Best Execution Policy


The purpose of this document (Best Execution Policy) is to inform you of how Mizuho Bank, Ltd., Singapore Branch (“the Bank”) will execute trades with or on behalf of its clients. This takes into consideration the Notice [SFA 04-N16] and Guidelines [SFA 04-G10] as set out by the Monetary Authority of Singapore (MAS).

1. Scope and Application of the Best Execution

This document only applies to clients who are dealing in capital market products[1] handled by the Bank. Best execution is owed to clients where the Bank executes orders on behalf of clients who place legitimate reliance on the Bank to protect their interests in relation to pricing and other elements of the transaction.

Best execution is not owed to clients who are not placing legitimate reliance on the Bank to protect their interests. The Bank will determine if clients are placing legitimate reliance on the Bank by taking into account the following four considerations for non-retail investors[2].

  1. Which party initiates the transaction:
    Where the client initiates the transaction, it is less likely that the client is placing legitimate reliance on the Bank. In circumstances where the Bank may communicate trade ideas, market communications or indicative processes as part of our general business, we regard these communications as purely for information purposes and such communications shall not be deemed to have initiated the transaction.
  2. Market practice, including the convention of the client to ‘shop around’ for the best deal:
    Where market practice for a particular product suggests that the client already has ready access to different providers who may provide quotes and that client has the ability to shop around, it is less likely that the client will be placing legitimate reliance on the Bank.
  3. Relative levels of transparency within a market: 
    In circumstances where pricing information is transparent and it is reasonable that the client has access to such information, it is less likely that the client will be placing legitimate reliance on the Bank.
  4. The information provided by the firm about its services and any agreement reached with the client:
    Where any terms of an agreement with the client do not indicate or suggest that an understanding has been reached that the client will place any legitimate reliance on the Bank or the Bank has agreed to provide best execution.

2. Execution Venue

The Bank has a list of execution venues to execute transactions which we determine as beneficial in providing best execution.

3. Execution Factors

Where a duty to achieve best execution applies, the Bank will take account of the following factors when executing a transaction on behalf of the client:

Price - The price will depend upon the method of order receipt and characteristics of the order, and, may also be affected by any specific instructions given by the client.

Speed of execution - The time it takes to execute the order will depend on the price volatility and liquidity of the market.

Size and nature of order - Orders are executed in the manner that is suitable to the size requested and does not have any impact on the market.

Likely market impact; Nature of the market for the financial instrument - This may include, for example: when the market volatility of the financial instrument in question is greater than normal, there may be a reduction in the liquidity in the marketplace as well as the availability of prices.

Likelihood of execution and settlement - The likelihood for the Bank to be able to complete the order. For example: having necessary credit facilities and clearing and settlement services in place to guarantee settlement.

Any “external costs” relevant to the execution - Any external costs that are related to the execution of the transaction. For example: execution venue fees, clearing and settlement fees and any other fees paid to third parties. 

Any other consideration that the Bank considers to be relevant to the execution of the transaction.

[1] Foreign Exchange Derivatives (excluding Spot Foreign Exchange), Interest Rate Derivatives and Commodity Derivatives
[2] Client who is an accredited investor, expert investor or institutional investor (collectively known as “non-retail investors”). Clients that are institutional investors are not subject to Best Execution requirements.


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