Best Execution Policy
This page sets out our policies when seeking to achieve the best possible result (“best execution”) for clients when we execute trades in financial instruments on clients’ behalf either in the case where clients give us instructions to execute trades or where we have discretionary authority over a client’s portfolio. Please note that we also apply this policy to spot foreign exchange transactions, even though spot foreign exchanged technically is not a financial instrument.
Definitions used in this document:
Multilateral trading Facility
A multilateral system, operated by an investment firm or a market operator, which brings together multiple third-party buying and selling interests in financial instruments - in the system and in accordance with non-discretionary rules - in a way that results in a contract.
Organised Trading Facility
An OTF is a multilateral system which is not a regulated market or a multilateral trading facility and in which multiple third-party buying and selling interests in bonds, structured finance products, emission allowances or derivatives are able to interact in the system in a way that results in a contract in accordance with Title II of the Directive.
Trading Venue (TV)
EU trading venue a Regulated Market, Multilateral Trading Facility or Organised Trading Facility.
Recognised non-EU trading venue trading venues located out-with a European Union member country
1. What is best execution/what are the execution factors?
The overarching objective is that we take all sufficient steps on a best efforts basis to obtain the best possible result for our clients. In order to achieve this we take into account a number of execution factors including:
A. any restrictions that may exist on a client’s account as to where trades can be executed;
B. total consideration to the client of the transaction after all fees and commissions have been taken into account, including:
i. size of the transaction;
ii. speed of execution and settlement;
iii. likelihood of execution;
iv. likelihood of settlement; and
v. any other factor we consider is relevant to the transaction.
In determining the applicability of the factors we consider:
a. Market information
b. The details we hold about the client
c. The nature of the transaction including the specific financial instrument and the markets that the specific financial instruments
The application of these factors is a matter of judgement. In most cases the total consideration to the client will be the determining factor, although not the only one. The remaining factors are not listed in any order of priority. The factors may be interlinked such that for example, in fast-moving markets, particularly for large orders, the way we would seek to achieve best total cost/revenue may involve giving the order to a broker who we believe can execute the entire order in a timely manner even if part of the order could be filled at a more advantageous price from another broker.
2. What are our obligations?
We undertake to take all sufficient steps on a best efforts basis to obtain, when executing orders, the best possible result for our clients. How we assess the “best possible result” is set out under “What is best execution?” above.
3. Execution Venues (Competing Markets)
For some financial instruments there are a range of execution venues where the trade could be executed. If the client instructs us to use a particular venue and we have accepted that instruction the transaction will be executed on the venue of the client’s choice. Unless the client instructs us otherwise, whilst adhering to this policy, we shall have complete discretion as to the choice of venue including trading outside a trading venue if we believe that trading in that way is likely to achieve the overall objective.
Some financial instruments may only be traded on one venue.
4. Execution outside of regulated markets, multilateral trading facilities and organised trading facilities (each a trading venue)
Unless the client instructs us otherwise, where we consider it to be in the client’s best interest, we will allow the brokers to whom we pass execution instructions to trade outside of regulated markets, multilateral trading facilities and organised trading facilities. The brokers will still be bound by their own best execution policies which we will review.
5. How do we execute
We are not a member of any exchange.
We seek to ensure we have deep relationships with high-quality counterparties with the aim of maximising execution quality in terms of total consideration.
In cases when we transmit a client’s order to another broker or dealer the same criteria for selection apply as when we execute a client’s trades ourselves. When passing a trade to a third party for execution we may:
a. Determine the ultimate execution venue ourselves by accessing specific execution venues through such third parties; or
b. Instruct the other broker or dealer accordingly (having already satisfied ourselves that they have arrangements in place to enable us to comply with our Best Execution Policy).
For financial instrument that are traded on an exchange e.g. shares in companies, we pass the order relating to a client’s account to a broker for execution. In the case of a broker in the European Economic Area or Switzerland that broker will have their own best execution policy. In the case of brokers outside the EEA and Switzerland those brokers may or may not be subject to local best execution rules. In all cases the selection of a broker is based upon the execution factors.
For quote driven markets e.g. most bonds, foreign exchange and OTC derivatives the firm that we pass a client’s order to may not be under a best execution obligation as historically in those markets, firms operate as principal rather than as agent. Our selection of broker, in this case, will reflect the fact that the broker is not under his own best execution obligation.
6. Specific client instructions
If a client provides us with a specific dealing instruction which may prevent us from following our Best Execution Policy as we would usually do and we accept that instruction we shall nevertheless be deemed to have complied with the best execution requirement to the extent of that instruction.
7. Order Execution Timing
Usually orders will be executed in a prompt, fair and expeditious manner. Client orders will be carried out sequentially unless the characteristics of the order or prevailing market conditions require otherwise.
Clients will be informed of any difficulty in the prompt execution of orders.
8. Limit orders
If a client gives us an investment instruction at a specified price limit and/or for a specified size (a ‘‘limit order’’), we will endeavour to fulfil that order but will not be responsible for any third party’s failure to observe the limit requirements of the instruction
9. Amendments to this policy
We may amend our Best Execution Policy from time to time. A formal review will take place periodically at a time of our choosing although this may not result in any changes to the policy. When we make a material change to the Policy we will notify clients of the changes before such changes come into force.