Cross Trade Policy

Cross trade is defined as a buy and sell transaction of the same security between two or more funds’/ clients’ accounts managed by the Manager.

The Manager may conduct cross trades provided the following conditions imposed by the regulators are met:-

• the cross trade is in the best interests of both portfolios;
• the cross trade is executed on an arm’s length and fair value basis;
• the reason for such trades are documented and approval of the Chief Investment Officer is obtained prior to execution; and
• the cross trade transaction is disclosed to both the clients.

The cross trade will be executed in accordance with the Manager’s policy which is in line with the regulatory requirements, monitored by the compliance officer and reported to the investment committee.

Cross trades between the personal account of an employee of the Manager and any funds’ account or between the Manager’s proprietary accounts and clients’ accounts are strictly prohibited.