Trading and execution

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  • 1. How frequently are trades reconciled to broker / custodian confirmations?

    Post execution trades are sent from GAM to State Street Investment Management Services team via a
    secure trade interface. These trades are then matched/reconciled to the brokers’ confirmations. The
    trades are posted in to Global Horizon as part of the NAV process. Any trades which are not matched or
    have failed settlement are investigated and reported / escalated as appropriate back to GAM on a daily
    basis.

  • 2. How are executed trades allocated to accounts?

    In the GAM Star Credit Opportunities fund range, each of the three funds (in USD, EUR and GBP) has
    specific trading lines with each counterparty, so when the fund managers trade on the secondary market,
    they specifically mention during the trade for which fund the trade is going to (vs block trading with an
    allocation at a later stage). On the primary market, if they do not get the full allocation and want to invest
    the position in more than one fund, the allocation between the funds is done on a pro-rata basis.

  • 3. Describe your trading process.

    Market prices are reviewed and in most cases, competitive quotes are sought from two or more
    counterparties, agency brokers or market makers. For transactions in less liquid markets and if not
    detrimental to the funds’ interests, a single counterparty may be approached on the basis of that
    counterparty’s suitability for the transaction. Most of the transactions are traded over the counter on a net
    basis.
    The long experience of Atlanticomnium in the industry has helped them build relationships with major
    investment banks, other industry analysts, fund managers, company managements, specialist brokers,
    industry consultants and other respected sources. This enables them to have access to insightful
    information, which provides them with the best available trading prices, in accordance with the best
    execution policy.
    Then orders for GAM funds are nearly always given to the broker with a price limit. The broker confirms to
    Atlanticomnium S.A.’s back office and the custodian (State Street). Atlanticomnium verifies and
    communicates the trades to GAM, upon confirmation for independent validation upon execution. Only
    upon validation are the transactions accepted. GAM then instructs the custodian to settle the trade. There
    are two pre-trade risk and compliance checks and one post trade compliance check. These checks are
    conducted independently of the investment team, operations and risk teams in the order management
    system.
    Transactions are monitored for prices against independent data regularly as well as any limits or size to
    ensure they comply with both the stated instructions of the manager and the requirements of the funds’
    prospectuses and UCITS regulations.

  • 4. Who is authorised to place orders on behalf of the fund? Describe their function and experience?

    Anthony Smouha Gregoire Mivelaz and Patrick Smouha , the co-fund managers of the funds, are
    authorised to place orders on behalf of the funds.

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