BEST EXECUTION POLICY
We provide discretionary management services. In the course of providing these services we undertake transactions in investments for clients. It is in the interests of our clients and our firm that we obtain the best possible result when placing orders for execution on behalf of our clients, with third parties, such as platforms, fund managers or stockbrokers. We are required to take all sufficient steps to provide best execution when carrying out such transactions and, on your request, to provide you with a copy of this policy that we have adopted to achieve that objective. This Best Execution Policy applies to orders in investments such as funds and other securities. You should read this policy in conjunction with your Discretionary Management Agreement.
Execution Venues And Third Parties
An execution venue is effectively a trading venue such as a regulated stock market where investment transactions are executed. Our firm does not execute orders or deal directly with execution venues. Instead, we place orders on behalf of our clients with appropriate third parties as explained below:
Our discretionary managed portfolios are held and managed on a platform, and client orders will be placed directly with the relevant platform. Our main platform is 7IM, and their Best Execution Policy can be found on their website. We also use Standard Life Wrap and their Order Execution Policy can be found on their website and we also use Transact and their Best Execution Policy can be found on their website.
Off Platform Investments
Off Platform investments are held directly with individual fund managers or Product Providers, and client orders will be placed directly with the relevant fund manager or Product Provider.
We will regularly assess the third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging the execution of your orders. The above list will then be updated, where necessary, following such assessment.
The third parties have responsibilities in relation to best execution and client order handling themselves. We will also undertake periodic monitoring to ensure that they’re meeting the relevant requirements.
When transmitting orders to a third party, we’ll make every effort to ensure the best possible result for our clients taking into account the following factors:
- Likelihood of execution and settlement
- Nature of the order
- Any other considerations relevant to the execution of the order
For retail clients, the price and cost of execution of the order will normally be the most important aspect in obtaining the best possible result. We will therefore assume this is the most important outcome for your transaction unless you tell us otherwise.
Client Specific Instructions
If you have given instructions that price is not the most important factor in executing your instructions, we will make every effort to comply with your instructions but cannot guarantee this. This may be due to either the nature of the order, or the type of investment you wish to trade in. We will make all decisions as to where the orders are placed and we will not accept specific instructions from clients regarding which third parties to use.
It is our policy that commission and charging structures will not influence either the selection of the third parties to which we place client orders, or the order flow that follows as a result of the execution process. We will therefore not discriminate between the third parties used to arrange execution of your orders.
Monitoring And Review Of Our Best Execution Policy
We will regularly monitor the effectiveness of our Best Execution Policy to identify and, where appropriate, correct any deficiencies. In particular, this will cover the third parties to which we transmit client orders in terms of their quality of execution. This review will be carried out regularly (on at least an annual basis) or whenever a material change occurs that affects our ability to continue to obtain the best possible result for our clients.