Baring Asset Management
Execution Policy
Professional Clients
April 2024

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Contents
Execution Policy ..................................................................................................................................................... 3
Order Placement .................................................................................................................................................... 3
Execution Factors And Their Relative Importance ............................................................................................ 4
Execution Strategies and Practices ..................................................................................................................... 4
Assessing Fairness of OTC Transactions .......................................................................................................... 4
Monitoring ................................................................................................................................................................ 5
Policy Review ......................................................................................................................................................... 6
Appendix A - Equities, ETF’s, Equity Derivatives .............................................................................................. 7
Appendix B - Fixed income – private and public debt and derivatives ............................................................. 8
Appendix C – FX and FX derivatives .................................................................................................................10
Appendix D – List of Counterparties and Execution Venues ..........................................................................11

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This document applies to Baring Asset Management Limited and Baring International Investment
Limited, Barings (U.K.) Limited, (together “Barings”).

Execution Policy
Barings execution policy details how Barings obtains the best possible result for its clients when
executing orders. Barings will take all sufficient steps to satisfy that it has the necessary processes inplace to lead to the best possible outcome for its clients. Barings cannot guarantee that it will always
be able to provide best execution on every order executed on behalf of its clients. The policy has beendrafted based on providing services exclusively to non-retail clients.
Detailed information on all execution factors are broken down by asset class in these Appendices:
Appendix A for Equities, ETFs and Equity Derivatives;
Appendix B for Fixed Income (FI) and Fixed Income Derivatives; andAppendix C for Foreign Exchange (FX) and FX Derivatives
Barings is required to provide appropriate information regarding best execution to its clients and to obtainthe consent of each client to its best execution policy. Barings shall obtain the prior consent of each newclient to its best execution policy.

Order Placement
Barings can place trades outside of the EU with Barings affiliated entities as long as permissible perclient agreements.
Equity orders are placed, indirectly, via Brokers, (the execution venues) and electronically in the majorityof cases; where this is the case Barings is owed a duty of best execution. When equities are traded ona Multilateral Trading Facility (MTF), this will always be via a broker (indirectly).
If Barings were to execute an equity order directly against an execution venue (Appendix A) Barings
would have a duty to provide best execution to its client.
Fixed income orders are deemed Over-the-Counter (OTC) and are generally placed directly via thefollowing practices:a ) Electronic trading platform: Trade Web, Bloomberg, BondTrader (TSOX), MarketAxess &Liquidnetb ) Over the phone; andc ) Via Bloomberg IB chat
In a primary syndication, the order will be placed with the lead arranger covering Barings. In a secondary
market trade, orders will be placed with a broker selected in accordance with the execution factors
outlined in Appendix B where there is a public market for the asset.
Client consent is granted via the account opening documentation for any fixed income OTC transactions
outside of a trading venue. Transactions undertaken outside of a trading venue increase the potential
for counterparty credit risk.
All FX, Euro Commercial Paper (ECP) and some Currency Option transactions are classified as OTC
products. OTC is a security traded in some context other than on a formal exchange. Some FX
transactions will be placed via a MTF.
In all scenarios, Barings will owe best execution to its clients.
a) For the Authorised Counterparty List for equities, fixed income and FX, please refer toAppendix B.
b) In respect of each class of financial instrument and the factors affecting the choice of venue
please refer to Appendices C – E.
c) Barings takes into account its own execution commissions and costs for executing an order oneach of the eligible execution venue. Barings has a standardized execution commission
schedule for equities. These are negotiated and analysed on a regular basis, against
independent third-party peer group data.
d) Where Barings receives a specific instruction from one of its clients, Barings will execute theorder in accordance with that specific instruction. It should be noted that any specific
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Corporainstructions received from its clients may prevent it from taking some or all of the steps that
Barings has designed and implemented as part of its execution policy designed to achieve
best execution.
e) Barings does not receive third-party payments or non-monetary benefits in relation to its
selection of execution venue.

