Order Execution Policy

1. Purpose

The purpose of this document is to provide Clients with information on Whitefoord LLP’s (WLLP’s) Order Execution Policy.

2. The Scope

The Order Execution Policy for WLLP applies to Clients and financial instruments where WLLP provides discretionary management or receives investment orders from Clients. The instruments covered and used by WLLP may include equities, fixed interest securities, exchange traded funds, collective investments, structured products, options, futures, swaps, forwards and other derivative contracts.

3. Placing orders on a Client’s behalf

WLLP will take all sufficient steps to obtain the best possible result for Clients when executing investment transactions.

When placing orders ‘on a Client’s behalf’ WLLP will protect the Clients’ interests in relation to the pricing or other aspects of the transaction that may be affected by how and where the order is placed by WLLP. This will be the case where WLLP places orders when dealing as the agent.

4. Obtaining the best possible result

Subject to any special instructions that may be given by Clients when placing orders for execution, WLLP will take all sufficient steps to obtain the best possible result, in terms of total consideration, by taking into account the execution factors.

The relative importance of the execution factors will be determined by WLLP using commercial judgement and experience in the light of market information available.

5. Execution factors

The execution factors that will be taken into account will include price, costs, speed, likelihood of execution and settlement, size, nature, or any other consideration relevant to the placement of the order.

Ordinarily, price of the instrument and cost related to execution will merit a high relative importance in obtaining the best possible result.  In some situations WLLP may determine that other execution factors weigh more heavily than price and cost of execution in obtaining the best possible overall result.

6. Execution criteria

The execution criteria that will be taken into account are the combined characteristics of the Client, the order to be placed, the financial instruments that are the subject of that order, and the third party entities, brokers and market makers, to which the placement of that order can be directed.

7. Placing an order

The list of brokers and market makers WLLP use for each class of financial instruments is at the end of this document. This list comprises those third party entities with which WLLP relies on and has to handle orders WLLP believe these execution venues enable us to obtain, on a consistent basis, the best possible result for the execution of client orders. WLLP reserves the right to add to or remove any of the brokers or market makers on the list at any time.

This list is regularly assessed, for all financial instruments WLLP trade, to identify those that will assist on a consistent basis in obtaining the best possible result when placing orders on behalf of Clients. The list will be updated where necessary, from time to time, however, WLLP will not notify the Client separately of such changes. A current list will always be available on request or via the website at www.whitefoord.co.uk.

WLLP does not structure or charge commissions in a way that unfairly discriminates between any third party entity.

Signing the Client Agreement means the Client accepts the WLLP Execution Policy.

8. Selecting a broker or market maker

Subject to any specific instructions that may be provided by a Client, WLLP will always select the broker or market maker WLLP considers to be the most appropriate given the execution criteria and factors prevailing at the time.  WLLP may execute transactions outside a Regulated Market such as on a multilateral or organised trading facility, where WLLP believes that doing so will achieve the best possible result for the client.

9. Top five execution venues

WLLP will provide information on the top five execution venues in terms of trading volumes by asset class, where WLLP has executed client orders in the preceding year. This applies to all instruments in scope of MiFID II. This information will be published on the WLLP website on an annual basis from 2018.

10. Specific Client instructions

Subject to any specific instructions that may be provided by a Client, WLLP may transmit an order received to one of the selected brokers for execution. In doing so, WLLP will always act in each Client’s best interests and also comply with sections 4 and 5 above.

The Client needs to be aware that the execution of specific instructions may limit or prevent WLLP from implementing the steps referred to in the Order Execution Policy to obtain the best possible result for Clients in respect of the elements covered by those instructions.

Whenever there is a specific instruction from the client, WLLP will execute the order following the specific instruction.

11. Publication of Unexecuted Limit Orders

Unexecuted client limit orders must be made public unless the Client expressly instructs otherwise. By agreeing to this Policy the Client expressly instructs us not to make unexecuted limit orders public.

12. Order aggregation and allocation procedure 

WLLP has an Order Aggregation and Allocation procedure and arrangements in place to provide for the prompt and fair execution of client orders.  In the interests of achieving best execution, we may only aggregate a client’s order with those of one or more other clients, if it is unlikely that the aggregation will be to the disadvantage of any of the clients concerned.  But, the effect of aggregation may operate on some occasions to the disadvantage of the clients concerned.

12. Monitoring and review

WLLP will monitor compliance with the Order Execution Policy annually, and regularly review the arrangements, effectiveness and accuracy.

The Client will be notified of any material change to WLLP’s execution arrangements and the Order Execution Policy.