Order Execution Policy
Disclosure Statement
April 2024

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Introduction
The primary service Stewart Investors provides to clients is that of portfolio management. We manage funds andportfolios on behalf of our clients, and in so doing we place orders in various asset classes, primarily equities but also
including bonds and money market instruments for liquidity management, currency and collective investment
schemes. In carrying out this activity we execute orders on behalf of clients and also transmit or place orders forclients with other entities for execution. These two methods of giving effect to those decisions are distinguished forthe purposes of our regulatory requirements, with a separate best execution obligation for each:

Direct execution
Where we execute a transaction directly with a counterparty or on an exchange or other trading system, we are
required to take all sufficient steps to obtain the best possible result for our clients when executing those transactions
on their behalf.

Indirect execution
Where we place an order with a third party (eg a broker) for that third party to execute, we must act in accordancewith the best interests of our clients when placing orders with those third parties for execution.
This Disclosure Statement summaries our execution arrangements and the steps we take to meet our obligations to
our clients.
Our policy and procedures are designed with the intention of obtaining the best possible execution result, subject toand taking into account the nature of your orders, the priorities we place upon filling those orders and the market inquestion, and which in our view provides the best balance across a range of factors, some or all of which may be
conflicting.
Stewart Investors is a trading name of First Sentier Investors (UK) IM Limited, First Sentier Investors International IM
Limited and First Sentier Investors (UK) Funds Limited, each of which is authorised and regulated by the Financial
Conduct Authority, of First Sentier Investors (Singapore), which is authorised and regulated by the Monetary Authorityof Singapore, and of First Sentier Investors (Hong Kong) Limited which is licensed and regulated by the Securities andFutures Commission in Hong Kong. Stewart Investors operates as a separate division of First Sentier Investors (UK) IM
Limited, First Sentier Investors International IM Limited, First Sentier Investors (UK) Funds Limited and First Sentier
Investors (Singapore) in its own right, and this policy relates solely to the execution of orders by Stewart Investors.
In Australia, Stewart Investors provide investment services via First Sentier Investors (Australia) IM Limited, which islicensed and regulated by the Australian Securities and Investments Commission. If you are not a client of Stewart
Investors but of First Sentier Investors, please refer to the First Sentier Investors Order Execution Policy.

Scope
This Disclosure Statement forms part of our obligations relating to the United Kingdom (UK) Markets in Financial
Instruments Directive (MiFID), and Chapter 11.2 of the UK Financial Conduct Authority’s Conduct of Business
Sourcebook, Notice SFA 04-N16 of the Monetary Authority of Singapore (MAS) and the Code on Unit Trusts andMutual Funds by the Securities and Futures Commission in Hong Kong, and sets out our business practices concerning
the execution of orders on your behalf.
All references in this document to “we” or “us” are references to Stewart Investors. Where we utilise the services ofaffiliated companies around the world for execution or order transmission purposes, we will expect them to follow thispolicy, and for any external brokers and such third parties to treat them as though they were Stewart Investors. The
ultimate holding company of Stewart Investors is Mitsubishi UFJ Financial Group Inc.
This Policy applies to business conducted with Professional Clients (as defined under MiFID) and customers (as defined
under MAS Notice SFA 04-916), and applies in all circumstances except the following:•

Where you provide us with a specific instruction in relation to an entire order, or any particular aspect of an order
including selecting to execute using a particular venue or broker, we will execute or transmit the order inaccordance with your instructions.

•

Where any instruction relates to only part of the order, we will continue to apply this policy to those aspects of
the order not covered by the specific instruction. Where you provide us with a specific instruction, this may
prevent us from following some or all of the steps in this policy. In following your instructions we will be deemed
to have taken all sufficient steps to provide the best possible result in respect of the order covered by yourspecific instructions.

•

Where you give us specific instructions (either for your account in general or in relation to a specific order)
requesting your unexecuted limit orders are not made public, you acknowledge that such specific instructions may
prevent us from following some or all of the steps in this policy, and that your order may be denied the potential
benefits arising from our order allocation and aggregation policies.

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Delivering best execution
When executing orders on your behalf we will take all sufficient steps to achieve “best execution” of your orders.
The main factors we will take into consideration include:•

Price;•

Costs;•

Speed of execution;•

Likelihood of execution and settlement;•

The size of the order;•

The nature of the order;•

Prevention of information leakage; and•Any other considerations relevant to the execution of the order.

