Best Executin & Client Order Executin Plicy Octber 2017 BE31/10/17 v1 P age 1 6
Cntents 1. Backgrund... 3 2. Order placement... 3 3. Order executin factrs... 3 4. Order executin plicy... 3 5. Order executin venues... 4 6. Order executin timescales... 4 7. Client rder handling, aggregatin & allcatin... 5 8. Cancellatin... 6 9. Mnitring and reviewing... 6 10. Cnsent... 6 BE31/10/17 v1 P a g e 2 6
1. Backgrund This dcument shuld be read alngside ur Praemium Custdy and Executin Terms & Cnditins and Key Features Dcument ( Terms ), which shuld be supplied frm yur Financial Adviser. Best Executin refers t the respnsibility f Praemium Administratin Limited ( Praemium ) t prvide the mst advantageus rder executin fr ur clients. The purpse f this plicy is t infrm all clients and their advisers abut Praemium s apprach t prviding Best Executin. Please nte: We d nt supprt trading n an executin-nly basis (i.e. withut advice frm yur Adviser). Praemium reserve the right t vary any aspect f this plicy withut ntice. 2. Order placement Due t the nature f ur business, rders are typically generated by investments (new mney r tp-ups), disinvestments (regular r ad-hc withdrawals r the deductin f fees) r an adjustment t the mdel by the discretinary prtfli manager. 3. Order executin factrs There are varius factrs we take int cnsideratin when we place an rder fr yu. These include: Price (nrmally cnsidered the mst imprtant factr); Cst; Speed f executin; Likelihd f executin and settlement; Size f deal; Nature f rder; and Any ther cnsideratins relevant t the executin f the rder. Praemium take int accunt all f the abve factrs t achieve Best Executin; hwever, this may nt always result in btaining the best available price, despite it generally being the primary cnsideratin. Other cnsideratins culd include the liquidity f the market (which may make it difficult t execute an rder), and whether such transactins are executable n a regulated r unregulated market. Praemium reserve the right t act in a deal as agent fr mre than ne client cllectively. 4. Order executin plicy Praemium must cnsider the Best Executin factrs in Sectin 3 when yu place an rder with us fr executin. This Order Executin Plicy has been designed t help yu understand hw we execute yur rders in the market. In the nrmal curse f business, we will rute rders t ur dealing partners which are listed in Sectin 5. We reserve the right t review and amend the dealing partners t ensure that we BE31/10/17 v1 P a g e 3 6
cntinue t achieve Best Executin fr yu. We mnitr all executed rders fr best price pst trade via the use f an external analytics prvider. 5. Order executin venues We aim t achieve cnsistent Best Executin thrugh ur selectin f venues when we execute rders n yur behalf. When trading n the platfrm, we are able t use the fllwing instruments: Exchange traded securities: Equities; Exchange-traded funds (ETFs) & investment trusts; Exchange traded cmmdities; Gvernment bnds; Crprate bnds; Cllective investment schemes; Structured prducts. Dealing in exchange traded securities We have appinted Winterfld Securities Limited as ur dealing partner t execute rders in exchange traded securities; they are authrised and regulated by the Financial Cnduct Authrity (Register Number 141455) and are part f the Clse Brthers Grup. Dealing in pen-ended funds (OEICs, SICAVs, Unit Trusts) We have appinted FNZ UK Limited as ur dealing partner t execute rders in pen-ended funds; they are authrised and regulated by the Financial Cnduct Authrity (Register Number 438687). In exceptinal circumstances the nly methd available fr dealing in pen-ended funds may be t transmit rders directly t the relevant peratr f the fund r its agent fr executin. If the relevant pen-ended fund is listed (fr example because it is used as a vehicle t prvide exchange traded assets r funds), we may execute yur rder in the same way as fr any ther UK rder in exchange-traded securities. By agreeing t the Terms yu will be deemed t have prvided cnsent t the executin f yur rder in pen ended funds being carried ut utside f a regulated market r multilateral trading facility. Dealing in structured prducts Orders placed in structured prducts will be traded directly with the respective issuer. 6. Order executin timescales Thrughut the executin f yur rders, we cannt be held accuntable fr any third-party failures. BE31/10/17 v1 P a g e 4 6
