Introduction

We, China Construction Bank Corporation, Singapore Branch (the “Bank”) refer to the MAS Notice on Execution of Customer’s orders (SFA 04-N-16) pertaining to the implementation of policies and procedures for the following:-

(a)to place or execute or both, as the case may be, customers’ orders on the best available terms (“Best Execution”); and

(b)to place or execute, or both, as the case may be, comparable customers’ orders in accordance with the time of receipt of such orders.

Scope

Please note that this Best Execution Policy only applies to Over-The-Counter Derivatives Contracts executed by the Bank’s Treasury Department as principal.

Execution Factors

The Bank will take reasonable steps to obtain the best possible result when executing orders. In order to achieve the best possible execution outcome for the customer, we will consider a range of execution factors relevant to the placement or execution of the orders.

The execution factors that we will consider are (not in any order of priority):-

(a)Price

The price at which a transaction is executed

(b)Costs

The costs of the transaction, including internal and external costs, and the possibility of additional costs should an order be executed in a particular way

(c)Speed

The length of time it takes to execute the order or complete the transaction/settlement

(d)Likelihood of execution and settlement

The probability that the order can be fulfilled, which is more relevant and is expected to take higher priority for transacting illiquid instruments

(e)Size and Nature

The size of the order to be executed and the type of order placed

(f)Others

Any other considerations relevant to the execution of the order.

For transactions under the RMB purchase and sale business guided by the People’s Bank of China, the Bank is required by our Head Office to square off such trade positions with them only and the Bank is unable to offer a secondary venue, hence, the Bank will not be able to offer or provide a Best Execution outcome.

Notwithstanding the above, the Bank will take reasonable steps to quote a fair price and achieve best possible execution outcome for the customer, however, the Bank does not confirm that the Bank will be able to achieve Best Execution for every transaction.

Weighting of Execution Factors

These characteristics below may affect the ways in which execution factors are weighted or prioritized and it is up to the Bank to determine the changes in weighting and priority for each particular case:-

(a)Client Characteristics

Institutional clients likely have different needs to other professional individual investors

(b)Order Characteristics

Client’s specific instruction or preference, possibility and extend of market impact, triggering and operating of in-house order and system controls, risk and compliance issues etc.

(c)Financial Instrument Characteristics

Liquidity and recent performance or behaviour of such instrument, price volatility, etc.

(d)Other characteristics

As maybe relevant, such as market conditions or connectively considerations.

Affiliates and Third-Party Brokers/Counterparties

In executing orders for the Bank’s customers, the Bank may use affiliates and third-party brokers/counterparties to assist with the execution of orders. Where we use any affiliates and third-party brokers/counterparties, we will ensure that due diligence is carried out on such parties.

Specific Instruments from Customers

If there are specific instructions given by the Bank’s customers, whether in relation to an order as a whole or any particular aspect of an order), we will execute the order in accordance with those instructions.

In doing so, we will have satisfied our Best Execution obligations with respect to the part or aspect of the order to which the Bank’s customer’s instruction relates. For aspects of the order where no specific instructions have been given, we will apply the principles set out in this Best Execution Policy.

However, we reserve the right to intervene in the execution of such specific instructions given by the Bank’s customers if such orders would result in adverse market movement.

Monitoring and Updates to Best Execution Policy

The Bank performs periodic monitoring on the key requirements of this Best Execution Policy. This Best Execution Policy may be updated from time to time and any customer that deals or continues to deal with the Bank agrees to the terms and conditions of such updated Best Execution Policy.

Disclaimer

This document does not constitute an offer or invitation to enter into any type of financial transaction.