The Iyo Bank, Ltd. Singapore BranchBest Execution Policy

1. Introduction
This Disclosure is issued pursuant to the Monetary Authority of Singapore (“MAS”) Notice on
Execution of Customers’ Orders (Notice No. SFA 04-N16) (“Best Execution Notice”) and the MAS
Guidelines to MAS Notice SFA 04-N16 on Execution of Customers’ Orders (Guideline No. SFA 04G10) (“Best Execution Guidelines”).
This disclosure statement provides relevant customers with information on order execution
under our Best Execution Policy, including the considerations and approach by us to provide
Best Execution for our customers in the execution of relevant trades.
To the extent that you continue to maintain your trading relationship with The Iyo Bank, it will
be on the basis that you have read and understood this disclosure.
2. Scope and Application of the Best Execution Policy
This Policy applies only to those corporate banking customers who are classified as Accredited
Investors or Expert Investors as defined under Securities and Futures Act 2001 (SFA) and who
deal in capital markets products which are over-the-counter (OTC) derivatives with us.
Customers who are classified as Institutional Investors under the SFA are not entitled to any
protections established in this Policy. The Best Execution obligation we owe you under thisPolicy is only applicable if you are relying on us to protect your interests in relation to theexecution of the transaction. In determining reliance, we will consider the following factors:(i)(ii)(iii)(iv)

Who initiated the order: Where you initiate the transaction, it is less likely that you areplacing reliance on us. In circumstances where the Bank may communicate trade ideas,
market communication or indicative processes as part of our general business, weregard these communications as purely for information purposes and such
communications shall not be deemed to have initiated the transaction.
Market practice and existence of a convention to “shop around”: Where it isconventional market practice for clients to “shop around” by approaching several
dealers for quotes, it is less likely that you will be placing legitimate reliance on us.
Relative levels of price transparency: In circumstances where pricing information istransparent and it is reasonable that you have access to such information, it is less likelythat you are placing reliance on us.
The information provided by you and any agreement reached: Where any agreements
or arrangements with you do not indicate or suggest that an understanding has beenreached that you will place any legitimate reliance on us or that we have agreed toprovide best execution in our transactions with you.

This Policy does not apply to you if we have assessed that you are not relying on us to achieve
best execution of in-scope products determined in accordance to the above.

3. Best Execution Factors
3.1 Where a duty to achieve Best Execution is indeed assessed to be owed, and unless the customer
gives specific instructions, we will consider the following factors when executing a transaction
on behalf of the customer:
(i)
(ii)
(iii)
(iv)
(v)
(vi)

3.2

In determining the relative importance and/or the applicability of the factors, we will consider
the following characteristics:
(i)
(ii)

(iii)
3.3

Price – Price at which the order is executed.
Costs – Costs relating to possible market impact, external costs such as exchange or
clearing fees and internal costs such as internal spreads.
Size of the Order – The size and nature of the order may affect the price of execution.
Speed – The time it takes to execute your order.
Likelihood of execution or settlement – The likelihood that we will be able to complete
your order.
Nature of the order and any other considerations relevant to the placement and/orexecution of the order.

The characteristics of the customers we serve. The types of financial products forwhich we are accepting execution orders for;The characteristics of the execution venues or brokers to which the order can bedirected. Where there is more than one execution venue or broker, we will consider
the respective merits of each venue or broker and document the basis for selecting
the venue or broker; andThe characteristics of your orders.

The application of best execution policy involves the exercise of commercial judgment in thecontext of available information. Upon you engaging us, we will seek to execute your order on
the best available terms in the manner set out in this policy.

4. Specific Instructions
Where specific instructions are given by the customer regarding the execution of an order or apart of the order, we will ensure execution in accordance with those instructions. In suchcircumstances, we will consider itself as having satisfied its Best Execution obligations withrespect to the part of the customer order to which the instruction relates, when those
instructions have been correctly carried out. Where the customer provides specific instructions
covering only part of an order, we will not consider itself released from its Best Execution
obligations for the parts of the order which are not covered by the instructions. In this case, wewill comply with this Best Execution policy to that part of the trade which is not covered by
specific instructions. Where specific instructions given by the customer cannot be followed, wewill inform the customer of the reasons before executing such orders. There may be someorders, depending on the circumstances we will not be able to accept.

5. Execution Venues
Where there is only one appropriate Execution Venue available for execution of the customer
order, the Branch will only use that single venue to fill the order. Where the use of one of theusual Execution Venues would not, in a particular situation, result in the best possible result on
the customer order, the Branch will consider other execution venues where available.
6. Monitoring
We will regularly monitor and assess the effectiveness of our Best Execution Policy andassociated arrangements in order to fulfill the regulatory requirements applicable to us. Regularassessments will be conducted on a regular basis to identify and where appropriate, address any
deficiencies. Additionally, we will review our Best Execution Policy and associated procedures atleast annually or whenever a material change occurs that affects our ability to continue toobtain the best possible result for our customers.
7. Updates to Best Execution Policy
We will review our Best Execution Policy on a periodic basis and reserve the right to update it asappropriate.
If you require further information on our Best Execution Policy, please contact your relationshipManager or contact The Iyo Bank., Ltd, Singapore Branch.