Order execution policy

 1. Introduction

This document contains the order execution policy for A/S Global Risk Management Ltd. Fondsmaeglerselskab (“GRM”). GRM offers hedging solutions to clients who are exposed to price changes in the oil markets.

The financial contracts offered by GRM to our clients are based on exchange traded products as well as being OTC. In these trades, GRM is the direct counterparty and trading on own account with the clients (bilateral trading). A minor portion of the trades are traded with clients on a cleared basis through a clearing member of the relevant exchange.

Generally, GRM does not provide order execution services to its customers and GRM will normally always be party to a trade whether OTC or exchange traded. The following contains the guidelines for any order execution services that notwithstanding the above may be carried out by GRM.

2. Guidelines on order execution

When providing order execution services to clients, GRM takes all necessary steps to ensure the best result for the client based on:

•  Characteristics of the financial instruments including; price, cost, payoff, risk, maturity
•  Characteristics of the client, i.e. client category, hedging purpose, risk profile, financial capability
•  Characteristics of the trading venue; liquidity, spread, transaction fees etc.
•  Characteristics of the client request, i.e. correlation to the client’s exposure, quality of underlying product, location of delivery, maturity etc.

In summary, this means that in order to ensure the best result for the client GRM will take into consideration the price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration, such as the above mentioned, relevant to the execution of the order.

If the customer has supplied a specific instruction, GRM will execute such order following the specific instruction.

Where GRM executes an order on behalf of a retail client, the best possible result shall be determined in terms of the total consideration, representing the price of the financial instrument and the costs relating to execution which shall include all expenses incurred by the client which are directly relating to the execution of the order.