Execution Factors And Their Relative ImportanceBest Execution is executing an order with the intention of achieving the best possible outcome forBarings clients, in the particular circumstances at the time, using a counterparty Barings believes willachieve the best outcome and efficiently settle the trade. It is Barings’ intention to achieve best
execution on a consistent basis equally for all clients.
The primary responsibility for ensuring the quality of trade execution resides with the trader. The trader
will take into consideration the market conditions at the time a trade instruction is received andthen determine when, where and how the order should be traded. The trader will always seek toobtain the best overall quality of execution for clients under the prevailing circumstances at the time of
trading.
Below are the main factors that Barings takes into account when deciding how to achieve best
execution. They will differ in their relative importance from transaction to transaction and between asset
classes:• Price• Size• Liquidity• Speed• Likelihood of execution & settlement• Cost• Nature
This policy seeks to determine the relative importance of the execution factors in the execution process.
Whilst price and dealing cost plays an important part of the trader’s decision-making, they may also take
into consideration a range of different factors when undertaking the execution. Barings traders aim to
select venues that enable them to take all sufficient steps to obtain the best possible result for the
execution of client orders on a consistent basis. Please refer to Appendices B-E for further information.
The relative importance of the execution factors varies from transaction to transaction. In most cases,
the price achieved and costs incurred will be the primary execution factors in gaining the best possible
outcome, although there will be occasions when other execution factors have equal weighting. For
instance, for a less liquid instrument, the size and nature of the order and likelihood of execution might
be as important as price and cost. There may also be times when there is breaking news or other periodsof volatility when both speed to market and the ability to complete an order quickly are as important.

Execution Strategies and Practices
Barings traders will utilise different trading strategies across a range of asset classes, instruments
and markets. Please refer to Appendices F - H for further information.
Each Trading Desk has specialist traders with considerable experience trading in varying
market conditions. They have access to a range of electronic trading tools and other sources ofliquidity.
Each of the equity and fixed income trading team reviews performance of its different trading
venues on an on-going basis, utilising independent third-party Transaction Cost Analysis (TCA) andbroker provided TCA. Where traders have concerns, they will change the way they interact with or
refrain from trading with venues. Please see Appendix A for further information.

Assessing Fairness of OTC Transactions
The fairness of an Over-the-counter (OTC) transaction for fixed income orders is assessed using a
number of different sources. The experience of the trader and price indicators in the market willassist with such an assessment. The trader will seek to gather market data and locate available
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prices for the relevant asset or similar or comparable asset types, and the trader may also seek
offer or bid quotes from the market, including via brokers. The Barings valuation committee reviews
the price obtained for such transactions and will seek additional information where there is a material
difference between the mark-to-market and the price obtained in order to be satisfied that any
differences are reasonable and within an appropriate tolerance. The Barings valuation committee’s
tolerance level is set at 2.5% for fixed income and 10% for equity.

Monitoring•

Barings monitors the effectiveness of its order execution arrangements and execution policyin order to identify and, where appropriate, correct any deficiencies.

•

Barings assesses, on an on-going basis, whether the execution venues included in thepolicy provide for the best possible result for the client. The Trading Desk and Complianceindependently carry out these tasks.

•

Barings carries out specific analysis to determine whether or not other suitable counterparties
and execution venues meet our requirements•

Barings will notify clients of any material changes to the execution policy.

•

The Trading Practices Committee reviews independent and internal Transaction Cost
Analysis (TCA) against industry standard benchmarks.

•

Barings monitor reports that are generated by brokers and actions accordingly.

