Market timing

Our stance

We have an obligation to protect the interests of all our customers against the adverse effects of market timing.

We will therefore not knowingly allow investment transactions within our funds which are associated with market timing practices. We also reserve the right to restrict or refuse investment transactions for customers where we consider the transactions may be related to market timing.


We consider market timing and short-term trading as similar activities, both of which are designed to give the investor returns at the expense of the other investors in the fund.

In general, market timing refers to the investment behaviour of an investor or a group of investors buying, selling or switching shares on the basis of predetermined market indicators. The activity is designed to exploit market inefficiencies when the price of the fund, which is determined at a specific time of the day, does not reflect the current or expected market value of the underlying securities held by the fund. This may be characterised by short-term ‘in and out’ trading. Market timers also include investors or groups of investors whose transactions seem to follow a timing pattern or are characterised by frequent or large exchanges.

For the purposes of ascertaining whether transactions may relate to market timing practices, we may combine transactions where the policies involved are under common ownership or control.

Common ownership or control of policies includes without limitation, legal or beneficial ownership of the policy and where a financial adviser has authority to give dealing instructions on behalf of their customers.