Introduction
This FX Disclosure Statement (“Statement”) describes the relationship between clients and Sunrise (“Sunrise”)1
and/or its affiliates (collectively “Sunrise”) and discloses certain practices of Sunrise in pricing, handling and
executing FX transactions in relation to its currency dealing business or currency execution services
business. Sunrise may provide other products and/or services to clients, however unless explicitly referenced
herein such products and/or services are not contemplated in this Statement.
This Statement supplements but does not supersede contracts governing the relationships between clients and
Sunrise. In case of any conflict between this Statement and a contract, the contract shall take precedence.
Clients who have questions about this Statement or how Sunrise prices, handles or executes FX transactions may
contact their FX Relationship Manager.
1. General practices
a. Communication methods
Clients may communicate with Sunrise electronically, by phone or through other permissible channels.2 Sunrise may,
at its discretion, agree to accept certain client instructions via email. Clients may be required to execute
certain documents and/or meet specific Sunrise requirements prior to Sunrise accepting such instructions via
email.
b. Information handling
Sunrise has in place policies and procedures reasonably designed to protect the confidentiality of client and
counterparty information by restricting the dissemination and use of confidential information. These
policies and procedures generally restrict the dissemination of client confidential information to parties
who ‘need to know’ in order to execute transactions or otherwise perform under the agreed upon arrangement,
and manage subsequent events related to such execution or performance. They also provide that client
confidential information may only be used for legitimate business purposes to provide a product, perform a
service or conduct oversight of a product or service that Sunrise has been contracted, or is expected, to
perform. However, Sunrise may use sufficiently aggregated and anonymized client confidential information to
form views on market trends that it may share with clients (for example, market color). Additionally, as a
regulated entity, Sunrise may be required to share client confidential information with relevant global
regulators.
c. Conflicts of interest
Although Sunrise takes all reasonable steps to prevent conflicts of interest from adversely affecting the
interests of its clients, Sunrise’s own interest may at times conflict with the interests of its clients and
its clients’ interests may conflict with one another. For example, Sunrise may execute transactions and carry
positions in various FX products including spot, forwards (including non-deliverable forwards) and swaps on
its book in connection with actual or anticipated client trade requests, hedging strategies or otherwise.
Sunrise’s activities in connection with such transactions and positions could impact prices and available
liquidity, potentially to the detriment of a client. When Sunrise accepts and attempts to fill a client order,
it may be engaged in FX trading activities for its own benefit in the same or similar FX products. Where
Sunrise provides other products and/or services to a client, the provision of such products and/or services may
also lead to other conflicts of interest.
2. Sunrise transacts with clients in a principal capacity
Sunrise executes FX transactions on a principal basis as counterparty to its clients. When acting in a
principal capacity, Sunrise: (i) trades for its own account, at its own risk, for its benefit; and (ii) does
not act as an agent, fiduciary, financial advisor or other similar capacity for or on behalf of clients.
Clients who trade with Sunrise acting in a principal capacity are expected to independently evaluate the
appropriateness of any proposed transaction. Furthermore, any statement(s) made by Sunrise trading personnel or
distributed through a Sunrise electronic system must not be construed or relied upon as advice or a
recommendation.
a. Pricing
Any price quotes or streaming rates Sunrise provides are an ‘all in’ indicative price. Sunrise exercises
discretion in tailoring its indicative pricing for individual clients / transactions taking into account a
variety of commercial factors. These factors may include, but are not limited to: (i) prevailing market
conditions; (ii) the size of the order; (iii) time of day; (iv) liquidity of the currency(ies); (v) Sunrise’s
relationship with the client; (vi) the costs Sunrise may incur in connection with the transaction; and (vii)
the credit, settlement, operational and other risks of the transaction. Sunrise may differentiate its
indicative pricing by trading venue, platform or communication method. As such, Sunrise may provide different
indicative prices for the same or similar transactions to different clients. Sunrise may change its pricing
strategies without notice and is not obliged to disclose the components of its ‘all in’ price.