Due diligence, oversight & monitoring of electronic trading for all asset classes
All trading applications (including algorithms) are sourced from third party suppliers. Before Barings
on-boards third party trading algorithms, it undertakes a programme, including the use of due
diligence questionnaires, to ensure it understands the set-up of the broker’s electronic trading desk andhow its products are tested before being released to clients. Each trader undertakes sufficient training
and must pass a competency test. Annually Barings sends a DDQ to each algorithmic broker and thetraders undertake annual refresher training on the various nuances of each algorithmic strategy.
The Trading Desk and the Compliance Department analyse executed trades and undertake post trademonitoring.
Transaction Cost Analysis (TCA)
Barings monitors ‘best and timely execution’ using independent third-party TCA services for equities.
Through this analysis, Barings evaluates more effectively on the quality of trade execution, thetransaction costs from brokers, the liquidity provided by trading venues, as well as the investment
manager’s decision to assess the value added on each trade.
The results of the analysis are presented by the TCA provider to Barings on a quarterly basis.
In addition, each equity trader in London and Hong Kong is required to send a weekly summary of theirtrading performance as measured by the TCA provider to the Compliance department. The reportmeasures the trader’s performance against proprietary post trade benchmarks measured by the TCA
provider.
Barings monitors ‘best and timely execution’ of FX trades using an independent third-party TCA service(Amaces) as well as our own Barings Dealing Desk macro that is run nightly using Bloomberg data. The
result of this analysis is presented for discussion and further oversight at the quarterly Trading Practices
meeting.
Through this analysis Barings evaluates the quality of the trade execution. The results of the analysis arepresented by the TCA provider to Barings’ on a monthly basis and presented for discussion and further
oversight at the quarterly Trading Practices Committee.
Independent Compliance monitoring is undertaken and involves a monthly dealing review to assess
timely and best execution, using in house data, third party data, along with external news data andanalysis. The best execution analysis is derived from a comparison of benchmark indices and/or priceBarings5
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Corporadata. Costs, markets and liquidity are key elements for assessing both best execution and timely
execution. Compliance also reviews order aggregation and allocation to ensure that clients have not been
unfairly advantaged or disadvantaged.
Best Execution – Reports from Execution Venues
Execution venues, which include trading venues (brokers), Systematic Internalisers (SIs) and otherliquidity providers trading over the counter (OTC), are required to produce a quarterly report for every
single instrument they quote or trade. Barings utilises some of the data to help determine if thecounterparties are delivering best execution.

Policy Review
The equity, FI, FX & derivative trading teams review this Execution Policy annually or as soon as asignificant event occurs. Compliance will also perform a periodic review of this policy to determine its
accuracy and effectiveness and any areas needing attention will be promptly addressed.
A significant event is defined as one where Barings considers that there is a material change in the waythat it determines Best Execution.
Examples of a significant event might include, but are not limited to:••Changes in market structure that Barings considers may have a material impact; andRegulatory change.

These events may cause Barings to reconsider how it uses a venue and or execution venue.
When Barings determines a significant event has taken place, it will publish a revised version of thispolicy at the earliest opportunity on its website.

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Appendix A - Equities, ETF’s, Equity Derivatives
Execution Venue Selection
Barings currently does not trade directly with an execution venue for equity transactions however, should
Barings decide that in order to meet best execution it is necessary to do so, the following criteria will need
to be met:
• Qualitative factors such as clearing schemes, circuit breakers, scheduled auctions, antigaming logic or any other relevant consideration, and the relative importance of each factor.

Factors Used to select a Venue (Broker)
•
•
•
•
•
•

Price: Achieving the best possible priceSize: Block trade
Liquidity
Speed: Expediency of the execution is decided by the trader
Likelihood of execution and settlement: Authorised Counterparty list
Cost: Standardised commission schedule (reviewed and negotiated regularly)

The priority of importance of the execution factors varies from transaction to transaction.
In most cases achieving the best price for the trade size will be the primary execution factors in gaining
the best possible outcome, although there will be occasions when other execution factors have equal
weighting, e. g. for a less liquid instrument, the size and likelihood of execution might be as important as
price and cost. There may also be times when there is breaking news or other periods of volatility whenboth speed to market and the ability to complete an order quickly are just as important.

Strategies Employed•

Algorithmic Trading (Low Touch): Barings uses selected brokers’ Algorithmic trading suites inorder to utilise specific electronic trading strategies (e.g. liquidity seeking, volume participation,
dark, lit, Direct Market Access (DMA), etc.).
Algorithmic trading offers speed, control, anonymity as well as access to different pools of
liquidity. Algorithmic trading helps Barings to reduce signaling to the market.

•

Sales Trader (High Touch): Barings’ traders may choose to instruct a Sales Trader to executeorders on an agency basis. Barings’ traders and the Sales Trader maintain a regular dialogue
throughout the lifecycle of the order.

•

Block Crossing (High & Low Touch): Barings will look to cross blocks electronically in MTFs,
Dark Pools and Broker “naturals” (inventory) in order to reduce market impact. Barings will also
look to cross blocks with a Sales Trader (High Touch)•

Programme Trading (Low Touch): Barings uses programme trading as an effective way ofmanaging the execution quality of a large number of orders with the same benchmark.

