Order Execution Policy

Purpose

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

When executing investment transactions WLLP is required to take all reasonable steps to obtain the best possible result for Clients. WLLP is also required to provide appropriate information to Clients on WLLP’s MiFID Order Execution Policy.

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.

Placing orders on a Client’s behalf

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.

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 reasonable 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 and taking into account the execution criteria.

Execution factors

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

Ordinarily, price will merit a high relative importance in obtaining the best possible result. For certain orders, for certain Clients, under certain circumstances, for certain markets or for certain financial instruments, WLLP may appropriately determine that other execution factors weigh more heavily than price in obtaining the best possible overall result.

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.

Placing an order

The list of brokers and market makers WLLP use for each class of financial instruments is attached to this document. This list comprises those third party entities with whom WLLP has entered into an agreement for handling orders and on whom is placed significant reliance. WLLP reserve 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, though 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 do not structure or charge commissions in a way that unfairly discriminates between any third party entity.

WLLP may deal outside a Regulated Market or Multilateral Trading Facility.

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 execution factors prevailing at the time. However, price will always be the predominant factor.

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.

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 and this will be posted on the website along with any change, from time to time, in the list of selected brokers and market makers. The Client will not be notified separately of minor changes. Please refer to the website for the current arrangements and Policy from time to time.

 

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