circumstances (such as a disruption of the execution system or exceptional market conditions), we may exercise appropriate discretion to employ other methods of execution.
Where appropriate (e.g. for fixed income or structured products), we will seek multiple quotes for orders. Where multiple quotes are not available, we will exercise our professional judgment (factoring in for example, comparisons from other sources if available) to decide if the quote is reasonable and fair. For certain asset classes, we will transmit your orders to the DBS Treasury & Markets division (as the sole counterparty) in accordance with our order placement procedures; and the DBS Treasury & Markets division will in turn provide a quote in accordance with its Best Execution policy.

Client Order Handling

Individual orders will be promptly executed or transmitted sequentially in accordance with their time of receipt to an Approved Counterparty. Exceptions may apply if the characteristics of the order or prevailing market conditions make this impracticable, or if we deem it that your interests require otherwise.
For orders received outside the normal exchange business hours of the market, we will promptly transmit the order when exchange trading resumes.
If the order size has the potential to have a significant market impact, other considerations may apply and we will consider such an order as being outside the scope of this policy.

Execution Factors
General Execution Factors

In order to achieve the best possible execution outcome for you, we will consider a range of execution factors relevant to the placement or execution of the orders. Although some of the factors below are more important than others, there are situations where the relative importance of these factors may change.
The execution factors that we will consider are (not in any order of priority):
1. Price: this is the price a capital markets product is executed at;
2. Costs: this includes implicit costs such as the possible market impact, explicit external costs e.g. exchange or clearing fees and internal costs that are incurred/payable by us to parties involved in execution of your order;
3. Speed: the time it takes to execute your order;
4. Likelihood of execution and settlement: the likelihood that we will be able to complete your order;
5. Size and Nature: the order size and how the characteristics of your order can affect how Best Execution is achieved;
6. Overall relationship and service quality provided by counterparty through life cycle of transaction and consideration of other services (e.g. research support, access to IPOs / new issues) provided by counterparty;
7. Any other circumstance which, in our opinion, is relevant to the execution of an order.
In order to determine the relative importance of each execution factor, we will consider:
1. the characteristics of the execution venues or brokers to which the order can be directed;
2. the characteristics of the order; and
3. the characteristics of the capital markets product.
Where a capital markets product is traded on multiple execution venues and/or may be executed via multiple Approved Counterparties, we will consider having the trade executed on the market where liquidity is highest, as this would likely be the most appropriate option for the client with advantageous execution in terms of price, execution speed and probability of settlement.

Specific instructions
When executing specific instructions from you to execute or transmit an (or part of an) order in a certain way, we will have satisfied our Best Execution obligation if we comply with your specific instructions. Examples of such instructions may include, but are not limited to, requests to execute on a particular venue or to execute an order over a particular timeframe.
Where your instruction relates to only part of the order, we will continue to apply the Best Execution principles to those aspects of the order not covered by your specific instructions.

Execution Venues and Approved Counterparties
Selection and onboarding

When executing and transmitting your orders, we will use Approved Counterparties selected by us based on the following procedure.
We select the Approved Counterparties (such as brokers or other investment firms) or Approved Issuers based on a selection procedure, which encompasses qualitative factors, such as:
1. Creditworthiness and reputation;
2. Access to execution venues;
3. Range of products, product innovation and pricing competitiveness;
4. Connectivity;
5. Regional market coverage;
6. Sales trading information;
7. Access to facilitation and to market makers’ prices;
8. Access to Clearing Houses and connectivity for settlement;
9. Quality of Middle and Back Office support; and
10. Other considerations (e.g. research support, access to IPOs and new issues).
Monitoring of Approved Counterparties and Policy Review
We perform due diligence monitoring on our Approved Counterparties and Approved Issuers on a regular basis.
Due diligence is also carried out on the Approved Counterparties’ affiliates, connected parties or third parties engaged for execution, and a systematic process is in place to continuously monitor execution outcomes. Factors that will be considered include transaction cost analysis, performance and trade support services.
We have also put in place appropriate arrangements for the periodic monitoring and review of our Best Execution Policy and its related processes.

Updates to Best Execution Policy

We will review our Best Execution Policy on a periodic basis and reserve the right to update it as appropriate.
If you require further information on our Best Execution Policy, please contact your relationship manager or contact DBS.

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