最佳条件执行交易指示政策（只备有英文版）

This Policy is pursuant to the guidelines and circulars of the Securities and Futures Commission (the “SFC”). In relation to order execution, DA International Financial Service Limited (“the Company”) are required to obtain the most advantageous execution terms reasonably available under the circumstances when executing client orders. The Company is required to take into account a range of execution factors and determine their relative importance based on the characteristics of clients, the orders that the Company receives and the markets in which the Company operates.

1. Scope of the Policy
This Policy applies to trading conducted on securities, futures and options and other related financial products that the company provides.

2. Legitimate Reliance
The best execution is owed where the Company executes orders on behalf of clients where clients place legitimate reliance on the Company to protect their interests in relation to pricing and other elements of the transaction. The assumption is that clients always place legitimate reliance on the Company, and therefore best execution applies. In order to help determining whether a client is legitimately relying on the Company to provide best execution, the Company should consider the following factors, where applicable:
• The client’s level of sophistication;
• The client’s ability to negotiate competitive prices bilaterally based on factors including the client’s product knowledge, experience and level of market access;
• party initiating the transaction;
• existence of market for shopping around; and
• Whether the Company has disclosed to the client that best execution is not applicable.
The client is considered not placing legitimate reliance on the Company to provide best execution under the following circumstances:
• where the client initiates the transaction, (for example where the client provides details as to direction, size, level and/or other specific instruction), and when the Company is willing and able to trade within those parameters and an agreement to the transaction therefore reached between the Company and the client which is thereafter executed;
• where the Company has disclosed to the client that best execution is not applicable;
• where the pricing information for the particular product or asset class is transparent and it is reasonable that the client would have ready access to such information; or
• where the client accepts a price provided by the Company further to a request for quote or other expression that may lead to the execution of a transaction.

3. Best Execution Considerations
Best-execution obligation requires the Company to take reasonable measures to obtain the best possible results for the client when executing orders. the Company shall take reasonable steps to achieve best execution of the client’s orders in accordance with applicable local trading rules and market regulations.
3.1 Execution Factors
The manner in which an order is executed for a client can be affected by various factors and criteria. In determining how a specific client order should be executed, the Company should take into consideration the following:
• Nature of client’s orders;
• Client’s specific instructions;
• Time of reception of orders compared to other orders;
• Price;
• Cost;
• Speed of execution;
• Speed of settlement;
• Likelihood of execution;
• Likelihood of settlement;
• Size of the order;
• Market liquidity and impact of the order on the market; and
• Any other relevant factors.
Clients may instruct the Company to take into consideration certain execution factors to which they attach greater importance. In the absence of a client’s specific instructions, the Company should exercise its own discretion to determine the relative importance of the execution factors and should use reasonable efforts to obtain the best possible outcome in executing clients’ orders. In determining the relative importance of the execution factors to achieve best outcome for clients’ orders, the Company should also take into consideration the following characteristics:
Market Considerations
• Likelihood of execution;
• Market depth;
• Characteristics of the execution venues to which that order can be directed;
• Characteristics of the financial instruments that are the subject of the order; and
• Recent order flow. Counterparty Considerations
• Ability of a counterparty to execute in the desired volume;
• Ability of a counterparty to act on a confidential basis;
• Ability of a counterparty to act with minimum market effect;
• Creditworthiness of a counterparty in relation to credit risk created by the transaction (including estimated time for settlement);
• Willingness and ability of a counterparty to make a market in particular securities;
• Counterpart’s reputation for ethical and trustworthy behavior;
• Market knowledge of a counterparty;
• Ability of a counterparty to execute difficult transactions in unique and/or complex securities;
• Operational risk the counterparty presents;
• Quality of research and trading ideas provided;
• Market making activity how much liquidity the counterparty should likely provide in the future; and
• Ancillary fees that may be waived or incurred in connection with such counterparty. Other considerations
• Operational considerations (e.g. ability to settle effectively, use of automation);
• Client preferences/guidance or specific instructions (if applicable);
• The type of clients, whether retail clients or otherwise; and
• Other relevant factors, depending on the market place or location.

4. Specific Instruction from Clients
In case specific instruction is received from the client, the Company should prioritize the specific element(s) as given in client’s instruction when executing such order(s): -
• Specific price and/or;
• Specific broker and/or;
• Specific counterparty and/or;
• Specific timeframe and/or;
• Specific venue etc.
In considering clients’ specific instruction, the Company may be prevented from executing the order(s) in accordance with this Policy to achieve the best possible results in executing those order(s). In respect of other elements of the order (if any) that are not covered by the specific instruction, the Company should still be obliged to provide best execution.

5. Electronic Orders
Electronic orders placed by the client should be routed directly to an exchange or trading venue via a Direct Market Access platform. In such situation, the client should be considered to have provided a specific instruction to the Company.

