Best execution policy 

The Swedish original version of the Best execution policy (Swe. Instruktion för bästa orderutförande och sammanläggning av order) has been adopted by the Board of Directors of Lysa AB (“Lysa”) on 2020-06-12. This English version is a translation. 

Responsible for the document: Chief Executive Officer 

1. Background

In accordance with Chapter 9, Section 33 of the Securities Markets Act, a securities company must establish guidelines for the best execution of orders. Further, Lysa must under the Commission Delegated Regulation (EU) 2017/565 make an annual revision of the guidelines. Therefore, Lysa has adopted the following policy. 

This policy includes information on how Lysa will ensure that the customers’ best interest is taken into account when placing orders. Orders are placed against the fund company Lysa Fonder AB when trading in the funds distributed by Lysa (“Lysa’s funds”).

2. Best execution and order accumulation in Lysa’s funds

Lysa’s funds are funds which are traded outside the market by transmitting an order to Lysa Fonder AB for execution in accordance with the fund rules. Lysa will execute a customer’s order fast, efficient and fair. 

Lysa will accumulate a customer’s order of fund shares in Lysa’s funds with other customers’ orders. An accumulated order which has been executed in its entirety will be distributed with regard to the NAV applicable for the relevant business day. If an accumulated order only can be partly executed, the executed part will be divided proportionally between the customers based on the NAV applicable for the relevant business day.

3. Disruptions 

In case of market disruptions, insufficient access to Lysa’s internal technical systems or other force majeure events outside of Lysa’s control, it may according to Lysa’s assessment be impossible or inappropriate to execute an order according to any of the methods specified. If so, Lysa will take all reasonable measures to by other means achieve the best possible result for the customer.

4. Compliance and updates 

The Chief Executive Officer is responsible for the compliance and implementation of this document. Lysa will on an annual basis review its policy that has been adopted for best execution. The policy will also be reviewed when there has been a material change which affects Lysa’s possibilities to achieve the best possible result when executing customers’ orders. The policy will be updated annually or more regularly if necessary.