The criteria we will use in determining the relative importance of the execution factors listed above include:•Your characteristics, including your regulatory client categorisation;•

The characteristics and nature of your order, including the broader context of the investment style of theportfolio to which it relates and whether any specific instructions are given;•

The characteristics of the financial instruments that are the subject of your order;•

The characteristics of the execution venues to which your order can be directed.

Regulatory requirements provide that achieving “best execution” does not demand that firms achieve the best
possible result with every trade, but that the focus is on taking all sufficient steps for obtaining the best possible
result on a consistent overall basis.
It is our policy, therefore, to have a process which ensures that every client order is treated in a way that aims tomaximise the chance of getting the best set of results.

Trading venues
In selecting the most appropriate venues for the purpose of executing your orders, we will take into account thevarious factors which we believe are relevant to the order. In doing so, we will assess what we reasonably believe tobe your best interests in terms of executing the relevant order and the execution factors.
One important consideration when selecting execution venues to transact client orders is that the venue concerned
has adequate systems and controls in place to enable the delivery of best execution. In conducting this assessment
we will take into account the factors we believe may be appropriate including, the ability of the venue to manage
complex orders, the quality of the venue including the nature of other participants and order types available, thespeed of execution, the creditworthiness of the venue and the quality of any related clearing and settlement facilities.
Our approach is to maintain a choice of venues and entities that offer the potential for us to obtain the best possible
result for the execution of your orders on a consistent basis. By selecting the most appropriate venues we can limit
trading costs and ensure a higher chance of execution. The main factors we will take into consideration include:•

Venue liquidity. We use factors such as historical trading volumes and indications of interest to assess thelikelihood of an execution on that venue;•

Venue toxicity. The likelihood that routing to or executing on the venue will impart too much information about
the balance of the order;•

Order matching logic. Different venues match contra (buy/sell) orders using differing matching logic. Somevenues may prioritise by best price and others by largest size or by submitting broker – we will choose the mostsuitable for each execution;•

Infrastructure. We will only route to venues which have the infrastructure to efficiently manage the complexity
levels appropriate to each order. We also assess the creditworthiness of the venue and the quality of any related
clearing and settlement facilities;•

Control of information flow. Venues must ensure unexecuted order information is appropriately protected;•

Access to data. Venues should allow access to trade and price formation data, where appropriate, on an
equitable basis and distribute this data at a fair cost; and•Fees and charges. Venues should not charge excessive fees to transact on their venue, nor should they offer
excessive inducements to trade.
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In meeting our obligations we may use one or more of the following venue types when executing an order on
your behalf:•

Broking firms who transact on behalf of our clients on regulated markets, through their own Multilateral
Trading Facilities, as a Systematic Internaliser or acting as principal;•

Other independent Multilateral Trading Facilities where trades can be executed away from the exchanges’
order books;•

Organised Trading Facilities and trading facilities that have been declared equivalent in accordance withapplicable laws and regulations; and/or•

Third party investment firms acting as market makers or other liquidity providers.

Where we use a broker to execute orders on your behalf, such execution may also be achieved through the use ofalgorithmic trading, in which an order is traded in line with specific parameters using a proprietary platform
provided by that broker. We do not engage in algorithmic trading ourselves but utilise broker-supplied platforms,
infrastructure and algorithms. We also do not engage in high frequency trading.
In certain financial instruments there may only be one execution venue. In executing a trade in such circumstances
we will presume that we have provided the best possible result in respect of these types of financial instruments.
We do not receive any form of remuneration, discount or non-monetary benefit for directing orders to a particularvenue or broker for execution. Selection of a broker for an order is driven solely by the factors and inputs as
described in this policy.