•

Crossing (High & Low Touch): Where there is the opportunity to cross trades between clients’portfolios, Barings will only do this where the relevant investment managers determine it to be in
the best interest of each client and there is no restriction in the Client Mandate or regulations.

•

RFQ (Low Touch): Barings employs a request for quotation for the purpose of inviting a numberof market makers to make competitive prices.

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Appendix B - Fixed income – private and public debt and derivatives
Factors Used to Select a Venue – Primary Markets
Barings will conduct a detailed analysis of each opportunity to lend or subscribe for private or
public loan or bond debt in the primary markets.
The Barings [Investment Policies and Procedures Manual] contains further details on the orderprocess for primary market debt. This will culminate in an Investment Committee meeting at which
it is assessed whether to proceed with the investment and how much of an allocation (if any) Barings
should seek to obtain in aggregate.
In a primary syndication, the Lead Arranger will allocate to Barings an amount of each target
investment. The portfolio manager decides how to allocate this investment across the various funds
in accordance with Barings’ allocation policy. Barings maintains a more detailed procedure on
allocation in its [Investment Policies and Procedures Manual].
In the primary markets for syndicated debt, the only execution venue Barings typically uses is a
Lead Arranger or an affiliate of a Lead Arranger. The price of the issue is determined by such Lead
Arranger or such affiliate based upon market indications and capacity.

Factors Used to Select a Venue – Secondary Markets and Derivatives
•
•
•
•
•
•

Price: Achieving the best possible priceSpeed: Expediency of the execution is decided by the trader
Likelihood of execution and settlement: Authorised counterparty list
Cost: Agency transfer and transaction fees and expenses
Size: Avoiding significant adverse movements
Review: Regular broker reviews

Price is generally the most important factor, however, the priority of importance of the execution
factors varies from transaction to transaction and there will be occasions when o t h e r execution
factors have equal weighting. For example, for less liquid instruments, the size and likelihood of
execution might be as important as price and cost. There may also be times when there isbreaking news or other periods of volatility when both speed to market and the ability to complete
an order quickly are just as important.
In the private debt market there are no publicly quoted prices. Where appropriate, Barings will
generally contact only one or a very limited number of brokers to ascertain best price. This method
is preferable to calling several brokers for quotes because, if Barings were to take that approach,it could lead to an adverse movement in the price of the proposed investment. The broker contacted
will typically offer his or her best price on the basis of Barings’ position in the market and thefact that Barings would not continue to do business with a broker which repeatedly failed to offer
the best price.
It will often be important to ensure that a transaction can be executed quickly. Barings will haveregard to the record of brokers with whom it has previously dealt in ascertaining the likelihood thata broker will in fact execute the transaction promptly rather than going back into the market to finda counterparty for the transaction; this delay could both increase the price and make it less likely thatthe transaction will in fact reach execution.
Barings will prefer brokers or other counterparties with whom it has not experienced historic settlement
or execution delays. For any settlement on and above the agreed terms of the debt trade (usually
T+2), the buyer may receive delayed compensation from the seller until the date of actual settlement.
Delayed compensation equates to the margin earned on the asset.
For syndicated debt, where the other factors above are equal between different brokers, Barings will
typically trade in the loan market with the syndicate agent, who is able to either waive or reduce its
transaction fees. This will generally result in a cost saving for Barings’ clients. However, in the eventof a large trade, Barings may seek to spread the order around a number of brokers to avoid asignificant adverse movement in the price of the relevant investment.

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Barings conducts reviews of its brokers periodically to identify whether particular brokers haveparticular strengths. The primary consideration in determining which broker to use is the price which
Barings perceives it can achieve from the relevant brokers on a consistent basis.

Factors Used to Select a Venue – Transactions Between Clients
Where Barings has a favourable view of a particular investment, it will seek to retain it within its or
its affiliates' clients’ portfolios, subject to clients’ capacities and credit ratings. Barings does not churnsecurities.
In the event that Barings transfers investments between such portfolios or transacts with the GIA(whether allocated to Massachusetts Mutual Life Insurance Company or to CM Life Insurance
Company) the principal execution factor is price. Other key factors, such as speed, likelihood of
execution and settlement, and size, will be within Barings’ control.

