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This Policy sets out the general position and covers all services we provide. A new policy comes into effect on January 3rd 2018, please click here to see this policy.
a) Where we provide the service of discretionary portfolio management we will act as ‘portfolio manager’. In all other instances of service we will act as “receiver and transmitter” of orders and where possible, give effect to your instructions as soon as is reasonably possible after we have received your instructions but will not be responsible for any delay or loss of investment return which is beyond our control. In both cases we will usually pass instructions for trades to a third party to execute, as opposed to executing trades ourselves
b) We must ensure that we achieve best execution when executing trades on your behalf which means that we or any third party we instruct obtains the ‘best possible result’.
c) The requirements of best execution apply to equities and bonds. All transactions will be effected in accordance with the rules and regulations of the relevant market or exchange. We may take all such steps as may be required or permitted by such rules and regulations and/or by appropriate market practice on such terms as we see fit.
d) Execution Factors
For retail clients, the following factors take priority:
i. Total consideration of the deal, taking into account:
a. the price offered; and
b. costs, commissions or other charges to be charged by brokers of the regulated market.
The following execution factors may be taken into consideration, the:
ii. speed and likelihood of successful execution;
iii. size and nature of the order;
iv. current liquidity for the relevant instrument;
v. ability of the venues or brokers to manage execution in relation to the size and nature of the order;
vi. speed and efficiency of the settlement process post execution; and
vii. impact on the relevant market and choice of available venues for the particular order.
The success of obtaining the ‘best possible result’ will be assessed at the time of execution and is dependent upon:
viii. review of the order execution policy regularly; and
ix. variability of execution factors.
e) Monitoring order execution
We or any third party we use will monitor the execution of their trades using a number of third party transaction cost analysis systems and will monitor the order execution on a consistent basis over a series of trades to ensure that as far as possible the best possible result is being consistently achieved.
f) Material difficulty
We or any third party we use may experience material difficulty in executing certain transactions from time to time. These difficulties will be managed so as to seek to obtain the best possible result for our clients under the circumstances.
g) Limited Orders
No limit orders will be accepted.
We may deal through the following venues:
i. regulated markets;
ii. multilateral trading facilities;
iii. market makers and broker dealers who are FCA regulated and/or LSE member firms;
iv. systematic internalisers, which may result in orders being executed outside a regulated market.
i) Selection of venue
Either we or a third party we use will include the following tools/analysis in making selections:
i. indications of interest– sell side broadcasts on price/size;
ii. broker rankings, using best brokers by volume per security/sector;
iii. bid & offer lists received from approved brokers; and
iv. research/recommendations – analyst research from brokers.
j) Order handling policy
In respect of timely execution, we require that orders are arranged to be executed fairly and in due turn, and that:
i. orders will be promptly and accurately recorded and allocated;
ii. comparable orders are executed sequentially unless the prevailing market conditions would disadvantage the execution as a consequence; and
iii. any material difficulties in execution of orders by a third party will be disclosed to us.
k) Aggregation and allocation
We will only permit aggregated orders for our clients where this is unlikely to work to the disadvantage of each retail client concerned, though we recognise that this may on occasions work to the disadvantage of one or more clients.
Records on client orders and trade executions for at least the periods required by FCA.
Markets and brokers will be reviewed on a continuous basis. A list of the most updated markets and brokers used is available on request.