Specific financial instrument considerations
The decision around venue consideration will be made having regard to the relative importance of the execution
factors for the specific financial instrument in question. The following instrument-related considerations are taken
into account:

Equities
Orders relating to equities (including related exchange-traded collective investment schemes, warrants andderivatives) are generally executed by third party investment firms or through multilateral trading facilities.
In considering the execution factors and deciding the appropriate execution venue, we will take account of factors
such as the reason for the order, the size of the order relative to available and historic liquidity, specific portfolio
manager instructions (including price limits) and other grounds deemed relevant at the time. While price (including
all costs related to execution of the order) will generally be the most important factor, for larger orders particularly
factors such as execution certainty, market impact reduction and execution speed may have greater importance.
Where an order does not have a specific priority related to timing or speed of execution, we will normally prioritise
other execution factors, particularly price, ahead of timing or speed. Where we transmit the order to a broker for
execution, we will select a broker who we believe can achieve the best result for orders of this nature; similarly if
we transmit the order to be executed through a broker’s algorithmic trading platform our selection will include ourassessment of that platform’s ability to achieve the best result for orders of this nature.
If a natural counterparty does not exist for your order, we use market information and our dealers’ experience toselect a broker for working part of the order for us, usually on an agency basis, being careful not to expose toomuch of our order to the market in order to avoid impact costs. This is a general strategy adopted when speed is aless important factor than, say, price or the ability to retain anonymity.
We will, where appropriate, try to identify sources of natural liquidity before entering an order into the market.
We typically use multilateral trading facilities in trying to source a natural match. The order will be executed withreference to the prevailing market price. Trading in this manner can greatly reduce market impact.

Bonds and money market instruments
Orders relating to bonds and money market instruments are executed either by third party investment firms or
through multilateral trading facilities or quote aggregation platforms. Orders executed through multilateral trading
facilities or quote aggregation platforms will usually involve obtaining screen-based competitive quotations and thisapproach seeks the best price through competition among multiple third party investment firms.
In the case of larger orders we are more likely to place orders directly with third party investment firms, in which casewe will generally obtain at least three quotes and retain these for audit purposes, assuming these quotes can beobtained without impacting the market. While price (including all execution costs) will generally be the mostimportant factor, we may take other factors into account as appropriate to the size and nature of the order.
The diversity in some markets and instruments and the kind of orders that we carry out on your behalf may meanthat different factors will have to be taken into account when we assess the nature of our Execution Policy in thecontext of different instruments and different markets.
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For example, there is no formalised market or settlement infrastructure for over-the-counter transactions. In somemarkets, price volatility may mean that the timeliness of execution is a priority, whereas in other markets that have
low liquidity, the act of execution may itself constitute best execution.
In other cases, our choice of venue may be limited (even to the fact that there may only be one platform/market uponwhich we can execute your orders) because of the nature of the order or of your other requirements.

Currency
Orders relating to foreign exchange are executed with third party investment firms. For orders of a marketable size,
we will obtain several simultaneous quotations from multiple counterparties and retain these for audit purposes, withthe predominant factor being best price at the time of execution.
For some orders, particularly larger or more illiquid orders, a single counterparty may be approached dependent on
the execution strategy at the time of the order to avoid impacting the market significantly. In such a case,counterparty selection will take into consideration factors such as previous execution performance, clearance andsettlement capability, credit worthiness and financial stability, timely trading and ability to trade in large volumes.
Where a client has appointed their own custodian with standing instructions in place for restricted or othercurrencies, foreign exchange trades will be conducted through the appointed custodian bank. In these circumstances
best execution will not apply.
MiFID does not define spot foreign exchange transactions as “financial instruments” however we will strive to apply
equivalent standards to such transactions as well as to other instruments which are not defined.

Collective investment schemes
Orders in collective investment schemes which are not exchange-traded will normally be in an environment where
there is no secondary market. Generally we will place such an order with the relevant administrator of the scheme,
who will be the execution venue. Such transactions will be effected at an appropriate price based on net asset value,with execution certainty being the most important factor.
In relation to Bonds, Money Market Instruments and Currency the following market and product considerations aretaken into account:Market characteristics
Execution is dependent on factors such as market transparency and ability to trade in size, pricing and execution speed.
Therefore the best price does not automatically equal the best execution, rather best execution is to be assessed on an
overall basis taking into consideration these factors described below:•

Market transparency and ability to trade in size. The best observed price in a market is typically quoted as a priceagainst a particular size, which may not match the size of the proposed trade. Where the order is to execute a larger
size, if part of the order is executed at the indicated size, the price for subsequent executions may become lessfavourable (that is, the market may move). On the other hand, if the order is to execute a smaller size, the same price
may not be available.

