Order Execution Policy

Transcription

1 Order Executin Plicy This dcument summarises the general basis n which Rthschild ( Rthschild, we r us ) will prvide best executin fr a client ( client r yu ) when required by the Eurpean Unin s Markets in Financial Instruments Directive (knwn as MiFID ) and the Cnduct f Business Rules (the COBS ) f the UK Financial Cnduct Authrity (the FCA ) and any similar, r equivalent, rules f the Guernsey Financial Services Cmmissin. 1. Scpe and Purpse We have always recgnised the imprtance f achieving the best pssible result when executing rders fr clients. In certain cases where we are prviding rder executin services t ur clients, we are required under applicable FCA (and if applicable, GFSC) rules t establish and cmply with a plicy n best executin. This dcument sets ut that plicy. The Plicy applies where we: (i) place rders with entities fr executin as a result f a decisin by us t transact in financial instruments when prviding prtfli management services t yu; (ii) execute rders n yur behalf; (iii) receive and transmit rders n yur behalf. The Plicy will nt apply when we are nt executing an rder n yur behalf, fr example where r t the extent: We are fllwing yur specific instructins t execute yur rder in a particular manner r at a particular price; We are fllwing yur specific instructins t execute a specific part r aspect f an rder. Any specific instructins frm a Client may prevent Rthschild frm taking the steps that it has designed and implemented in its Order Executin Plicy t btain the best pssible result fr the executin f thse rders in respect f the elements cvered by thse instructins. The financial instruments cvered by MiFID include mst financial instruments but d nt include: spt freign currency exchange transactins; and spt cmmdity derivative transactins. The Plicy applies t all transactins we arrange r execute n yur behalf, whether arranged r executed thrugh Rthschild Assciates r therwise. 2. Achieving Best Executin Best executin means, fr the purpses f MiFID: that when we transact fr ur clients we take all reasnable steps t achieve the best pssible result (taking int accunt all relevant factrs described belw) acrss all rders n a cnsistent basis fr any financial instrument cvered by MiFID. Best executin means, fr purpses f the Licensees (Cnduct f Business) Rules 2009: -1-

2 that when we transact fr ur clients we take reasnable care t ascertain the price which is the best available fr the client in the relevant market at the time fr transactins f the kind and size cncerned and, unless the circumstances require us t d therwise in the interests f the client, we will deal at a price which is nt less advantageus t him. Best executin is nt a guarantee that we will always be able t prvide best executin n every rder executed n yur behalf, particularly where yu give us specific instructins as t all r part f an rder. In achieving best executin, we take int accunt a number f factrs (unless therwise instructed by yu, as described in paragraph 3 belw). These include: price; csts; speed; likelihd f executin and settlement (liquidity); size f the rder; nature f the rder; type and characteristics f the financial instrument; characteristics f the pssible executin venues; and any ther cnsideratin relevant t the executin f the rder. Whilst ttal cnsideratin (price and csts) wuld usually be the mst imprtant factr, the verall value t yu f a particular transactin may be affected by the ther factrs listed abve. We may cnclude that factrs ther than price and csts are mre imprtant in achieving the best pssible result fr yu. The relative imprtance f each f the factrs will differ depending n: any special bjectives yu may have in relatin t the executin f the rder; the characteristics f yur rder; the characteristics f the financial instruments t which yur rder relates; and the characteristics f the venues (if there is mre than ne) t which yur rder may be directed. We may pass yur rder n t anther Rthschild entity r a third party (which may be a brker) t execute. In cases where we pass yur rder t a Rthschild Assciate utside the EEA, such nn-eea Assciates have agreed t be subject t the best executin requirements. We may pass an rder t a nn-affiliated third party brker r dealer t execute yur rder. In such cases, we will have internal prcesses and prcedures in place t review peridically ur chice f third party brkers and dealers t determine that, taking int accunt all the factrs specified abve, -2-

