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Cross trade policy 

Cross trade is defined as a buy and sell transaction of the same security between two or more funds'/ clients’ accounts managed by the Manager.
 

The Manager may conduct cross trades provided the following conditions imposed by the regulators are met:

  • the cross trade is in the best interests of both portfolios;
  • reason for such transactions is documented prior to execution of the trades;
  • the cross trade are executed through a dealer or a financial institution on an arm’s length and fair value basis; and
  • the cross trade transactions are disclosed to both clients.


The cross trade will be executed in accordance to the Manager's policy which is in line with the regulatory requirements, monitored by the compliance officer and reported to the members of the committee who carry out the oversight function of the Fund. A compliance officer must verify that any cross trade undertaken by the fund management company complies with the requirement provided in paragraph 11.30 of the Guidelines on Compliance Function for Fund Management Companies.


Cross trades between the personal account of an employee of the Manager and the Fund's account or between the Manager's proprietary accounts and clients’ accounts are strictly prohibited.

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