Order Execution Policy

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Order Execution Policy

Part 1: top five entities used for the transmission or placing of client orders

Where we send investment applications or orders on your behalf to third parties (for example, to buy or sell investment holdings), we make every effort to ensure the best possible result for our clients. This is referred to as best execution. We may transmit or place the order via a third party platform (an online investment administration service), directly with a fund manager or with a stockbroker, to execute your order.

We’re obliged to disclose on an annual basis the top five firms that we send our client orders to. The tables below relate to the period 1st January to 31st December 2018.


Class of investment Other investments
(includes collective investments)
Notification if
< 1 average trade
per business day in
the previous year

Top 5 investment firms
ranked in
terms of volume
(descending order)
Proportion of volume
as a percentage of
total in that class

Proportion of volume
as a percentage of
total in that class




Aviva Investors
UK Fund Services



Schroder Unit
Trust Managers

8.16%  2.59%
Henderson Global
Investors Ltd

7.74% 8.05%
Invesco Fund
Managers Limited
 6.63%  2.08%


• All business in the period disclosed was for investors classed as “Retail Clients” within the FCA client categorisation rules.

• During the 2018 calendar year, we gained permissions for Discretionary Investment Management. The range of collective investments (or mutual funds) within our Model Portfolios are categorised within “Other Investments”. The percentages transmitted via third-party platforms to the top 5 Investment Manager entities are disclosed within the above table.

Part 2: monitoring and review

• We operate in accordance with our best execution policy. Please ask, if you want to see a copy of our policy.

• Under the terms of our policy, we 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 for the execution of your orders.

• The third parties that we use, also have responsibilities in relation to best execution and client order handling. We undertake periodic monitoring to make sure that they continue to meet our requirements. This review is carried out at least annually or whenever a significant change occurs that we feel could affect our ability to continue to obtain the best possible results for our clients.

• Collective investments are typically traded within an aggregated dealing process, meaning your order will be grouped together with similar orders from clients for the same collective fund and executed as a single transaction at the correct price, within a reasonable timeframe, subject to the fixed valuation points for collective investments. More information on the best execution policies of the third parties we use is available on request.