Best Execution Policy

Principles for executing investment decisions

A. General

1. Scope

The following principles apply to the execution of orders which rubarb processes for customers in accordance with the General Terms and Conditions for the purpose of buying or selling securities (only Exchange Traded Funds (ETFs)).

If the customer requires further information on our execution strategies, regulations and review procedures, this information will be provided within a reasonable period of time.

2. Priority of instructions

The customer can issue instructions to which execution venue or which securities trading bank an order should be executed. Such instructions always take precedence over the present Execution Policy.

In the app, the customer specifies a deposit account connection with the BNP Paribas SA branch in Germany. In this context, he can declare in the app that each of his orders to buy or sell the ETF shares offered should be executed via this custodian bank. The custodian bank in turn has this order executed via Lang & Schwarz TradeCenter AG & Co. KG. This instruction of the customer takes precedence over the present execution principles in any case.

Note:

If there is an instruction from the customer, rubarb will not execute its investment decision in accordance with the present principles. An instruction from the customer thus releases rubarb from taking the measures that it has defined and implemented within the framework of the execution principles below in order to achieve the best possible result when executing the orders with regard to the elements covered by the instruction in question.

This execution policy is reviewed regularly, at least once a year, based on the criteria described here. The customer will be informed immediately of any significant changes.

3. Execution of orders outside a trading venue

rubarb does not conduct any business outside of a trading venue.

B. Execution of the investment decision by third parties (selection policy)

rubarb does not execute customer orders itself, but commissions another securities trading bank to execute the ETFs instructed by customers to buy or sell. In connection with the selection of a securities trading bank, rubarb has taken precautions to achieve the best possible result for the customer. The selection of the securities trading bank charged with executing customer orders is made taking into account the following criteria.

1. Aim of the execution of customer orders

The securities trading bank to be selected has the option of executing customer orders via different execution channels (floor trading, electronic trading) or at various execution venues (e.g. capital management company, stock exchange, multilateral trading systems, systematic internalisers, market makers, OTC or other trading venues, domestically or abroad ).

These principles describe possible execution routes and locations that rubarb would choose when executing customer orders if it were to have the customer orders executed itself and not through the securities trading bank. It takes this own selection of execution routes and venues into account when selecting the securities trading bank. As a basis for information, rubarb uses the execution principles of the securities trading banks and compares them with their own selection of execution channels and places.

2. Criteria for the selection of execution venues

When selecting specific execution venues, rubarb primarily aims to achieve the best possible total price (purchase or sale price of the financial instrument and all costs associated with the respective disposition) for the customer (private customer). The costs to be taken into account when calculating the total fee include fees and charges for the execution venue at which the transaction is executed, costs for clearing and settlement and all other fees paid to third parties involved in the execution of the order. In addition, rubarb makes its selection decision based on the following criteria, whereby the individual criteria are weighted taking into account the characteristics of the customer and the financial instruments concerned:

3. Information basis for the selection of the execution venues

When selecting the execution venues, rubarb includes the existing clearing systems and emergency safeguards for the trading venues as well as the quarterly information published by the trading venues about the quality of the execution of orders with the financial instruments traded there. The trading venues provide the following information, among other things:

4. Execution policy for individual types of financial instruments

Based on the factors set out in No. 2 above for the selection of execution venues for private customers and taking into account the information from the trading venues about the quality of execution, as described in No. 3 above, rubarb has the following execution principles with reference to the selection of possible execution methods set up.

Investment assets in accordance with KAGB

FundsExecution venue (for private customers)
Exchange traded funds (ETF)Execution transaction with the respective capital management company or with a trading partner who offers to conclude transactions relating to the corresponding investment fund on stock exchanges (so-called market maker); alternatively execution at the main trading place for the ETF

C. Choice of Third Party

1. Screening

To ensure the best possible result for the customer in the event of disposals, rubarb has selected the following facility for executing the orders:

Investment assets in accordance with KAGB

Funds Settlement bank (for private customers)
Exchange traded funds (ETF)Processing via BNP Paribas SA branch in Germany and Lang & Schwarz TradeCenter AG & Co. KG

2. Deviation in individual cases

If, in individual cases, orders are to be executed by entities other than those named in No. 1 or by entities other than those named by customer instructions (within the meaning of Section A. No. 2), the customer’s consent is obtained beforehand.

3. Application of the execution policy of the commissioned third party

Since rubarb commissions another securities trading bank to execute customer orders, the respective ETF purchase and sale takes place in accordance with the precautions that this securities trading bank has taken to achieve the best possible execution. The execution principles of the securities trading bank can deviate from the above-mentioned principles of rubarb regarding the execution venues and execution channels.

Hamburg, July 2020