Strategies Employed•

Sales Trader (High Touch): Barings’ traders may choose to instruct a Sales Trader to executeorders on an agency basis or to create a market for the asset. Barings’ traders and the Sales
Trader maintain a regular dialogue throughout the life of the order.

•

Crossing (High Touch): Where there is the opportunity to cross trades between clients’portfolios, Barings will only do this where the relevant investment managers determine it to bein the best interest of each client, there is no prohibition in the Client Mandate or regulations
and any relevant consents are obtained prior to settlement or shortly thereafter.

•

RFQ (Low and High Touch): Barings employs a request for quotation for the purpose ofinviting a number of market makers to make competitive prices. This may be achieved througha request for offers from prospective sellers (OWIC or offers wanted in competition) or arequest for bids from prospective buyers (BWIC or bids wanted in competition).

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Appendix C – FX and FX derivatives
Factors Used to Select a Venue
All Eligible Contract Participant (ECP), some currency options and FX are classified as OTC
products. OTC is a security traded in some context other than on a formal exchange.
Following the changes to the market structures as a result of MiFID II, Barings has been tradingsome FX via MTFs.
Factors used to select a venue are:
•
•
•
•
•

Price
Size
Liquidity
Speed
Likelihood of execution and settlement

The priority of the execution factors varies from transaction to transaction. In most cases, achieving
the best price for the trade size will be the primary execution factor in gaining the best possible
outcome, although there will be occasions when other execution factors have equal weighting, e.g.
for a less liquid instrument, the size and likelihood of execution might be as important as price andcost. There may also be times when there is breaking news or other periods of volatility when bothspeed to market and the ability to complete an order quickly are just as important.

Strategies Employed•

Sales Trader (High Touch): Barings’ traders may choose to instruct a Sales Trader to
execute orders on an agency or principal basis. Barings’ traders and the Sales Trader
maintain a regular dialogue throughout the life of the order.

•

RFQ (Low and High Touch): Barings employs a request for quotation for the
purpose of inviting a number of market makers to make competitive prices.

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Appendix D – List of Counterparties and Execution Venues
Equities
AppitalArqaam Capital
Auerbach Grayson
BMO Capital Markets
Citadel Securities Institutional
Daiwa Capital Markets Europe
Financial Brokerage GroupGBM International Inc.
J&E Davy
KNG Securities
Olive tree
Roemer Capital (Europe)
The Bank of Nova Scotia
Tradeweb Direct
Barclays
Bank of America
BCS Prime Brokerage
Berenberg
Bernstein
BNP
Bradesco
Canaccord
CantorCarnegie
China International Capital Corp
CIBC World Markets
CIMB Securities
CITIC Securities
Citigroup
CLSA
Commerzbank
Cowen & Co.
DaewooDanske Bank
Dash Capital
Deutsche Bank
FlowTraders
Goldman Sachs
Goodbody
Hauck & Aufhauser
HSBC
India Infoline
Instinet
Investec
ITAU
Jane Street Financial
Jefferies & Co.
JP Morgan
Kepler Cheuvrex
Kotak Securities
Liberum
Liquidnet
Macquarie
Metzler

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Mizuho International
MM Warburg
Morgan Stanley
NordeaNumis Corp
Oppenheimer
Panmure Gordon
Peel Hunt
PKO Securities
Royal Bank of Canada
Samsung
Santander
SMBC Nikko
Societe Generale
Stifel Nicholas Europe Limited
Susquehanna
UBS
Virtu
Winterfloods
Wood and Co
XP securities
Zeus Capital

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Fixed Income
Developed Market Sovereign Counterparties
ANZ
Barclays BankBNP Paribas
Bank of America
CIBC
Citigroup
Commonwealth Bank of Australia
CSFB
Daiwa
DBS
Deutsche Bank
FTN
Goldman Sachs
HSBC
ING Group
J P Morgan
Millennium Advisors
Mizuho Intl PLC
Morgan Stanley
National Bank Financial Inc
NomuraNordeaRBCRBS
SEB Group
Sberbank
Toronto Dominion
UBS
Wells Fargo