•

Price is an important factor to consider whenever it is possible to execute orders at more than one price. Price isalways likely to be relevant, but the best price in a given market at a given moment may not represent the best
possible result.

•

Speed. Prices change over time and the rate of change varies with different instruments, market conditions andexecution methods. Where we consider that the cost of an adverse market movement is likely to be great, faster
execution may be required. For larger orders in less liquid instruments other factors may outweigh speed or aslower rate of execution may be needed.

Product characteristics
A combination of pre-trade and post trade criteria is applied to each type of instrument to determine theimportance of the processes that occurs before (and after) trades are executed. We believe pre-trade criteria is
important when sensitive to the selection of the counterparty and post trade criteria is important when comparing
the trade data against pre trade benchmarks and relevant market data to determine fair pricing.

Single venue transactions
Operational considerations may prevent us from using more than one venue for execution. In other instanceswhere execution speed and certainty and/or market impact are judged to be more important, obtaining multiple
quotes may have a negative impact on obtaining best execution or for some orders there may only be one potential
counterparty, in which case we may approach a single broker or counterparty on the basis of their suitability forthat transaction. In such cases we will check the fairness of any price proposed by gathering market data relevantto the estimation of such a price and, if possible, comparing to similar assets.

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Brokers and counterparties
Stewart Investors will generally only transact client orders with brokers and counterparties which are regulated,either by the Financial Conduct Authority (FCA) or by the counterparty’s and broker’s home state regulator, andwhich have been specifically approved by us after review in accordance with our policy, and they must haveexecution arrangements that enable them to comply with our obligations. We may also place such orders with ouraffiliate companies around the world for execution on our behalf, in which case those affiliates will also adhere to
this policy.
We have a process for the selection of brokers with whom we place orders for execution. The specific criteria to
add a broker varies based on the relevant asset class, however the approval process is applied in the same manner
across all asset classes. We do not conduct any activity with a new broker until the screening and approval process
has been completed.
The criteria to add a broker to the approved counterparty list is generally based on a number of factors which may
include, but is not limited to, our assessment of their:•

Quality of financials;•

Sustainability;•

Execution quality;•

Operational risk;•

Service quality; and•Reputation, including regulatory status and history

All approved brokers undergo screening including for disciplinary actions, criminal proceedings and reputational
issues. In order to minimise the risk of potential conflicts of interest when selecting brokers with whom to placeorders for execution, the commission rates we pay are set so as not to discriminate between different brokers. We
also do not take part in any form of directed brokerage or commission recapture arrangement, and we do not tradewith brokers who are affiliates of us. We do not receive any form of remuneration or discount for directing orders
to a particular venue or broker for execution. While discouraged, any minor non-monetary benefits are limited tothose permitted under our Gifts and Entertainment Policy. Selection of a broker for an order is driven solely by thefactors and inputs as described in this policy. Counterparties are reviewed on an annual basis to ensure relevance.
Where we place an order for execution by an approved broker, we are not responsible for controlling or influencing
the arrangements made by the broker relating to execution of that order (ie we do not control the broker’s choiceof venues). We are not required to duplicate the efforts of the broker to whom an order is passed in ensuring thebest possible result. Our policy is therefore to ensure that the approved brokers are the ones who will assist us tocomply with our best execution obligations (by delivering the best possible result) and that orders are passed to
brokers in accordance with this policy.

Order handling
We have an Order Handling Policy which governs how we ensure your orders are executed promptly, fairly and
expeditiously relative to orders of our other clients. When we create orders on behalf of your account, we act toensure those orders are executed in a timely manner, subject to the factors listed above, in line with our order
execution policy, and that we record and allocate those executions promptly.
Where we have sufficiently comparable orders on behalf of a number of clients, we will generally look toaggregate such orders. We will not do this if we believe it would disadvantage you, however any particular orderaggregation may subsequently prove to have worked to your advantage or disadvantage. To ensure we treat all
our clients fairly, our Order Handling Policy governs how aggregated orders are allocated, especially where they
are only partially executed. We will allocate all order executions proportionally in accordance with our Order
Handling Policy.
Where we have orders where one or more client accounts are buying and one or more client accounts are sellingthe same security, depending on local regulations, internal procedures, and client instructions we may seek to
execute those orders as cross transactions. Such transactions will only be executed where it is in the interests of
all clients involved to do so and where local regulations or client restrictions allow it, and will be transacted
through a broker as a net trade at a fair and appropriate market price.

