RHB BANK BERHAD’S BEST EXECUTION POLICY IN SINGAPORE (“DISCLOSURE STATEMENT”)

1. INTRODUCTION

This Disclosure Statement is issued pursuant to the MAS Notice SFA 04-N16 on Execution of Customer’s Orders and MAS Guidelines SFA 04-G10 to MAS Notice SFA 04-N16 on Execution of Customers’ Orders where we (“RHB Bank Berhad Singapore”) are required to establish and implement policies and procedures relating to the placement and execution of customers’ orders on the best available terms (“Best Execution Policy”). RHB Bank Berhad Singapore’s customers (“customers”, “you”, “your”) should read and understand this Disclosure Statement so that they can make an informed choice when they place an order with RHB Bank Berhad Singapore. This Disclosure Statement provides an overview on the overall best execution approach that we shall apply and the factors considered by us to achieve best execution for our customers.

2. SCOPE AND APPLICATION OF BEST EXECUTION

The best execution obligation is generally owed when we accept an order to execute a transaction on your behalf, or place your order with, or pass your order to others or an execution venue for execution or in other circumstances where we have otherwise expressly agreed to accept such best execution obligation.

Collective Investment Schemes (“CIS”) have been determined to be out of scope as it can only be subscribed and redeemed at one place (with the manager/ administrator of the CIS) and at one price (the net asset value (NAV)). As such, we have no discretion with regards to the execution venue and/or price and therefore CIS have been determined to be out of scope.

2.1 CAPACITY

The best execution obligation is also applicable when we are acting in a principal capacity and the customers are placing a legitimate reliance on us to protect their interest in relation to the execution of a transaction relating to any products specified in part 2.2 of this Disclosure Statement.

2.2 PRODUCTS

The best execution obligation applies to all capital markets products as prescribed by the regulators in the locations that RHB Bank Berhad Singapore is operating, which include but not limited to the following:

Over-the-Counter Derivatives
Structured Products
Foreign Exchange (Forwards and Non-deliverable Forwards)
Bonds & Fixed Income

2.3 CUSTOMERS AND APPLICATION

2.3.1 The best execution obligation will apply to you if you are placing your order with us as a person other than an institutional investor (as defined in section 4A of the SFA).

2.3.2 If you are dealing with us as an accredited investor (as defined in section 4A of the SFA) or expert investor (as defined in section 4A of the SFA), we will determine whether you are placing a legitimate reliance on us to provide best execution to you based on the following criteria:

Party initiating the transaction
– If you initiate the transaction, it is less likely that you are placing legitimate reliance on us.
Market practice and your ability to obtain quotes from various providers
– Where you will have ready access to obtain quotes from various providers, it is less likely that you are placing legitimate reliance on us.
Relative levels of price transparency within the market
– Where pricing information is transparent and it is reasonable that you have access to such information, it is less likely that you are placing legitimate reliance on us.
Information provided by us and any agreement reached
– Whether any agreements or arrangements with you (including provisions under this Disclosure Statement) indicate or suggest that an express understanding has been reached that you will place legitimate reliance on us.

3. SPECIFIC INSTRUCTIONS

3.1 Where you give us specific instructions in relation to an order, we will strive to follow that instructions so far as they are reasonably possible when executing the trade. By following your specific instructions, we shall be deemed to have satisfied our best execution obligation in relation to the transactions to which your instructions relate.

3.2 Where your specific instructions relate to only part of the order, our best execution obligation shall only apply to aspects of the order that are not covered by your instructions.

3.3 If your specific instruction cannot be carried out by us, we will inform you.

4. BEST EXECUTION FACTORS

4.1 When executing your orders, all orders are first and foremost fulfilled in accordance to the time of receipt, after which, the following factors may be taken into considerations, while we are acting in capacity as a principal:

Price – This is the price at which the order is executed. This price excludes our own execution charges but includes costs such as execution venue fees, clearing and settlements prices and any other fees, if applicable.
Speed – This refers to the time it takes to execute an order.
Likelihood of Execution – This is the rate at which we are able to execute the order in its entirety or a substantial part of it. Where your instructions dictate or imply a timeline or speed of execution at point of order, we will follow such instruction. Where the instructions do not refer to a timeline or speed of execution, we will progress the order at a rate which we believe to achieve the best balance across the full range of factors. This may mean that we do not always achieve the best price for every order, but the best result that can be reasonably expected given the information available during the execution process. Amongst others, we will strive to reduce execution risk, which may be particularly important in situations where access to liquidity in the relevant instrument is constrained in some way. For example, if the security is illiquid or if you provide a limit price which is challenging to achieve
Likelihood of Settlement – We expect transaction that we execute to settle in a timely fashion. If we become aware that a particular best execution strategy may compromise the likelihood of settlement, we may not pursue that strategy even if it would result in a better price.
Order Size – Size of any request for quote may affect the quote price, e.g. exceptionally large market moving orders or with limited counterparties willing to quote.
Nature of the Order – Characteristics of your order which can affect how best execution is achieved.

4.2 We may also take into consideration the following factors in determining the relative importance and/or the applicability of the best execution obligation:

The characteristics of the customers;
The characteristics and nature of the order, including any specific instructions received;
The characteristics of the capital market products that are subject of the order; and
The characteristics of the execution venues or brokers to which the order can be directed.

4.3 For individuals who are accredited investors (as defined in section 4A of the SFA) customers, we will process your trade application on a First-In-First-Out (FIFO) basis for as long as you have provided the necessary information for processing. All charges or fees will be disclosed to you prior to your trade application.

4.4 For the activities relating to initial public offerings and private placements, we may not be able to guarantee your placement as it depends on the relevant issuer’s confirmation where factors including but not limited to timing of order and investor’s profile may be considered.

4.5 We reserve the right to intervene in the execution if such orders would result in adverse market movement (e.g. large orders).

5. EXECUTION VENUES

5.1 The deals that we transacted in are traded on a principal basis. As such, you will be dealing with either us or one of our other offices (or affiliates). The execution venues we use are generally to clear our own market risk.

5.2 In meeting the best execution obligation, we will monitor which venues are likely to provide, on a consistent basis, the best available terms for our customers. However, we may not be able to connect to all venues or sources of liquidity.

6. USE OF AFFILIATES, THIRD-PARTY BROKERS, COUNTERPARTIES AND NOTE ISSUERS

6.1 We may use our affiliates, third- party brokers, counterparties and note issuers to assist in the execution of orders for you.

6.2 We conduct periodic review of such affiliates, third party brokers, counterparties and note issuers as part of our ongoing due diligence to assess and monitor if they are capable of providing the appropriate level of expertise in executing your orders.

7. MONITORING OBLIGATIONS

7.1 We perform periodic effectiveness testing such as order execution is monitored during pre- and post-trade and is subject to nature, scale and complexity of products as well as the characteristics of customers.

7.2 We will assess whether the entities to which we transmit orders or execution provide the best possible result for you.

8. UPDATES TO BEST EXECUTION POLICY

8.1 We will review and update our Disclosure Statement from time to time. Please visit our website to obtain the latest version of our Disclosure Statement.

8.2 Our commitment to provide the customers with best execution does not mean that we owe the customers any fiduciary or other duties over and above the specific regulatory obligations placed upon us.

8.3 If you require further clarification on our Best Execution Policy, you may contact your Relationship Manager or Sales Representative for more details.

(last update 30 December 2024)