3 the third party brker r dealer is prviding the best results fr yur rders n a cnsistent basis. In making this determinatin we will have regard t: prices ffered fr the particular type f instrument ver time; average csts per trade charged fr the type f trade ver time; the best executin plicy f, and any ther guidance issued by, the relevant brker r dealer frm time t time. 3. Cmpliance with Client Instructins Where we have accepted yur instructins with respect t the executin f yur rder, whether r nt we have given yu advice n any aspect f it, we will fllw thse instructins t the extent it is pssible fr us t d s. We will nt cmply with ur best executin bligatins where we accept and fllw yur specific instructins when executing an rder r a specific part f an rder, althugh the Plicy may apply t ther aspects f the rder t the extent that they are nt cvered by yur instructins. Fr example: Where yu instruct us t execute an rder fr yu at a particular price; Where yu instruct us t execute yur rder n a particular venue, we will nt be respnsible fr selecting the venue; Where yu instruct us t execute yur rder at a particular time r ver a particular perid, regardless f the price available, we will endeavur t execute yur rder at that time r ver that perid in the best pssible manner but will nt be respnsible fr the timing r any f the cnsequences fr price r ther factrs that results frm the timing f executin. 4. Chsing an Executin Venue Fr purpses f MiFID, a venue includes: an exchange, a Multilateral Trading Facility, a market maker, a systematic internalizer, a brker r anther liquidity prvider. Unless we agree with yu therwise we will use a selectin f venues that will be reviewed peridically. When carrying ut yur Orders, we place significant reliance n the fllwing Executin Venues: member firms f the Stck Exchange; member firms f the Internatinal Capital Market Assciatin; member firms f verseas stck exchanges; managers and administratrs f Cllective Investment Schemes and ther Investments; and ther UK and verseas Executin Venues that we deem apprpriate and that accrd with ur rder executin plicy. A list f the brkers and venues we currently use is available frm yur client directr. The list -3-

4 may be updated frm time t time. Where yur rder is executed thrugh third-party brkers, we will review peridically the brkers that we use taking int accunt the factrs we describe belw fr determining the entities with which the rders are placed r t which we transmit rders fr executin in rder t ensure that the brker r brkers that we use are prviding best executin taking int accunt all rders executed during the review perid. Where it appears in a particular case that better executin is available frm a brker that we d nt rdinarily use, we may use such ther brker n a case by case basis. Hwever, we are nt under any bligatin t check a variety f brkers with respect t each transactin. What factrs are taken int accunt in determining the executin venues? Factrs that we cnsider in selecting the entities with which yur rders are placed r t which we transmit yur rders fr executin in respect f a particular financial instrument include: general price available; depth f liquidity; relative vlatility in the market; speed f executin; cst f executin; creditwrthiness f the cunterparties n the venue r the central Cunterparty; and quality and cst f clearing and settlement. In sme markets price vlatility may mean that timeliness f executin is a pririty. In ther markets that have a lw liquidity, the fact f executin may itself cnstitute best executin. In ther cases, ur chice f venue may be limited because f the nature f yur rder r yur requirements. Fr example, when investment prducts are mre illiquid, there may be little (r n) chice f venue. Where we have a chice f venues in respect f a particular rder, hw d we chse? We take int accunt factrs such as cst and benefits f accessing multiple venues and accessibility in deciding which venues we use. In sme circumstances we may have access t mre than ne venue fr executing an rder in a particular financial instrument. In such cases, we will endeavur t chse the best venue fr the rder taking int accunt the factrs applicable t chsing venues. Hw ften d we review ur venues? Generally, we will review annually the venues we use t execute yur rders, and will update the Order Executin Plicy accrdingly. Clients will be advised f any material change t the Order Executin Plicy via the Rthschild website. If yu wuld like a cpy f the mst recent plicy please cntact yur client directr. 5. Cnsenting t the Plicy We are required t btain yur prir cnsent t the Order Executin Plicy and yu will be deemed t cnsent t it if yu cntinue t retain ur services. Outside regulated markets -4-

5 By signing the Accunt Applicatin (unless yu state therwise therein) yu give yur prir express cnsent t Rthschild executing rders frm time t time in instruments admitted t trading utside a regulated market r Multilateral Trading Facility. Client Limit Orders By signing the Accunt Applicatin (unless yu state therwise therein) yu expressly instruct Rthschild t exercise their sle discretin in yur best interests in determining whether t make public a client limit rder in respect f shares admitted t trading n a regulated market which is nt capable f being executed under prevailing market cnditins. 6. Cntact Details If yu have queries abut the Plicy, please cntact yur client adviser. -5-