Order Execution policy Nomo Investments Funds

Third-party provider

Appointment

BLME has appointed a specialist third-party provider for order execution. BLME has undertaken due diligence on its third-party provider and has an agreement with it to execute orders. BLME’s thirdparty provider is a regulated bank which has its own Order and Best Execution policy, which it is contractually bound to follow when executing orders for BLME’s clients.

Distribution agreements

BLME’s third-party provider has distribution agreements with all the fund managers which manage the Funds offered by Nomo Investments. Accordingly, no intermediaries are used. Order execution is carried out directly with the fund manager (or its agent, where applicable) which ensures the best possible result in terms of operational efficiency and price. One of the advantages of this arrangement is that it is able to execute trades on favourable terms, e.g., whereby fund managers waive Entry Charges.

Monitoring

BLME, through its routine oversight of its third-party provider, has in place the following monitoring arrangements:

• Third-party provider reporting on order handling issues such as orders which are not settled / confirmed on time and orders not executed in line with the fund cut-off times.
• BLME monitoring of order confirmation / settlement outside agreed service level timeframes.

Best execution

BLME’s third-party provider will adopt all reasonable measures to obtain the best possible result in executing orders, considering all relevant execution factors. For the Funds offered, the only factor within the control of BLME’s third-party provider is speed of execution – executing the order at the next available price set by the fund manager, subject to the cut-off times.

Order handling

Valuation

All Nomo-selected Funds are priced daily. At a set time each business day, a fund is revalued with reference to the value of its holdings. The total value of the holdings divided by the number of units is the Net Asset Value (NAV) of the fund, i.e., the unit price.

Cut-off times

For each business day, the fund has a cut-off time. All orders received by the fund prior to its cut-off time will be traded at that day’s price. BLME’s third-party provider sets its own, earlier cut-off time for each fund in order to have time to meet the fund’s cut-off time.

Sequence

Orders are processed according to their receipt prior to the established cut-off times. The sequence of their receipt will have no bearing on the sequence in which they are executed.

Aggregation

BLME’s third-party provider may combine client orders for Funds with those of its other customers to carry them out as aggregated orders (block orders). In no case will this cause any disadvantage to clients

Transmission

BLME will transmit orders to its third-party provider. BLME’s third-party provider will execute client orders directly with the fund house or, where applicable, the entity in charge of order execution for a fund house (transfer agent). Orders received before the cut-off time will be processed on the same business day (always depending on the trading characteristics of each UCITS).

Price

Orders are executed at the fixed unit price as determined by the Net Asset Value (NAV) of the fund at the applicable execution date / time, with no option for them to be executed at a different price. BLME’s third-party provider does not undertake to guarantee the price for orders received prior to cut-off time when, due to external causes or reasons of force majeure, it has not been possible to transmit them to the fund house or the transfer agent in time. In such cases, orders will be processed as quickly as circumstances allow.

Notifications

Clients will receive the following notifications:

1. Order accepted
2. Confirmation of order (contract note)
3. Receipt of asset (units) into portfolio account.