Introduction

The purpose of this document is to inform CSAM's clients or potential investors of the policy for selecting and executing orders on behalf of the portfolios it manages.

This document is intended for professional or qualified investors within the meaning of MiFID, as well as holders of individual portfolios managed under mandate or holders of units of Alternative Investment Funds (AIF).

This document was prepared in accordance with the MiFID 2014/65/EU and the AMF Position-Recommendation No. 2014-07, Best Execution Guide.

The majority of CSAM's orders are entrusted to Interactive Brokers as part of its intermediation activities. CSAM has requested that its intermediaries be categorized as professional clients and provide the management company with "best execution" when acting on behalf of its clients.

Best Execution Policy

General

All necessary measures are taken to ensure that order execution occurs in the client's best interests and respects market integrity, taking into account the factors listed by ESMA: price, costs, speed, likelihood of execution and settlement, size, nature of the order, or any other consideration relevant to the execution of the order.

Order Types

Depending on the type of order sent, the relative importance attributed to the execution factors and the asset characteristics concerned by the order, the latter will be routed to an execution venue according to a determined execution strategy.

All measures are taken to ensure that orders are executed in the best interest of CSAM and to promote the integrity of the market by taking into account the criteria set out, such as price, liquidity, speed, cost, etc., according to their relative importance for the different types of orders transmitted.

Aggregation and Allocation

CSAM will only aggregate orders from clients who meet the following criteria:

• They participate in the same investment program.
• They have identified a Prime Broker or equivalent for trade execution that supports CSAM's chosen allocation methodology.
• They have a sufficient notional size, such that normal trading in full-sized contracts results in an acceptable weighting of aggregate risk equal to other clients.

Clients who do not meet the above criteria may have their orders placed individually in the market. CSAM will manage their account to have the same overall risk profile as participating client accounts, as far as practicable. Furthermore, orders from clients may be aggregated with the order of another client or of CSAM, only where it is reasonably believed to be in the best interests of all clients concerned. The Investment Management Agreement must disclose this to clients involved in aggregated trades. The effect of aggregation may work on some occasions to their disadvantage in relation to a particular order.

CSAM will not give unfair preference to itself or to any client for whom it has dealt when allocating orders. In all cases, all clients must receive fair and equitable treatment. CSAM will not receive any additional compensation as a result of the aggregation.

Portfolio Swaps

CSAM will not carry out portfolio swaps.