Introduction

This FX Disclosure Statement ("Statement") outlines the relationship between clients and Sauder Global Investment ("SGI")¹ and/or its affiliates (collectively referred to as "SGI") and discloses certain practices of SGI related to pricing, handling, and executing FX transactions in the currency dealing business or currency execution services business. While SGI may offer other products and/or services to clients, this Statement only pertains to the topics mentioned herein.

This Statement serves as a supplementary document to the contracts governing the relationships between clients and SGI. In case of any conflict between this Statement and a contract, the contract's terms shall prevail.

Clients with inquiries about this Statement or SGI's pricing, handling, or execution of FX transactions may contact their FX Relationship Manager.

1. General practices
    a. Communication methods

Clients have the option to communicate with SGI through electronic means, phone, or other permitted channels.² SGI may, at its discretion, agree to accept specific client instructions via email. However, clients might be required to fulfill certain requirements and/or execute specific documents before SGI accepts such instructions through email.

    b. Information handling

SGI has implemented policies and procedures to safeguard the confidentiality of client and counterparty information. These measures restrict the dissemination and use of confidential information to relevant parties who require access for executing transactions or fulfilling agreed-upon arrangements. They also specify that client confidential information should only be used for legitimate business purposes, such as providing products or services or overseeing contracted products or services. However, SGI may use sufficiently aggregated and anonymized client confidential information to form market trend views, which might be shared with clients (e.g., market color). As a regulated entity, SGI may also be obligated to share client confidential information with relevant global regulators.

    c. Conflicts of interest

SGI takes reasonable precautions to mitigate conflicts of interest from adversely affecting its clients' interests. However, there may be instances where SGI's own interests conflict with those of its clients, and conflicts may arise among its clients. For example, SGI may execute transactions and hold positions in various FX products, including spot, forwards (including non-deliverable forwards), and swaps, based on client trade requests, hedging strategies, or other reasons. SGI's involvement in such transactions and positions could impact prices and available liquidity, potentially affecting clients negatively. When SGI accepts and endeavors to fill a client order, it may be engaged in FX trading activities for its own benefit in the same or similar FX products. Providing other products and/or services to a client might also lead to additional conflicts of interest.

2. SGI transacts with clients in a principal capacity

SGI acts as the counterparty to its clients in FX transactions on a principal basis. When operating as a principal, SGI (i) trades for its own benefit and assumes the associated risks, and (ii) does not act as an agent, fiduciary, financial advisor, or similar capacity for its clients. Clients engaging in transactions with SGI acting as a principal are responsible for independently assessing the suitability of the proposed transaction. Additionally, any statements made by SGI trading personnel or distributed through SGI electronic systems should not be considered as advice or recommendations.

    a. Pricing

SGI provides "all in" indicative price quotes or streaming rates, which are subject to SGI's discretion and may be tailored based on various commercial factors. These factors include, but are not limited to, prevailing market conditions, order size, time of day, currency liquidity, the client's relationship with SGI, transaction costs, and associated risks. Different clients may receive different indicative prices for similar transactions based on trading venue, platform, or communication method. SGI reserves the right to change its pricing strategies without notice and is not obligated to disclose the components of its "all in" price.

SGI may occasionally agree to execute orders using alternative pricing arrangements (e.g., Benchmark and fixing rates and Algorithms).

    b. Pre-hedging and pre-positioning

SGI may engage in pre-hedging and hedging activities based on its understanding of its clients' trading activities. These activities are carried out on a principal basis, at SGI's own risk, and not as an agent for clients. SGI endeavors to conduct such activities in a manner that does not disadvantage clients and aims to avoid significant impact on market prices.

    c. Benchmark and fixing rates

SGI may execute a client order based on a benchmark or fixing rate. While SGI does not intentionally attempt to influence these rates, its hedging or other FX activities might indirectly impact the ultimate benchmark or fixing rates.

    d. Order handling

When SGI acknowledges, accepts, or indicates willingness to "work" a client order, it will make an effort, though not contractually bound, to execute the trade close to the requested price and quantity. SGI is not obliged to accept client orders and reserves the right to accept or reject any order at its sole discretion. The occurrence of a condition (e.g., a stop loss order) does not guarantee that SGI will complete the order at the specified price and/or quantity. SGI may sequence or prioritize client orders at its discretion and can aggregate client orders for pricing purposes.

    e. Handling of requests received via electronic trading platforms (Last look)

SGI provides "all in" indicative price quotes or streaming rates. Clients may submit an electronic trade request based on these indicative prices, and SGI reserves the right to accept or reject the electronic trade request at its sole discretion.

    f. Algorithmic trading

SGI may use algorithmic trading strategies for its own risk management purposes in executing principal FX trades. SGI may also offer clients access to its algorithmic execution service ("Algo Execution Service"). The Algo Execution Service enables clients to request FX transactions with SGI at a price based on rate(s) derived from offsetting trades between SGI and liquidity provider(s) and subject to any agreed-upon mark-ups/downs by SGI. The offsetting trades between SGI and liquidity provider(s) are determined based on the client's requested algorithm and other specified parameters following the applicable Algorithmic Execution Terms & Conditions.

3. Agency FX

    a. Currency Execution Services

Sauder Global Investor Services Limited (“SGIISL”) may act as an agent to execute client trades with client designated clearing brokers or approved bank counterparties under its Currency Execution Services (“CES trades”). The pricing of CES trades will be based on rates derived from a panel of liquidity providers, along with any applicable prearranged fees. These agency trades are conducted in accordance with the SGIISL Order Handling Policy. Certain functions related to CES trades may be delegated by SGIISL to SGI, which also conducts principal trading. Therefore, there exists a potential conflict of interest between SGI's agency and principal trading businesses.

SGIISL may, at its discretion, aggregate the CES trades of multiple clients for pricing purposes. While the aggregation of orders and transactions is unlikely to overall disadvantage any client, it may have an adverse effect on a particular order.

    b. Other Agency activities

In specific instances, SGI may execute FX transactions as an agent for its clients. In such cases, SGI acts solely as an agent for the purpose of execution and does not assume any additional roles such as a fiduciary, financial advisor, or similar capacity on behalf of clients.

    c. Pre-hedging and pre-positioning

When acting in an agency capacity, SGIISL does not engage in pre-hedging or pre-positioning.

¹ As of the publication date of this Statement, SGI is the only SGI entity that conducts principal-based FX transactions.
² SGI may record phone communications as permitted by applicable local rules.