Best Execution Policy
This document constitutes the Best Execution Policy of the Financial Cooperative Association of International Civil Servants, hereafter “AMFIE” or “the Association”. Developed by the authorized management, it describes the investment services provided by AMFIE as well as the channel chosen for the execution of investment instructions in order to obtain the best possible result.
This Policy is based on current regulatory compliance requirements. It will be reviewed regularly to reflect regulatory developments.
The Association’s internal control service regularly verifies compliance with current regulatory requirements and, if necessary, makes recommendations for updating the Policy.
Any order placed by a Member with AMFIE implies the unconditional acceptance of this Best Execution Policy.
The Best Execution Policy applies to all transactions in financial instruments transmitted to AMFIE by its members, all of whom are "retail clients" within the meaning of EU Directive 2014/65/EU also known as the MIFID II Directive.
The financial instruments covered by this policy are as follows:
- money market instruments;
- units in collective investment undertakings,
- options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields or other derivative instruments, financial indices or financial measures that can be settled by physical or cash delivery;
- options, futures, swaps, forward rate agreements and any other derivative contracts relating to commodities that must be settled in cash or may be settled in cash at the request of one of the parties (other than in the event of default or other event causing termination);
- options, futures, swaps and any other derivative contracts relating to commodities that can be settled by physical delivery, provided they are traded on a regulated market, MTF or OTF;
- option contracts, futures contracts, forward contracts, forward exchange contracts and any other derivative contracts relating to commodities that can be settled by physical delivery, not otherwise mentioned in point 6 of Section B of Annex II to the law of 5 April 1993 on the financial sector as subsequently amended (“LSF”) and not intended for commercial purposes, which have the characteristics of other derivative financial instruments, taking into account that, in particular, they are cleared and settled through recognised clearing houses or are subject to regular margin calls;
- derivatives used to transfer credit risks;
- financial contracts for differences;
- option contracts, futures contracts, swaps, forward rate agreements and any other derivative contracts relating to climatic variables, freight rates, emission allowances or inflation rates or other official economic statistics that must be settled in cash or can be settled in cash at the request of one of the parties (other than in the event of default or other termination event), as well as any other derivative contracts relating to assets, rights, obligations, indices and measures, not otherwise mentioned in Section B of Annex II to the LSF, which have the characteristics of other derivative financial instruments, taking into account that, in particular, they are traded on a regulated market, an MTF or an OTF, are cleared and settled through recognised clearing houses or are subject to regular margin calls.
In the context of the management of the liquid assets deposited by members with AMFIE, investment decisions are made. AMFIE does not itself execute orders resulting from investment decisions taken in the context of the discretionary management of the assets deposited with the Association. But it ensures that the best interests of the members are served when orders are transmitted for execution. Buy and sell orders are then transmitted to the various custodians used by AMFIE for execution. A non-exhaustive list of these custodians is given below:
- Banque de Luxembourg
- Banque Internationale à Luxembourg S.A.
- ING Luxembourg
- Natixis Bank
- Société Générale Bank & Trust
All the custodians used by AMFIE have their registered office located in Luxembourg and are fully regulated by the Luxembourg supervisory authority (CSSF, Financial Sector Supervisory Commission).
However, when executing orders AMFIE is required to take all sufficient measures to obtain the best possible result for its members, taking into account the price of the financial instrument, the costs related to execution, the speed, the probability of execution and settlement, the size, the nature of the order, or any consideration relating to the execution of the order.
To this end, AMFIE regularly verifies that the entity executing the orders applies the provisions of Article 37-5 of the LSF or equivalent provisions. AMFIE therefore ensures that the above-mentioned custodians apply best execution policies that comply with the legal and regulatory requirements in force.
These policies are also available on the respective websites of these entities, and may also be provided upon request to AMFIE's Secretariat.
AMFIE establishes and publishes annually on its website, for each category of financial instruments, a list of the entities responsible for executing the above-mentioned orders, in particular in terms of trading volume.
AMFIE also publishes on its website an assessment of the quality of execution obtained on each of the platforms it uses and the conclusions it draws from the detailed monitoring of the quality of execution obtained on these platforms.
AMFIE offers its members the possibility of investing in various Financial Instruments as referred to in section B of Annex II to the LFS, e.g. shares, bonds and shares of collective investment undertakings.
In order to execute financial instrument purchase/sale orders for its members, AMFIE has entered into a partnership with Keytrade Bank Luxembourg ("Keytrade"), and with Société Moventum SCA ("Moventum"). In the context of these partnerships with Moventum and Keytrade, AMFIE does not execute its own orders from its members but forwards them to these companies for execution.
However, AMFIE is required to act in the best interests of its members when transmitting their orders for execution to the two companies mentioned above.
To this end, AMFIE ensures that Moventum and Keytrade each have a best execution policy for orders that complies with legal and regulatory obligations in force.
a) Moventum SCA
Moventum's best execution policy for orders is applicable to AMFIE's members for the investment product "AMFUND Savings Plan".
This policy, in English only, is available to AMFIE's members and prospective members upon request to AMFIE's Secretariat.
Any order sent to AMFIE as part of the "Savings Plan" implies outright acceptance of this policy and the policy of Moventum SCA.
b) Keytrade Bank Luxembourg SA
Thanks to the partnership with Keytrade Bank Luxembourg , members can manage their investments directly from their accounts. Members may transmit their purchase /sale orders to AMFIE using the means provided for this purpose and AMFIE then undertakes to transmit these orders as soon as possible to Keytrade Bank Luxembourg for execution. In order to be able to benefit from this service, the Member must open a dedicated individual account with Keytrade Bank Luxembourg in accordance with the procedures defined in the relationship entry documents available through AMFIE or on its website.
AMFIE does not execute orders from its members, but must ensure that their best interests are served when transmitting their orders for execution. To this end, AMFIE regularly verifies that the entity executing the orders, Keytrade Bank Luxembourg, applies the provisions of Article 37-5 of the LSF or equivalent provisions. AMFIE therefore ensures that Keytrade Bank Luxembourg has a best execution policy in line with regulatory obligations. Keytrade Bank Luxembourg's best execution policy applies to AMFIE's members for any order on financial instruments ordered by a member under the tripartite agreement he has signed with Keytrade Bank Luxembourg and AMFIE.
This Policy is available on Keytrade Bank Luxembourg's secure website under Preferences, Knowledge & Experience, Step 2. It can also be consulted from the following links:
This policy is also available to AMFIE's members and prospective members upon request to AMFIE's Secretariat.
Any order that is transmitted to AMFIE pursuant to the above-mentioned tripartite agreement implies the Member's outright acceptance of this policy and the policy of Keytrade Bank Luxembourg for the best execution of orders.
AMFIE reviews its Policy regularly, at least annually, and whenever there is a significant change that affects the Association’s ability to continue to achieve the best possible results for its members. AMFIE reserves the right to amend its Policy at any time it deems appropriate. Any significant change in the Policy shall be notified to the Member.
The fact that the Member sends AMFIE an order for a Financial Instrument implies the express and unconditional acceptance of AMFIE's Policy, that of Keytrade Bank Luxembourg, that of Moventum, and that of its custodians, as applicable at the time the order is placed.