Order Execution Policy
We have a requirement to provide information about our Order Execution Policy (Policy), and the purpose of this page is set this out in an easily accessible format for clients to obtain and consider.
We shall therefore outline how we take sufficient steps to ensure we obtain the best possible outcome when carrying out a transaction on behalf of clients, which is known as “best execution”. For the avoidance of doubt, clients will be deemed to have accepted our Policy when placing an order for execution, or where they wish to be provided with discretionary management services.
All clients of Maunby are classified as either ‘Retail’ or ‘Professional’ following discussions when an individual becomes a client or subsequently if they so choose. For the purposes of ensuring we achieve best execution we will treat all clients as ‘Retail’, regardless of their usual classification.
Execution only orders & Specific Instructions
When provided with a specific instruction, whether for all or part of an order, we will execute the order in accordance with those instructions, which may or may not result in a successful trade. We shall use our reasonable endeavours to execute any order promptly, but in accepting an order we do not represent or warrant that it will be possible to execute such order or that execution will be possible according to the instructions received. If we encounter any material difficulty relevant to the proper carrying out of an order we shall notify the client promptly.
We shall carry out orders only when the relevant market is open for dealing and shall deal with any instructions received outside the relevant market’s hours as soon as possible when that relevant market is next open for business (in accordance with the rules of that market). We may execute an order outside a Regulated Market or Multilateral Trading Facility (both terms as defined in the FCA Rules).
Where an order for a particular client has been aggregated with orders for another client, we will take care to ensure fair allocation of securities across those orders. Where there is an insufficient quantity of securities available to fill all orders, any allocation undertaken by us will be done on a fair and reasonable basis and in accordance with the FCA Rules.
Where orders are received by post, email or other non-verbal means, we shall endeavour to execute such orders as soon as possible following their receipt. Such orders must be clear and unambiguous, and should we be uncertain on any material aspect we reserve the right not to execute the order until confirmation has been obtained. We cannot guarantee that any orders submitted this way will be received by Maunby in a timely fashion, if at all, and therefore advise that any such instructions should be followed up by verbal confirmation.
We consider a number of factors when executing orders, in order to take all sufficient steps to achieve the best possible outcome. These include:
- The characteristics of the instructions from the client and the order to be placed;
- The characteristics of the financial instrument within the order; and
- The execution venue or venues that can be used.
When assessing the most appropriate route to carry out an order our primary focus is on the overall outcome or “total consideration”. This includes the price of the instruments likely to be obtained upon completion of the order, and the costs relating to execution, including:
- All expenses directly incurred by executing the order;
- Execution fees;
- Clearing and Settlement fees; and
- Any fees paid to third parties as part of the execution.
This will apply to the majority of client orders as they are likely to be standard in terms of instrument, settlement period, size and nature. For some orders other factors may have also be important in providing the best possible result for that order, including:
- Speed of execution;
- Likelihood of execution completing and settlement being achieved;
- Potential for the order to impact the price achieved;
- Size and nature of the order or instrument; and
- Other factors.
How Orders are Executed and Execution Venues
When executing orders on a regulated market or Multilateral Trading Facility (MTF), we will consider the execution venue based on the factors listed above. This includes the regulated market or MTF itself or a member of the regulated market or MTF.
In the majority of cases where the order is in a financial instrument that is listed on an exchange the order is likely to be placed with Redmayne Bentley, who act additionally as our CREST sponsor and international custodian. Redmayne Bentley are subject to the same regulations as Maunby, and therefore take all possible steps to ensure best execution when conducting orders on our behalf. A copy of their best execution policy is available from their website.
In some instances where we believe an enhanced outcome or improved total consideration can be obtained for clients, we will place such orders with a broker other than Redmayne Bentley, who will also be subject to the same regulations as Maunby and therefore to achieve best execution. There are a variety of different reasons why such a trade may be placed with a firm other than Redmayne Bentley, including:
- Reduced or low liquidity;
- Ability to locate a buyer or seller; and
- Wide spread between the bid and ask prices.
Orders for unit trusts or open-ended investment companies are executed with individual fund managers via an institutional fund platform. Negotiated terms with the manager/platform often lead to a more favourable outcome than if a client were to trade directly with the fund manager.
We may have close links to the brokers we use, such as Redmayne Bentley, but do not have any common ownership or any other arrangements which would give rise to a conflict of interests, such as the receipt of payments or rebates. Should such we enter into such arrangements in future we would first identify a potential conflict of interest and address it in such a way as to ensure that our ability to execute this Policy is not hindered.
At the end of April each year we publish the top five execution venues used in the previous year for each type of financial instrument on the basis of volumes traded. The Top Five Venues Report for 2018 is available here.
A limit order is where a client provides an instruction to place an order at a specified price limit or better, and/or for a specified size. It may not always be possible to execute the order under prevailing market conditions.
Orders Executed outside of a Regulated Market
There may be occasions when achieving the best possible result in carrying out a transaction for a client requires execution of the order to take place outside of a Regulated Market. By accepting this Policy clients are consenting to Maunby acting with discretion in such circumstances.
Monitoring and Review
At least once a year, we will undertake a review of this Policy to ensure that it is both suitable in terms of achieving best execution, and that it is being implemented correctly. This review will include an assessment of the execution venues used and that these remain suitable for the purposes of achieving best execution. Any changes to this Policy will be made available on our website.