Order Execution Policy: SPW UK
We will take all reasonable steps to obtain the best possible result for our clients by abiding by this policy when executing orders, or receiving and transmitting orders to other entities for execution.
This Policy applies to Retail and Professional Clients and to financial instruments as defined by MiFID for example shares, bonds and fixed interest securities, investment funds, exchange trade products, derivatives etc.
3. Client Orders
These may result from:
- A decision by us to deal on behalf of a discretionary client;
- A client instruction to deal, following advice or a recommendation from us; or
- A client instruction to deal on an ‘execution only’ basis.
Where we are appointed Discretionary Manager the timing of transmitting orders will be at our discretion.
Where we are acting on an instruction from a client, the order will be transmitted as soon as practicably possible following receipt of the instruction.
4. Best Possible Result
Sanlam Private Wealth transmits its client orders to regulated member firms (brokers) for execution. We select brokers that we are satisfied provide “Best Execution” in accordance with FCA regulations and have established and implemented order execution arrangements that enable us to obtain on a consistent basis the best possible result for our own clients.
Price achieved will be our primary focus for the majority of transactions, although in some circumstances we may take into account a range of execution factors in order to deliver best execution and we will determine the relative importance of those factors based on the characteristics of our clients, the orders we receive and the markets in which we operate. The factors we will consider when delivering best execution are:
- speed of the execution and settlement
- likelihood of the order being executed and settled
- size and nature of the deal
- any other consideration relevant to the execution of the order
In determining the relative importance of the 'execution factors' for each individual order, we will take into account the characteristics of the client and the client order, the characteristics of the financial instrument involved and the characteristics of the brokers to which the order can be transmitted. In the case of retail clients, we will always regard the most important factors as those which result in the best total consideration in terms of the price combined with the costs of execution.
We transmit the majority of our orders to Winterflood Securities (via WINNER, its proprietary electronic liquidity and dealing service that provides access to its in-house liquidity, with executions priced at the market best bid/offer or better) or Sanlam Securities UK for execution, with the following exceptions:
- Collective Investment Scheme (Unit Trust/OEIC) orders are transmitted to the managers of the relevant collective investment schemes or their agents as these are normally the only trading venue available.
- Structured Product orders are transmitted to the product providers or their agents as these are normally the only trading venues available.
- FX orders are generally transmitted to BNP Paribas.
- FX forwards are traded through AFEX Direct.We may transmit orders to other brokers if we are satisfied that they specialise in a particular market and comply with the FCA Best Execution obligations.
In exceptional circumstances where we are unable to find a broker to accept an order (for example, in a fixed interest stock where the size of an order is below the minimum market size that can be traded in that stock), we may execute the order ourselves, in which case Sanlam Private Wealth will be the execution venue and the order will be executed in accordance with FCA regulations.
5. Specific client instructions
Where you give us a specific instruction as to the execution of an order, we will execute the order in accordance with those specific instructions to the extent that it is possible to do so. You should be aware that providing specific instructions to us in relation to the execution of a particular order may prevent us from taking the steps set out in our order execution policy.
By signing the Client Agreement Form, you are providing your express consent to the following:
- If a limit order in shares which are admitted to trading is instructed by you and that order is not immediately executed, we will not normally publish your unexecuted order during the period that it remains unexecuted.
- In order for the best results to be achieved when we transmit orders on your behalf, the executing broker may seek to place an order with an execution venue other than a regulated market or a multilateral trading facility (MTF).
7. Monitoring and Review
We will monitor our compliance with, and the effectiveness of, our order execution policy on an ongoing basis.
We will regularly assess the brokers that we use to ensure that they continue to enable us, on a consistent basis, to obtain the best possible result when executing orders. The brokers we transmit orders to may change over time to reflect the results of our monitoring and review process.
We will undertake a review of our order execution policy at least annually or whenever a material change occurs that may affect our ability to obtain the best possible result for you on a consistent basis. We will notify you of any material changes to our order execution policy by posting an updated version of the policy on our website.
However, you may request a copy of the up-to-date policy at any time by contacting our Group Compliance Officer.