Emerging Market Counterparties
Australia and New ZealandBanca IMI
Banco Santander
Bank of America
Bank of Nova Scotia
Barclays
BBVA
BCP
BGC
BNP Paribas
BTIG
CantorCapital One BankCIBC World Markets PLC
Citi
CITIC
Credit Agricole
Credit Suisse
DBS Bank Ltd
Deutsche BankDNB
ED&F Man
Goldman Sachs

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HSBCImperial Capital
ING
Itau Unibanco
Jane Street
JPMorgan
Larrain Vial S.A.
LeucadiaLiquidity Finance
Liquidnet, Inc.
Lloyds Banking Group PLC
MarketAxess
Mitsubishi UFJ
MizuhoMorgan Stanley
National Bank of Canada
NatixisNomuraNordeaOcto Finances
Oddo BHF
Oppenheimer Holdings
Pareto Securities
Royal Bank of Canada
Royal Bank of Scotland
RW Pressprich
SC Lowy
Seaport Global
SEB Group
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Societe Generale
Standard Chartered
StifelSumRidge Partners
Toronto Dominion
Tradition
UBS
UniCredit
Wells Fargo
Zurcher

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European High Yield Counterparties
ArdentBanca IMI
Banco Santander
Bank of America
Barclays
BBVA
BCP
BGC
BNP Paribas
BTIG
CantorCiti
Credit Agricole
Credit Suisse
Deutsche BankDNB
Flow Traders
Goldman Sachs
HSBC
Imperial Capital
ING
Jane Street
JPMorgan
Kepler Cheureux
LeucadiaLiquidnet
Lloyds Banking Group PLC
MarketAxess
Mitsubishi UFJ
MizuhoMorgan Stanley
NatixisNomuraOcto Finances
Oddo BHF
Pareto Securities
Royal Bank of Canada
Royal Bank of Scotland
SC Lowy
Seaport Global
SEB Group
Societe Generale
StifelTradition
UBS
UniCredit
Wells Fargo

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FX and Derivatives
Australia and New Zealand Banking Group Limited
Banco JP Morgan S/ABank of America, National Association
Bank of Montreal
Bank of New York
Barclays Bank PLC
Barclays Bank Ireland PLC
BNP Paribas
BNP Paribas Securities Corp.
BNP Paribas Securities Services S.C.A.
BofA Securities Europe SA
Brown Brothers Harriman & Co.
Canadian Imperial Bank of Commerce
CIBC World Markets (Japan) Limited
Citibank, National Association
Citigroup Global Markets Limited
Commerzbank Aktiengesellschaft
Credit Agricole Corporate and Investment Bank
Credit Suisse ACA
Credit Suisse AG
Credit Suisse International
Credit Suisse Securities (USA) LLC
Deutsche Bank AG
Deutsche Bank Securities Inc.
Deutsche Pfandbriefbank AG
Goldman Sachs Bank USA
Goldman Sachs International
Goldman Sachs & Co. LLC
HiFX Europe Limited
HSBC Bank PLC
HSBC Bank USA, National Association
HSBC France
HSBC Securities (USA) Inc.
ING Bank N.V.
JP Morgan AG, Frankfurt
JP Morgan Securities PLC
JP Morgan Chase Bank, National Association
LLOYDS BANK CORPORATE MARKETS PLC
Macquarie Bank Limited
Merrill Lynch International
Morgan Stanley & Co. International PLC
Morgan Stanley & Co. LLC
Morgan Stanley Capital Services LLC
MUFG Securities EMEA PLC
MUFG Bank Ireland
National Australia Bank Limited
National Bank of Abu Dhabi PSSC
NatWest Markets PLC
Northern Trust (Guernsey) Limited
RBC Investor Services Bank S.A.
Skandinaviska Enskilda Banken AB
Societe Generale S.A.
Standard Chartered Bank
State Street Bank and Trust Company
State Street Global Markets, LLC
The Bank of New York Mellon
The Bank of Nova Scotia
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The Northern Trust Company
UBS AG
UniCredit S.p.A.
Wells Fargo Bank, National Association

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