Best Execution Policy

The following principles apply to the execution of investment decisions made by the asset manager in accordance with the asset management agreement and within the investment guidelines defined therein for the purpose of acquiring or disposing of securities or other financial instruments (transactions).

The asset manager does not execute the investment decision themselves but instead engages third parties to carry out the execution.

To the extent that the investment decision involves the acquisition or disposal of shares in investment funds whose issuance or redemption is carried out through a custodian bank, these principles do not apply. The asset manager will execute the acquisition or disposal of shares in investment funds in accordance with the Luxembourg Law on Undertakings for Collective Investment of December 17, 2010. Investment decisions regarding Exchange Traded Funds (ETFs) that are traded on an exchange will be executed according to the principles of the respective custodian bank.

The client may provide the asset manager with instructions regarding which execution venues should be used for executing the asset manager's investment decisions. Such instructions will take precedence over these execution principles in all cases.

Note:
The client acknowledges that in such cases, the obligation for best execution does not apply, and the securities orders may not be executed in the best possible manner.

The client (hereinafter referred to as "Client") has instructed the asset manager to engage certain institutions for the execution of the asset manager’s investment decisions. If the client provides the asset manager with account details at only one custodian bank, this will be regarded as an instruction to process investment decisions through that institution. Such instructions will take precedence over these execution principles in all cases.

Note:
If there is an instruction from the client, the asset manager will not engage third parties or select them according to the present principles.

The asset manager takes measures to achieve the best possible outcome for the client. The selection of a third party, tasked with executing the asset manager's investment decisions, is made based on the following criteria:

Investment decisions can generally be executed through different execution methods (such as in-person trading and electronic trading) or at various execution venues (such as stock exchanges, other trading venues, domestic or international). These principles describe potential execution methods and venues for the relevant types of financial instruments that consistently promise to deliver the best possible outcome in the client’s interest, which the asset manager will consider when selecting the third party to execute the investment decision.

When selecting executing entities, Baumann & Partners ensures that they maintain a standard market Best Execution Policy, which includes, in substance, the following criteria:

• Creditworthiness of the executing entity
• Best possible overall price (execution price, costs, and fees) for the client
• Security in settlement and custody
• Speed and completeness in execution and settlement

Note:
If asset management refers to investment fund shares, these principles do not apply, as the issuance and redemption of shares are carried out through the respective custodian bank. Furthermore, differing instructions are not possible.

The five most important executing entities used by Baumann & Partners for executing orders in financial instruments are the following custodian banks:

• V-Bank
• Banque de Caisse d’Epargne de l’Etat Luxembourg (BCEE)
• DAB
• DZ Privatbank
• UBS Switzerland

Baumann & Partners regularly collaborates with a number of banks and custodians and has reviewed their execution principles. If, in individual cases, investment decisions are to be executed by entities other than these, the asset manager will conduct a review of the above selection criteria beforehand.

If an entity is designated based on a client instruction as per Section A, Item 3, it is considered as the client's consent to have the investment decision executed by that entity.

Since the asset manager engages a third party to execute investment decisions, the respective transaction is carried out in accordance with the arrangements the engaged third party has in place to achieve best execution. As a result, there may be deviations from the aforementioned principles concerning execution venues and methods.

When selecting possible execution methods for individual order groups, the Best Execution Policies of the respective custodian banks apply, which are provided to clients upon account opening.