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Monitoring and review
We continually monitor our order execution arrangements and policies on an ongoing basis for their effectivenessand to ensure we have oversight of our regulatory obligations on best execution.
On a daily basis, where relevant, the dealers and investment team will discuss the trading flow and prices obtained.
In addition, the dealing desk uses third party transaction cost analysis to review the quality of execution on a post
trade basis.
On a quarterly basis the transaction cost analysis data is presented to the Execution Oversight Group which seeks
to identify wider execution trends and quality including counterparty selection versus trade allocation.
Our Execution Oversight Group is an oversight committee comprising representatives from our Investment,
Business Management and Front Office Surveillance teams alongside the dealing desk and regularly reviews trade
data from our order management and record keeping systems used to measure trade execution volumes, numberof trades and estimates of trade cost. The Group also reviews the quarterly transaction data around wider
execution trends and quality.
Through this process we assess whether the execution venues/brokers included in this policy provide the best
possible result for you or whether we need to make changes to our execution arrangements from time to time.
The Front Office Surveilance team periodically monitors the effectiveness of the order execution arrangements
and the policy. Any material concerns or issues are recorded and escalated through our internal governanceprocess as appropriate. The Front Office Surveilance team are also members of the Execution Oversight Groupand provide challenge and input into its meetings.

Updates to the Order Execution Policy
We review our order execution arrangements and policy at least annually or whenever a material change occursthat affects our ability to continue to obtain the best possible result for the execution of your orders. The review
will focus on whether we would obtain better results for clients if we were to:a)include additional or different venues or brokers (for the relevant instrument class);b)

assign a different relative importance to the execution factors (for the relevant instrument class); orc)

modify any other aspects of the policy and/or its execution arrangements.

In undertaking this review, we will take into account transaction cost analysis data as well as any other relevant
information or analysis available to us.
The purpose of the review is to carry out an overall assessment of whether the policy and Stewart Investors’
execution arrangements are current and enable the firm to obtain the best possible result for the execution of its
client orders.
In addition to the annual review, factors that might trigger an early review include:•

a material change to our dealing arrangements;•

the launch of, or substantial change to, a service, activity or product;•a significant restructure of part of the business; and•a relevant change in regulation and/or market practice.

We will notify you of any material changes to our order execution policy and a copy of the most recent version will
be published on our website. We will also update the list of execution venues and entities when necessary. Clients
will not be notified separately of any changes unless this constitutes a material change. The addition or removal ofa broker from our approved list would not typically be deemed a material change.

Client information
On your reasonable request, we will demonstrate that we have executed your order(s) in accordance with thisOrder Execution Policy.
This disclosure is initially provided to all new clients in order that we can evidence the provision of appropriate
information and we also request the client’s consent to the policy and prior express consent to the execution oforders outside a regulated market or a Multilateral Trading Facility.

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Appendix: brokers and execution venues
Stewart Investors may use the following brokers, counterparties and multilateral trading facilities as execution
venues when seeking best execution. This list is not exhaustive and may be subject to change and revised fromtime to time. Stewart Investors may use venues not listed below where it deems appropriate in accordance with
the Order Execution Policy. Brokers are listed at the main contracting level with Stewart Investors; we may
however also contract with various subsidiaries and affiliates for execution in different markets.

Equities (as at 31 January 2024)
African Alliance Securities Trading Pty Ltd
The Bank of Nova Scotia (London)
Bernstein Autonomous LLP
Batlivala & Karani Securities India Private Limited
Bradesco Securities Inc
BTIG Limited
China International Capital Corporation (UK) Limited
CLSA (UK)
Credicorp Capital LLC
CT CLSA Securities (Pvt) Limited
Goldman Sachs International
Ho Chi Minh City Securities Corporation
HSBC Bank plc
Itau BBA USA Securities Inc
Jefferies International Limited
J.P. Morgan Securities plc
Kotak Securities Limited
Liquidnet Europe Limited
Macquarie Capital (Europe) Limited
Merrill Lynch International
Mizuho International plc
Morgan Stanley & Co International plc
Motilal Oswal Financial Services Limited
RBC Europe Limited
The Standard Bank of South Africa Limited
Stonex Financial Limited
UBS AG
Virtu Europe Trading Limited