We d nt we yu any fiduciary respnsibilities ver and abve ur regulatry bligatin t prvide yu with Best Executin r as therwise specifically agreed with us. Whilst regulatins require us t take reasnable steps t prvide yu with the best pssible result n a cnsistent basis, we cannt guarantee that we will be able t prvide yu with Best Executin fr every rder where we act n yur behalf. Sale and buy rders with the same settlement date will be placed n the same day where pssible. Please nte: A delay in receiving prceeds f a sale rder may result in a delay t a buy rder. Delays in the settlement f any rders in a mdel prtfli may, therefre, cause delays in ther rders in the mdel. 7. Client rder handling, aggregatin & allcatin Order handling & aggregatin Praemium must execute client rders in a timely manner and execute cmparable client rders prmptly and sequentially, unless the characteristics f the rder r prevailing market cnditins make this impssible r the interests f the client dictate therwise. Praemium are nt required t treat client rders sequentially if the rders are received via different frmats and it wuld nt be practicable t d s. When apprpriate, Praemium may aggregate buy r sell rders in the same asset fr executin. If yur rder is t be aggregated with ther client rders, the effect f aggregatin may wrk t yur disadvantage in relatin t a particular rder. Praemium will nly aggregate rders if it reasnably believes that ding s wuld be f benefit t all clients when taking int due cnsideratin the range f factrs related t Best Executin. Praemium will nly trade as yur agent, nt as principal. Fair allcatin Praemium will allcate all rders fairly, and will nt give preference t ne client ver anther. Dilutin levy r exit charge Aggregatin f rders can lead t a large transactin in a particular asset. Such aggregatin therefre runs the risk f a fund manager applying a dilutin levy t the transactin. A dilutin levy is an extra charge levied by fund managers t ffset any significant mvement in the price f a fund that may be generated by a large rder. Any such levies are nt under the cntrl f Praemium and are nrmally expressed as a percentage f the value f the deal. If a dilutin levy is applied t an aggregated rder, the levy is apprtined t the individual rders making up the aggregated rder in prprtin t the units bught r sld n that rder. Exit charges may be applied n rders by fund managers when a sell transactin is executed. They are nrmally set in advance as described in the terms and cnditins f a fund. We wuld advise yu t check yur fund literature carefully befre purchase fr any exit charges yu may be liable fr when yu sell. BE31/10/17 v1 P a g e 5 6
Limit rders Praemium d nt supprt the request f limit rders as client rders will be aggregated. 8. Cancellatin We reserve the right t cancel an rder withut ntice where we believe there is sufficient justificatin. This may include, but is nt limited t, circumstances where we are requested t d s by ur cunterparty r the relevant exchange, r where we believe there may be ptential market abuse. We will nt be liable fr any lss yu incur as a result f the cancellatin f an rder in such circumstances. If multiple rders are prcessed we will apply charges separately t each deal. 9. Mnitring and reviewing We will review the effectiveness f ur Best Executin Plicy, either at least annually r if a material change ccurs, and may change it if it is in ur clients best interests t d s. We will ntify yu f any changes that are relevant t yu. Changes will cme int effect the next time that yu trade using the platfrm. If yu wish t discuss the cntents f this plicy r have any further questins, please call ur client services team n 44 (0)203 873 5566. 10. Cnsent We are required t btain yur prir cnsent t this Plicy when we execute an rder n yur behalf. Yu will be deemed t have prvided such cnsent when yu instruct us t act n yur behalf in relatin t an rder. In rder fr us t achieve best executin fr yur rders when we execute them n yur behalf, we may smetimes seek t place yur rders with an executin venue ther than a regulated market such as ver the cunter directly with the institutin. T enable us t place these rders n yur behalf we are required t btain yur prir cnsent befre we execute the rder. By signing the client applicatin frm and agreeing t ur Terms and Cnditins, yu will be deemed t have prvided such prir cnsent. Cpyright Ntice This dcument is the prperty f Praemium Administratin Limited authrised and regulated by the Financial Cnduct Authrity N. 463566 and cannt be cpied, mdified, r stred n a cmputer system withut the cmpany s cnsent. Fr further infrmatin please call client services team n 44 (0)203 873 5566. Telephne calls may be recrded fr training and security purpses. BE31/10/17 v1 P a g e 6 6