Best execution policy

Updated: January 2023

Information on the principles of execution for investment funds managed by HANSAINVEST Hanseatische Investment-GmbH (hereinafter referred to as “HANSAINVEST”) in accordance with section 2 (4) Kapitalanlage-Verhaltens- und Organisationsverordnung (German Regulation on the Rules of Conduct and Organisational Rules Pursuant to the Investment Code, hereinafter referred to as KAVerOV) in connection with Article 27 of the Delegated Regulation (EU) no. 231/2013 (hereinafter referred to as Level 2 Regulation) in connection with section 168 (7) Kapitalanlagegesetzbuch (German Capital Investment Code, hereinafter referred to as KAGB)


As an asset management company, HANSAINVEST is obliged under Article 27 of the Level 2 Regulation in connection with section 168 (7) KAGB to provide investors with appropriate information on the principles of execution and major changes to these principles. The following order execution principles describe how HANSAINVEST ensures that orders for the acquisition and sale of assets are executed consistently in the best interests of the investment fund or the investor. Procedures and measures have been put in place to ensure care and honesty, lawful and professional conduct and compliance with market standards.


These principles apply for executing orders issued for investment funds of HANSAINVEST for the purpose of acquiring or disposing of securities or other financial instruments. These include securities, derivative and foreign exchange transactions. If the execution of trading transactions is carried out by our contractual partners, they are also contractually obliged to observe the execution principles of HANSAINVEST.


Trading transactions may regularly be executed via different execution channels or at different execution venues, e.g. on stock exchanges or at other trading venues, in Germany or abroad, in floor trading or electronic trading. The execution channels and potential execution venues for the relevant types of financial instruments are described below. As a general rule, these can be expected to consistently provide the best-possible execution in the interest of the investment fund.

When choosing specific execution venues, HANSAINVEST assumes that the best-possible result for the investment fund is to be achieved, taking account of the price, costs, speed, probability of execution and settlement and the scope and nature of the order.

HANSAINVEST will also consider other relevant criteria (e.g. market conditions, security of settlement, etc.) within the scope of these benchmarks.

Forwarding orders

Trading decisions made by the portfolio manager are not immediately sent to the stock exchange and executed. Instead, they are usually executed through intermediaries (brokers, banks etc.) on regulated markets, exchange-like trading systems or systematic internalisers. The customer’s order is then processed in accordance with the intermediary’s arrangements to ensure optimal execution. This may result in additional costs.

However, this does not apply for the acquisition or disposal of real estate or alternative assets for which there is no choice of execution venue.

The brokers and counterparties we engage also include companies in our Group.

Combining orders

HANSAINVEST combines orders only if doing so is not expected to put each of the relevant customers at a disadvantage.

HANSAINVEST principles for optimal execution of securities orders

The following criteria are taken into account to ensure the optimal execution of securities orders. The factors are essentially weighted on the basis of the order below, with the first criterion weighted highest.


The price refers to the actual price to be obtained if the transaction is concluded immediately.


Costs are defined as all expenditure incurred in connection with the investment fund that is directly related to executing the order, including execution venue fees, clearing and settlement fees, in particular the costs of a change of location and all other fees at the time of concluding the transaction that are paid to third parties involved in executing the order.

Characteristics of the instrument, order or market:

Depending on the structure of the instrument, order or market, there may be differences in the probability, quality and speed of execution.

Execution speed:

Execution speed refers to the period of time between receiving an executable order and allocating the order.

Probability of execution:

Probability of execution gives an indication of whether a customer order is expected to be executed and, if so, at what pro rata quantity.

Market access and liquidity:

Available liquidity may differ significantly depending on the market. The more liquidity is available, the more likely it is that a customer order will be executed.


The probability of settlement criterion refers to the quality of the settlement. This includes proper delivery of the securities and the settlement of the payment and capital measures.

HANSAINVEST states that the best-possible price should be obtained for an investment fund, taking account of all costs associated with the execution transaction. As securities are generally subject to price fluctuations and so it cannot be ruled out that prices will develop to the detriment of the investment fund over time after the order is placed, intermediaries are considered primarily where full execution is probable and can be carried out promptly.

Orders are issued only to intermediaries on HANSAINVEST’s valid list of counterparties. An excerpt from the counterparty list is the broker list, which lists the intermediaries that best meet the requirements of HANSAINVEST. The composition of the counterparty list and the broker list is updated at least once a year as part of a regular adjustment.

If several intermediaries offer equally good execution quality, the portfolio manager selects an intermediary at his or her discretion.

HANSAINVEST recognises stock exchanges that are admitted for trading in a member state of the EU or in another contracting state to the Agreement on the European Economic Area as execution venues. Stock exchanges on the list of stock exchanges and other organised markets authorised by the Bundesanstalt für Finanzdienstleistungsaufsicht in accordance with section 193 (1) no. 2 and no. 4 KAGB are also permitted. OTC transactions in the interests of the investment fund are possible regardless.

Different execution in individual cases

If exceptional market conditions or a market disruption require a different execution, the order in question will be executed in the interests of the investment fund. As a result, there may be temporary changes in the weighting of the above criteria.

Outsourcing portfolio management

HANSAINVEST outsources portfolio management for the security special funds it manages to external fund managers in accordance with section 36 KAGB. The fund managers are contractually obliged to observe all best execution obligations arising from section 168 (7) KAGB in connection with Article 27 and Article 28 of the Level 2.

Informing customers and regular reviews

HANSAINVEST undertakes to review and, where necessary, update these principles of execution regularly and at least once a year. A review is also carried out when there is a material change in the market environment that could make it more difficult to achieve optimal results under these principles of execution. HANSAINVEST will inform investors of the changes in the principles of execution by reporting this on HANSAINVEST’s website.

Should last-minute events necessitate an ad-hoc review of individual criteria or intermediaries, this is carried out as part of the regular meetings or as agreed between meetings.