Mercer Limited Best Execution Policy 

Mercer will:

1. When providing the service of portfolio management, act in accordance with the best interest of its clients when placing orders with other entities for execution that result from decisions by Mercer to deal in financial instruments on behalf of its clients; and
2. When providing the service of receipt and transmission of orders, act in accordance with the best interests of its clients when transmitting client orders to other entities for execution.

Mercer will ensure it takes all sufficient steps to obtain the best possible result for clients taking into account price, costs, speed, likelihood of execution and settlement, size, nature and any other consideration relevant to the execution of the order, unless there is a specific instruction from a client whereby Mercer will execute the order in line with that instruction.

Any specific instructions from a client may prevent the firm from taking the steps that it has designed and implemented in this execution policy to obtain the best possible result for the execution of those orders in respect of the elements covered by those instructions.

Mercer must not receive any remuneration, discount or non-monetary benefit for routing client orders to a particular trading venue or an execution venue which would infringe on its requirements relating to conflicts of interest or inducements.

Where Mercer has been appointed by clients via an investment management agreement to manage a portfolio of collective investment schemes (“Funds”) and/or securities, Mercer usually buys and sells shares/units in collective investment schemes via the transfer agent, at the Net Asset Value of the fund on a given day. Mercer will consider the factors mentioned above when buying and selling funds. In addition to these factors, Mercer will also ensure that funds are registered for distribution in the specific country of domicile of the client, which may result in a delay in implementing the trade whilst registrations are pending.

Where a client portfolio includes securities other than collective investment schemes, Mercer will appoint a Sub-Investment Manager as described below, in the section titled “Delegation of investment management via segregated mandates”.

Mercer carries out discretionary portfolio management for its clients and, as part of this activity, buys/sells the Mercer Funds (collective investment schemes). Mercer Global Investments Europe (MGIE) is the investment manager for these funds and appoints sub-Investment Managers who use trading counterparties to buy and sell investments in the sub-Funds.

Where discretionary management is delegated to Sub-Investment Managers, the Sub-Investment Manager is contractually obliged to comply with all regulatory requirements applicable to managing the portion of the fund/portfolio (Segment) allocated to them. Oversight of Sub-Investment Managers is undertaken by MGIE.

Each Sub-Investment Manager is, prior to appointment, subjected to a rigorous due diligence process. As part of this, MGIE obtains a copy of the relevant Sub-Investment Manager’s own Best Execution Policy to ensure that it takes all sufficient steps to achieve the best possible result for clients.

Mercer may be involved in identifying counterparties for certain trades; however, Sub-Investment Managers will be fully responsible for conducting due diligence on such counterparties and managing the ongoing counterparty relationship.

Sub-Investment Managers are also required to provide their Best Execution Policies should there be a material amendment to their Policy.  Mercer, in conjunction with MGIE, will review changes to Best Execution Policies on a case-by-case basis. It is important to note that, where a financial instrument is traded on a market, Sub-Investment Managers may transact orders outside the relevant market, to obtain the best possible result for clients.

Internal use only

This document supersedes and replaces any previous Mercer documents on this subject. Mercer reserves the right to modify, suspend or terminate this document at any time.