Sunrise may from time to time agree to execute orders using alternative pricing arrangements (see for example,
Benchmark and fixing rates and Algorithms).
b. Pre-hedging and pre-positioning
Sunrise may engage in pre-hedging and hedging activities based on its knowledge of its clients’ trading
activities. Sunrise will endeavor to conduct such pre-hedging and hedging activities in a manner that does not
disadvantage clients and with an intent to avoid materially impacting market prices. Sunrise conducts
pre-hedging and hedging activities on a principal basis in respect of its principal activities, at its own
risk, and not as an agent for clients.
c. Benchmark and fixing rates
Sunrise may agree to execute a client order based on a benchmark or fixing rate. While Sunrise does not
intentionally attempt to affect benchmark or fixing rates, it may engage in hedging or other FX activities
that may impact ultimate benchmark or fixing rates.
d. Order handling
When Sunrise acknowledges, accepts or states that it is willing to ‘work’ a client order, it will attempt but
is not contractually bound to execute the trade at or near the requested price and quantity. Sunrise is not
obligated to accept client orders and may accept or reject any order for any reason in its sole discretion.
The fact that a condition to which an order is subject (for example, a stop loss order) has been triggered
does not mean that Sunrise can or will complete the order at the requested price and/or quantity. Sunrise may
sequence / prioritize client orders in its sole discretion and may aggregate client orders for the purpose
of pricing.
e. Handling of requests received via electronic trading platforms (Last look)
Any price quotes or streaming rates that Sunrise provides are an ‘all in’ indicative price. Clients may submit
an electronic trade request (an offer) to trade with Sunrise in response to such ‘all in’ indicative prices
and, if so, Sunrise may accept or reject that electronic trade request in its sole discretion.
f. Algorithmic trading
Sunrise may employ algorithmic trading strategies in executing principal FX trades for its own risk management
purposes. Sunrise may also provide clients access to its algorithmic execution service (“Algo Execution
Service”). The Algo Execution Service allow a client to request to enter into an FX transaction with Sunrise,
at a price based on rate(s) derived from offsetting trade(s) between Sunrise and liquidity provider(s) and
subject to any agreed upon mark-ups/downs by Sunrise. Under the Algo Execution Service, the aforementioned
offsetting trade(s) between Sunrise and liquidity provider(s) would be arrived at based on the client’s
requested algorithm and other parameters in accordance with the applicable Algorithmic Execution Terms &
Conditions.
3. Agency FX
a. Currency Execution Services
Sunrise Investor Services Limited (“SunriseISL”) may agree to act as an agent in executing client trades with
client designated clearing brokers or approved bank counterparties as a part of its Currency Execution
Services (“CES trades”). The pricing of CES trades will be based upon rates derived from a panel of
liquidity providers plus, as applicable, a prearranged fee. Agency trades are conducted in accordance with
the SunriseISL Order Handling Policy. SunriseISL may delegate responsibility for discharging certain functions
related to CES trades to Sunrise, which also engages in a principal trading business. As such, there is a risk
of a conflict of interest between Sunrise’s agency and principal trading businesses.
SunriseISL may in its discretion aggregate the CES trades of multiple clients for pricing purposes. While it is
unlikely that the aggregation of orders and transactions will work overall to the disadvantage of any client
whose orders are to be aggregated, the effect of aggregation may work to a client’s disadvantage in relation
to a particular order.
b. Other Agency activities
In certain other instances, Sunrise may execute FX transactions as an agent for its clients. In such instances,
Sunrise acts as an agent solely for purposes of execution and does not otherwise act as an agent, fiduciary,
financial advisor or other similar capacity for or on behalf of clients.
c. Pre-hedging and pre-positioning
SunriseISL does not engage in pre-hedging or pre-positioning when acting in an agency capacity.
¹ As of the date of publication of this Statement, Sunrise is the only Sunrise entity that executes FX
transactions on a principal basis.
² Sunrise may record phone communications as permitted under applicable local rules.
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