6. Execution Venues and Brokers
The best execution arrangement might be applicable through the exclusive use of affiliates, connected parties and third parties. When the Company passes its client’s order to another entity for execution, the Company should take all sufficient steps to achieve the best possible outcome, in accordance with this Policy, taking account of the factors mentioned above and any specific instructions received from the client in relation to that order.
When the Company uses the Company’s affiliates or connected party to execute a client’s order, the Company should ensure that any conflicts of interest are managed appropriately to provide the best result for the client. Executing client orders with the Company is permitted, subject to local regulatory requirements and/or restrictions contained in client agreements (e.g. in certain jurisdictions, principal and/or agency transactions with the Company are not permitted). These transactions must be conducted on an arms-length basis. Adherence to these requirements is the responsibility of dealers. Particular care must be taken with respect to principal transactions, especially in structured products, to determine whether the transaction is permitted and to satisfy legal and regulatory requirements.

7. Conflicts of Interest – Prohibited Considerations
Whenever the interests of the client conflict with those of the Company or the employee, the interests of the client must prevail. To help ensure this, the following factors must NOT influence the selection of an execution venue or timing of a trade:
• the Company ‘own commercial interests (e.g., directing trading volume to a counterparty as a reward for their distribution arm selling the Company’s products, directing trading to a counterparty who was willing to absorb a loss on a trade error, directing trading to an affiliate with the sole purpose of improving trading volumes/revenue);
• Compensation or rewards to a broker-dealer or its affiliate for the promotion or sale of shares of any fund (registered or private) for which a legal entity in affiliate serve as an adviser or sub-adviser (each a “Fund”);
• Offsetting obligations of the Company to a broker-dealer or affiliate for the promotion or sale of Funds to their clients;
• Entertainment or gifts given by the counterparty to a Company’ dealer;
• Compensation incentives that reward dealers based on volume of transactions with a particular counterparty;
• Whether a spouse, relative or friend is employed at the counterparty (where relevant, any such relationships must by disclosed to the employee’s supervisor and the Legal and Compliance Department); and
• Any factors not in the best interests of the client.

8. Prohibited Practices
The following practices are PROHIBITED:
• Employees (other than portfolio managers and research analysts) may not suggest or recommend to traders the use of any particular broker-dealers to execute trades; and
• Employees may not disseminate information regarding brokerage commissions paid to any broker-dealer except to senior management, compliance department and those employees whose duties require that they have access to such information.
Under no circumstances may the distribution staff exert any direct or indirect influence over dealer’s decision on the choice of brokers. Should the distribution staff share information regarding distributors who also act as broker dealers and execute transactions on behalf of the funds, the managers/dealers may not consider this information when executing orders with brokers, as this may be viewed as influencing dealer’s decisions.

9. Exceptions
The best execution is NOT applicable under the following scenario: -
• Where the client accepts a firm price or two-way price provided by the Company in response to client’s request for a quote;
• Order from the client with specific instruction such as request to execute at a specific price limit or request for execution on a particular exchange where the Company shall be deemed to have satisfied its best execution obligation to the extent that it executes an order, or a specific part of an order, according to client’s specific instructions;
• Quote driven order from the client who is a professional investor as defined under paragraphs (a) to (j) of the definition of “professional investor” in section 1 of Part 1 of Schedule 1 to the Securities and Futures Ordinance (Chapter 571 of the Laws of Hong Kong) where the client does not place legitimate reliance on the Company to provide best execution as it is the client who ultimately decides whether to proceed with a transaction on the basis of a firm price provided by the Company which the client can accept or reject;
• Order in collective investment schemes where the Company should trade exclusively with fund managers or its appointed administrators which may be affiliates or third parties on the Company’s approved counterparty list;
• In accordance with the terms of a contractual relationship between the Company and the client, the Company may exercise a power to terminate such relationship upon the occurrence of an event of default in respect of which the client is the defaulting party or a similar event. In exercising this power (including, without limitation, by unwinding or otherwise terminating any client position or enforcing any security), the Company acts for the Company’ own account to protect the Company’s interests and does not act on the client’s behalf in terms of best execution.

Regardless whether best execution applies or not, the Company should still be required to treat the client fairly and to manage any conflicts of interest that may arise.

10. Monitoring and Review
The Company will monitor the effectiveness of its order execution arrangements on a regular basis in order to identify any issues that may affect its ability to continue to obtain the best outcome for the execution of client orders on a consistent basis using the venues stated in this Policy.

The Company will review its order execution arrangements and this Best Execution Policy regularly and will notify clients of any material changes to its order execution arrangements or this Policy as described above by posting the information on its website.

11. General
The contents of this Policy are not intended to be exhaustive or a complete statement of the law or regulatory requirements.
This Policyis pursuant to the guidelines and circulars of the Securities and Futures Commission (the “SFC”).In relation toorderexecution,DA International Financial Service Limited (“the Company”)arerequiredtoobtainthe most advantageous execution terms reasonably available under the circumstances when executing client orders.The Company is required to take into account a range of execution factors and determine their relative importance based on the characteristics of clients, the orders that the Company receives and the markets in which the Company operates.