What is the Manager’s Best Execution Policy?

The Manager and its affiliates under States Street Global Advisors (“SSGA”)’s duty of best execution requires that we take reasonable steps to obtain as favourable an overall result as possible for our client transactions under the circumstances, taking into account various factors that are relevant to the particular transaction. This includes, but is not limited to, price, cost, speed of execution, likelihood of execution, likelihood of settlement, the nature of the transaction, market liquidity, local laws and regulations, potential market impact and size of the transaction. In considering these best execution factors, SSGA takes into account the particular characteristics of the order, the characteristics of the financial instrument, and the available execution venues and counterparties. While price is an important consideration, SSGA's duty of best execution does not imply a duty to always obtain the best price available at the time of the transaction. 

The ability of SSGA to achieve best execution at the time of a transaction is limited by, among other things, the limitations set forth in a client’s contractual arrangement with SSGA (including a trust deed) and/or a counterparty, any restrictions or explicit directions imposed by the client as to the panel of counterparties with which SSGA may transact with respect to the client’s account, the amount of available credit the client may have with counterparties, and any other specific instructions delivered by the client to SSGA. These factors can be viewed in terms either of the particular transaction or in terms of SSGA’s overall responsibilities with respect to the accounts for which it exercises investment discretion and has the authority to select counterparties. SSGA selects the counterparty for each transaction after considering price or spread and other qualitative criteria. However, the client, and not SSGA, bears any credit and operating exposure to a counterparty.