Best Execution Policy

Update

Effective September 28, 2024, the Canadian Investment Regulatory Organization (CIRO) has updated its rules, including its Best Execution rules. The updated CIRO rules expand the scope of regulations that previously applied only to securities-related activities and now include derivatives-related activities where appropriate. To ensure consistency with the updated CIRO rules, Raymond James Ltd. has updated the following Best Execution Policy.

This policy is issued pursuant to, and in compliance with, Canadian Investment Regulatory Organization (CIRO) Rule 3100 Part C Best Execution of Client Orders and National Instrument 23-101 Trading Rules. In relation to order execution, Raymond James Ltd (“RJL” or “we”) is required to obtain the most advantageous execution terms reasonably available under the circumstances when executing client orders. RJL is required to take into account a range of execution factors and determine their relative importance based on the characteristics of our clients, the orders that we receive and the markets in which we operate.

SCOPE OF THE POLICY

This policy applies to trading conducted on the RJL’s ECM, PCG and fixed income trading desks and includes client orders respecting all securities, including listed securities and derivatives, foreign-exchange traded securities and transaction in OTC securities.

BEST EXECUTION

Best Execution represents Raymond James’ obligation to seek the most advantageous execution terms reasonably available under the circumstances when executing a transaction on your behalf. We will consider such execution factors as price, speed, likelihood of execution & settlement, and costs. We will also consider prevailing market conditions when manually handling client orders:

• The direction of the market for the security or derivative being traded;
• The depth of the posted market;
• The last sale price and the prices and volumes of previous trades;
• The size of the spread;
• The liquidity of the security or derivative.

SPECIFIC INSTRUCTIONS FROM CLIENTS

When a client gives specific execution instructions, we will execute the order in accordance with those instructions so far as reasonably possible, subject to compliance with applicable regulatory requirements including the Order Protection Rule and the obligation not to create or continue to lock or cross a protected order. A specific instruction from a client may prevent RJL from taking the steps necessary to obtain customary best execution. To the extent that a client instruction is not complete, RJL will apply this policy in order to determine any non-specified part of trade execution.

ORDER HANDLING

RJL trading staff and systems will be available for order execution during between 9:30 am EST and 4:00 pm EST Monday through Friday, not including statutory holidays. Staff may be available outside of standard marketplace hours; however, order taking and/or trade execution outside of these times will be undertaken on a best efforts basis. Purchases and sales of securities or derivatives outside of regular trading hours may entail special risks, including lower liquidity and higher volatility which may result in wider spreads.

Principal Marketplace

The principal marketplace for a Canadian listed security or derivative is its primary listing exchange.

Pre-Open

Orders received before market open (9:30 AM) will be placed in the pre-open on the principal marketplace for execution or, at client request, RJL will route these order to a marketplace which maintains Pre-Market trading.

Post-Opening

Unfilled orders are moved to the post opening session of the marketplace where they were originally entered and will remain until the order is filled, expired, changed or cancelled.

Order received during the post opening session will be routed using a smart order router.

Changes to an outstanding order, or portion of an outstanding order, will be handled the same as a new order received and will be entered into the “best market” at the time.

RJL may route client orders resting on a marketplace to an alternative marketplace if we feel such actions will increase the likelihood of obtaining best execution on our client orders.

After the Close

Orders received after market close (4:00 pm) will either be entered in the pre-open on the principal marketplace the following trading day, or, at client request, RJL will route these orders to a marketplace which maintains afterhours trading.

Stop Loss

A stop loss order in Canadian markets is an order which is entered to buy or sell a particular security with a predetermined “trigger” price and which becomes executable once the trigger price has been reached. As a special term order, with each execution price having different risks, there is no guarantee of a fill. “On Stop” orders entered on US Exchanges are triggered for execution by the National Best Bid or Offer and the stock does not have to trade at the trigger price in order to be filled.

Unlisted Securities

For unlisted securities, fair pricing obligation will be verified through contact with multiple dealers. Records of communications will be retained for future audit purposes.