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Bonds and money market instruments (as at 31 January 2024)
BNY Mellon Capital Markets EMEA Limited
Citigroup Global Markets Limited
Goldman Sachs International
J.P. Morgan Securities plc
Lloyds Bank Corporate Markets plc
Merrill Lynch International
Bloomberg LP

Currency (as at 31 January 2024)
Australia and New Zealand Banking Group Ltd
The Bank of New York Mellon (London)
Barclays Bank plc
BNP Paribas SA
Citibank NA
HSBC Bank plc
JP Morgan Chase Bank NA
Lloyds Bank Corporate Markets plc
Merrill Lynch International
Standard Chartered Bank
State Street Bank and Trust Company
UBS AG
Refinitiv Transactions Services Limited

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Important information
This material is for general information purposes only. It does not constitute investment or financial advice and does not take
into account any specific investment objectives, financial situation or needs. This is not an offer to provide asset management
services, is not a recommendation or an offer or solicitation to buy, hold or sell any security or to execute any agreement for
portfolio management or investment advisory services and this material has not been prepared in connection with any suchoffer. Before making any investment decision you should consider, with the assistance of a financial advisor, your individual
investment needs, objectives and financial situation.
We have taken reasonable care to ensure that this material is accurate, current, and complete and fit for its intended purpose
and audience as at the date of publication. No assurance is given or liability accepted regarding the accuracy, validity orcompleteness of this material and we do not undertake to update it in future if circumstances change.
To the extent this material contains any expression of opinion or forward-looking statements, such opinions and statements
are based on assumptions, matters and sources believed to be true and reliable at the time of publication only. This materialreflects the views of the individual writers only. Those views may change, may not prove to be valid and may not reflect theviews of everyone at First Sentier Investors.
About First Sentier Investors
References to ‘we’, ‘us’ or ‘our’ are references to First Sentier Investors, a global asset management business which isultimately owned by Mitsubishi UFJ Financial Group. Certain of our investment teams operate under the trading names FSSA
Investment Managers, Stewart Investors and Realindex Investments, all of which are part of the First Sentier Investors group.
We communicate and conduct business through different legal entities in different locations. This material is communicatedin:•Australia and New Zealand by First Sentier Investors (Australia) IM Limited, authorised and regulated in Australia by theAustralian Securities and Investments Commission (AFSL 289017; ABN 89 114 194311)•

European Economic Area by First Sentier Investors (Ireland) Limited, authorised and regulated in Ireland by the Central
Bank of Ireland (CBI reg no. C182306; reg office 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; reg company no.
629188)•Hong Kong by First Sentier Investors (Hong Kong) Limited and has not been reviewed by the Securities & Futures
Commission in Hong Kong•

Singapore by First Sentier Investors (Singapore) (reg company no. 196900420D) and has not been reviewed by the
Monetary Authority of Singapore. First Sentier Investors (registration number 53236800B) is a business division of First
Sentier Investors (Singapore)•

Japan by First Sentier Investors (Japan) Limited, authorised and regulated by the Financial Service Agency (Director of
Kanto Local Finance Bureau (Registered Financial Institutions) No.2611)•

United Kingdom by First Sentier Investors (UK) Funds Limited, authorised and regulated by the Financial Conduct
Authority (reg. no. 2294743; reg office Finsbury Circus House, 15 Finsbury Circus, London EC2M 7EB)•

United States by First Sentier Investors (US) LLC, authorised and regulated by the Securities Exchange Commission (RIA
801-93167)•

In other jurisdictions, where this document may lawfully be issued, by First Sentier Investors International IM Limited,authorised and regulated in the UK by the Financial Conduct Authority (reg. no. 122512; reg office 23 St. Andrew
Square, Edinburgh, EH2 1BB; reg company no. SC079063)

To the extent permitted by law, MUFG and its subsidiaries are not liable for any loss or damage as a result of reliance on any
statement or information contained in this document. Neither MUFG nor any of its subsidiaries guarantee the performance of
any investment products referred to in this document or the repayment of capital. Any investments referred to are notdeposits or other liabilities of MUFG or its subsidiaries, and are subject to investment risk, including loss of income andcapital invested.
© First Sentier Investors GroupContact details
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