Our Policies: Best Execution Policy

Order Execution Policy (formally Best Execution Policy)

Introduction

The EU Markets in Financial Instruments Directive (‘MiFID’) and corresponding rules of the Financial Conduct Authority (‘FCA’) requires that investment firms establish an order execution policy and take all reasonable steps to obtain the best possible results for their clients when executing a Client Oder.

This policy outlines all of the reasonable steps taken by RowanDartington (‘RD’ or ‘we’ or ‘us’) to ensure that ‘best execution’ is achieved – that is obtaining the best possible results for you when undertaking transactions on your behalf.

We will take all reasonable steps, to achieve the best execution of client orders, subject to different factors which are dependent on the financial instrument and the type of market on which the order is executed.

Client Classification

Our Clients are classified as either Retail, Professional or Eligible Counterparty, but regardless of classification we will treat all clients the same for the purposes of achieving best execution, or getting the best possible result for you when carrying out trades. We always aim to achieve best execution on a consistent basis as outlined in this Order Execution Policy.

Execution Factors

When dealing for you we will consider the following:-

  • Your characteristics (including your regulatory client categorisation as mentioned above);
  • The characteristics of the financial instrument concerned and of your order;
  • Where such orders can be carried out (i.e. the ‘execution venues’).

In assessing the most appropriate route to carry out your order we will consider the following criteria:-

  • price of the instrument;
  • overall cost of the transaction;
  • need for timely execution;
  • likelihood of execution;
  • size and nature of the order
  • speed of execution and settlement.

When dealing in a financial instrument on your behalf we will exercise our discretion in assessing the criteria that we need to take into account to achieve best execution. The relative importance of these criteria will be judged on an order-by-order basis, in line with our commercial experience and with reference to market conditions. In executing orders for clients, in the absence of any specific instructions, we generally give precedence to the factors that allow us to deliver the best possible results in terms of value (total cost) to the client.

Execution Venues

For each instrument we execute on behalf of clients it is our policy on an ongoing basis to consider the variety of trading venues or sources of liquidity available from time to time. This enables us to obtain on a consistent basis the best possible result for the execution of transactions. In satisfying this policy, we may consider the use of one or more of the following venue types:

  • Regulated Markets (e.g. London Stock Exchange or overseas equivalent);
  • Multilateral Trading Facilities (e.g. Non-Exchange Financial Trading Venues);
  • Systematic Internalisers (e.g. Market Makers);
  • Third party investment firms and/or affiliates acting as Market Maker or other liquidity providers;
  • Non-EU entities performing similar functions.

We regularly assess the execution venues available and may add or delete venues in accordance with our obligation to provide you with the best possible execution result on a consistent basis. An up to date list of execution venues is attached in Appendix 1.Where we believe that best execution can be achieved on clients’ behalf outside Regulated Markets or Multilateral Trading Facilities it is our policy to do so. By agreeing the Order Execution Policy (formally Best Execution Policy) and our terms and conditions, you are giving your express consent to this requirement.In certain financial instruments there may only be one execution venue. In executing a trade in such circumstances we will presume that we have provided the best possible result in this respect for these types of instruments.

Order Handling

Rowan Dartington is committed to prompt and fair treatment of all clients’ orders. Having assessed the relevant criteria and any specific instructions provided by you, we will select the most appropriate venue(s) from those available and execute your order accordingly.

Limit Orders

Typically we will deal ‘at best’, using prices at the prevailing price in the market. However, if you give us an investment instruction at a specified price limit and for a specified size (a ‘limit order’), then it may not always be possible to execute that order under the prevailing market conditions. We would be required to make your order public (i.e. show the order to the market) unless you agree that we need not do so. We believe it is in your best interests if we exercise our discretion as to whether or not we make your order public. By agreeing to the Order Execution Policy you agree to us not making your orders public, unless we consider it is your best interests for us to do so.

Order Aggregation

We may combine (or ‘aggregate’) an order for our clients with orders for our clients with orders of other clients. We would only aggregate a client order if it was unlikely to work to the overall disadvantage of the client. However, the effect of aggregation may on some occasions work to the clients disadvantage and may on occasions result in our clients obtaining a less favourable price than if their order was executed separately.

If an order has been aggregated, but not been allocated in full then generally the distribution of assets will be allocated on a proportionate basis. In these circumstances, it may be more costly to the client as we have to fulfil the order over several transactions each subject to our minimum charges.

In all cases we will judge whether the action taken is in the client’s best interests.

Review and Monitoring

We will review our execution arrangements and venues on at least an annual basis or whenever a material change occurs that affects our ability to obtain the best possible result for our client orders. We will inform you of any material changes to our execution arrangements or our execution policy. We will also periodically monitor the quality of our execution against the factors detailed in this Policy to identify and, where appropriate, enhance our arrangements.

RD will actively monitor compliance with the Order Execution Policy.

General

RD operates on the basis that all Retail clients would be legitimately relying on the firm to deliver best execution for all transactions, regardless of how they arise.

By signing or agreeing to the declaration in the account opening form, you (or your authorised intermediary) consent to our Order Execution Policy including those sections that require your prior express consent.

Please note that if you do not provide your consent to our Order Execution Policy you may be limiting our ability to execute your orders on the most advantageous terms for you. Accordingly, if you do not consent to this Order Execution Policy we will be unable to open an account for you.

Instrument

Main Venues Used

Main Constituents

(N.B. these lists are not exhaustive)

UK Stocks and Shares/Warrants London Stock Exchange, ISDX/PLUS and approved member firms of these venues. We may also use Multilateral Trading Facilities and Dark Pools. Winterfloods, Peel Hunt, Knight Securities, Investec Bank, Numis Securities, Cenkos, Canaccord, Shore Capital, Singer Capital, Thomas Grant.
Foreign Stocks, Warrants and Depositary Receipts Regulated exchanges, Knight Securities, Winterfloods, Peel Hunt, Cannacord, Nomura, ICAP, Kaupthing, C Hoare & Co , Liberum Capital.
Investment Trusts London Stock Exchange. Cantor Fitzgerald, Panmure Gordon, Winterfloods, Collins Stewart, Cenkos, Cannacord Adams, Invesco, Investec, Numis Securities.
Fixed Interest/Bonds (non-UK Government and Corporate) Major liquidity providers and brokers Winterfloods GILTS, Bridport, BNP Paribas, Barclays, Investec, Morgan Stanley, Peel Hunt, Rabobank, UBS, Societe Generale, Numis Securities.
Unit Trusts/Exchange Traded Fund’s (ETF’s) Managers of the funds, Cofunds or regulated markets for exchange traded funds.
UK Treasury Bonds London Stock Exchange Winterflood GILTS, Cantor Fitzgerald

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