EXECUTION VENUES AND BROKERS

In order to achieve best execution for its clients, Raymond James Ltd.’s internal policy is to subscribe to all lit Canadian marketplaces (both protected and unprotected) to ensure compliance with UMIR, CIRO Rule 3100 Part C and NI 23-101. As such, in the event of the launch of a new marketplace, RJL will assess and participate in the testing facilities of such new marketplace.

The factors that have been considered in determining the list of execution venues may include the depth of liquidity a particular venue is able to offer, the likelihood of execution, speed of execution, reliability and system availability, historical trading activity and the robustness of the clearing arrangements.

Transactions executed on a non-Canadian marketplace, including the US marketplace, will be handled by another broker, which could be an affiliate of Raymond James. In all such cases, these orders will be required to be executed in accordance with the securities rules and regulations of that jurisdiction and will be subject to those order handling and routing practices. This could result in the executing broker applying different best execution criteria.

TRADE ROUTER

Raymond James Ltd employs Smart Order Router capabilities on all trade entry systems. The routers employed simultaneously route to all lit marketplaces and execute against the displayed volume which match the order criteria. RJLs routing decisions, including algorithmic trading, are made by advanced smart order router logic which adjust to market conditions. The decision as to which execution venues and price points to target will be made based upon either client instructions and/or the router’s programmed parameters.

This logic “sprays” numerous marketplaces in order to capture displayed volumes at the best available price before iteratively moving to the next price level. Any rejected orders which are immediately executable on a different marketplace are routed there by the Smart order router. The routers primary objective is to attain best execution.

Traders may choose not to employ the “sweep router” and instead book directly to a marketplace. Prior to doing so, all traders will verify through the consolidated quote that no “trade-through” will result. In the event that the order, or any part thereof, is not executable, the order will book to the marketplace according to parameters set by the Best Execution and Order Routing Committee.

Conflicts Disclosure

Raymond James does not have a material ownership interest in any of the exchanges or marketplaces in Canada, therefore, unlike other Canadian broker dealers, we do not have a conflict of interest when establishing order routing priorities.

Order Routing and Treatment of Market Center Fees/Rebates

Certain marketplaces may provide rebates and/or credits against fees in return for routing of orders. Any remuneration that RJL receives for orders reduces the execution costs and does not accrue to the client account. Marketplace fees and rebates are considered as part of overall costs when fulfilling our best ex obligations.

FIXED INCOME

Raymond James Ltd trades in the following over-the-counter securities: government bonds, corporate bonds, select high yield offerings, money market instruments, GICs, structured products, strip coupons and new issues. In accordance with industry practice, RJL trades as a principal in trades for over-the-counter securities. Pricing of bonds remains a manual process, with most trades executed via person-to-person negotiations.

RJL is required to provide best execution to our clients when executing all over-the-counter trades. When a client gives specific execution instructions, we will execute the order in accordance with those instructions so far as reasonably possible, subject to compliance with applicable regulatory requirements. Where no instructions are provided by the client, we will typically consider the following execution factors in the following order of priority: Price, Overall Cost, Certainty of Execution and Speed. Raymond James owes a general duty to our clients to use reasonable efforts to obtain a price that is fair and reasonable in relation to prevailing market conditions, including any mark-up or mark-down or added commission. Prices are verified as being in “the context of the market” by referring to multiple pricing sources on a security and retail commission guidelines have been established. Our fixed income traders use the same level of care and diligence that they would if undertaking the transaction for their own account.

RJL reports trade details in debt securities to the Investment Industry Regulatory Organization of Canada who oversees all investment dealers and trading activity on debt markets in Canada. These information reports assist CIRO in determining whether our best execution policies and procedures are reasonably designed to obtain prices that are, at a minimum, fair and reasonable.

To assist with ongoing appropriateness of the RJL fixed income best practices, the Debt Capital Markets Committee will additionally review best execution policies, at least annually, and whenever there is a material change to the trading environment for over the counter securities.