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Important Notice to Clients: Order Handling Policy with respect to Orders executed by J.P. Morgan Securities (Asia Pacific) Limited
When handling your orders, J.P Morgan Securities (Asia Pacific) Limited (“JPMSAPL”) will take all reasonable steps to provide execution on best available terms under the Hong Kong Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission. JPMSAPL has processes in place which are reasonably designed to obtain the best available terms taking into account the nature of the order, the execution venues (on reasonable commercial terms) available (including JPMSAPL and/or its affiliates acting as principal), and the priorities identified by you to JPMSAPL and/or JPMSAPL’s affiliates to which you give instructions.
JPMSAPL, an affiliate of JPMSAPL or some other person connected with JPMSAPL, may have an interest, relationship or arrangement that is material in relation to your order but JPMSAPL may deal or arrange deals in such circumstances without further specific prior notification to you, and JPMSAPL and/or its affiliates may retain any profit from such transactions. For example, JPMSAPL or an affiliate of JPMSAPL may deal in investments as principal, or as agent for more than one party, or may make a recommendation to buy or sell an investment in which JPMSAPL and/or an affiliate of JPMSPAL have a long or short position or in which JPMSAPL and/or an affiliate of JPMSAPL have been given instructions by another customer to buy or sell. Information barriers may exist between the different parts of JPMSAPL and its affiliates, which will mean that the person dealing with or for you may be unaware of such a situation. However, even where this is not the case, JPMSAPL shall not, in providing services, be obligated to use or disclose information, whether or not unpublished and/or price sensitive, which is in possession of any of JPMSAPL’s business areas or any of JPMSAPL’s affiliates.
Where you give your order to an affiliate of JPMSAPL (such as J.P. Morgan Securities LLC in the United States) for execution in Asia markets, you hereby authorize that affiliate to send your specific trade instructions (including with respect to the execution capacity in which JPMSAPL and/or its affiliates may fill your order) for and on your behalf to JPMSAPL. JPMSAPL will endeavor to execute your orders in Hong Kong listed equities as your agent unless it understands your instructions otherwise whereupon it may endeavor to arrange for an affiliate of JPMSAPL to act as the principal to your order. Where JPMSAPL is unable to complete the full execution of your order as your agent, any residual part of your order which could not be completed as agent may be completed by an affiliate of JPMSAPL as principal. In such circumstances, JPMSAPL and/or its affiliates will endeavour to notify you of the residual portion that is filled as principal.
Where JPMSAPL arranges execution of your order in markets outside Hong Kong, JPMSAPL may assume, unless JPMSAPL reasonably understands your instructions otherwise, that you consent to JPMSAPL and/or its affiliates filling or otherwise facilitating your order (or part of your order) as principal in accordance with the laws, regulations, rules and customary market practices (including with respect to the execution capacity in which JPMSAPL and/or its affiliates may fill your order) of the applicable market.
By giving JPMSAPL (or its affiliates) an order for execution by JPMSAPL you will be deemed to have agreed to the handling of your order by JPMSAPL in the manner above.
Should you have any queries, please do not hesitate to contact your JPMSAPL representative.
For and on behalf of J.P. Morgan Securities (Asia Pacific) Limited
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