Order Execution Policy

Order Execution Policy

1 Overview The purpose of this document is to provide clients of Stocktrade ( Stocktrade or we or us ) with information in relation to our Order Execution Policy. The Order Execution Policy outlines the reasonable steps taken by us to ensure that we obtain the best possible results, for you, when executing your orders. 2 Specific Client Instructions If you provide us with a specific instruction to deal for you it may prevent us from following some or all of the steps outlined in our Order Execution Policy, which are designed to obtain the best possible results in respect of your order. Where you have given us a specific instruction we will take all reasonable steps to obtain the best possible results for you in respect of the order or aspect of the order covered by your specific instruction/s. 3 Execution Factors When dealing for you we will consider the following: (1) Your characteristics, including your regulatory client classification; (2) The characteristics of the financial instrument concerned and of your order; and (3) Where such orders can be effected (i.e. the execution venues). In assessing the most appropriate route to carry out your order we will consider the following criteria: (1) Certainty of execution; (2) Client type; (3) Costs; (4) Order Size; (5) Price; (6) Settlement; (7) Speed of execution; and (8) Any other criteria relevant to the execution of the order. The weighting/relevance of these factors may differ between Retail and Professional clients. Professional clients should also refer to section 8. 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 provide you with the best possible result ( 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 Retail clients, in the absence of any specific instructions, we generally give precedence to the factors that allow us to deliver the best possible result in terms of value (total cost) to the client. stocktrade.co.uk 3

4 Execution Venues (Competing Markets) A list of the execution venues we may use can be found at Appendix One of this Order Execution Policy and at www.stocktrade.co.uk. These include Regulated Markets (London Stock Exchange/ISDX), Multilateral Trading Facilities (MTF) and the Retail Service Provider network (RSP), or with an external entity such as a third party broker authorised to handle the order on a regulated market or MTF. However, we reserve the right to use other unlisted execution venues which we deem appropriate and which accord with our Order Execution Policy. 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. For an up to date list of execution venues please visit www.stocktrade. co.uk periodically and you may request a hard copy of the updated list at any time. We may deem it appropriate or advantageous to execute your order outside a Regulated Market or MTF even where the investment ( financial instrument ) concerned is trading on a Regulated Market or MTF. For example this may be: (1) On an over the counter (OTC) basis with a market participant; (2) By crossing your order with that of another opposing client ( Agency Cross ); (3) By executing your order with a systematic internaliser (a firm which trades on its own book) or other liquidity provider; or (4) Occasionally executed by Brewin Dolphin on its own account. 5 Execution Methodology 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. 6 General Dealing Arrangements UK Equities In normal market conditions and for liquid UK equity orders, Stocktrade will utilise its automated execution technology to identify the best available terms by polling a variety of execution venues including the RSP. Large or illiquid orders will be executed on a manual basis utilising the skills of our in house dealing team. In such cases our dealers will source the best available terms by comparing the prices offered by a variety of market participants (including other regulated firms and MTFs) with reference market data. Execution of UK equity orders may occur off exchange. International Equities International Equity orders will normally be executed on the following basis: (a) For CREST deliverable securities, Stocktrade will utilise its automated execution technology to identify the best available terms by polling available 4 stocktrade.co.uk

execution venues. Larger orders will be executed on a manual basis as per the arrangements for UK equity orders. Execution of international equity orders may occur off exchange. (b) For overseas delivery securities (traded locally in the relevant domestic market), Stocktrade will utilise its automated execution technology to identify the best available terms by polling available execution venues (including other regulated firms). Large or illiquid orders will be executed on a manual basis utilising our network of local market participants (including MTFs) to source the best available terms. Execution of international equity orders may occur off exchange. Collective Investment Schemes / UCITS Stocktrade executes orders in collective investment schemes / UCITS directly with the fund manager. Orders are executed on negotiated terms, not generally available to individual clients. Debt Securities For smaller debt security orders Stocktrade will use its automated execution technology to source the best available terms from a variety of bond market participants. For larger orders and less liquid bond markets Stocktrade will utilise its network of tier one and secondary market participants to source the best available terms. UK Government Bond orders (GILTS) may be executed via our automated execution technology or on a negotiated basis via our network of market participants. Exchange Traded Funds (ETFs) In normal market conditions and for liquid ETF orders, Stocktrade will utilise its automated execution technology to identify the best available terms by polling available execution venues. Larger or less liquid orders will be executed on a manual basis as per the arrangements for UK equity orders. Structured Products Structured products are executed on an over the counter basis with the product provider concerned. In such cases an execution only client is solely responsible for accepting the terms offered by the product provider and we cannot accept these terms on your behalf. 7 Limit Orders If you give us an investment instruction at a specified price limit or better 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) in such a case unless you agree that we need not do so. We think it is in your best interests if we exercise our discretion as to whether or not we make your order public. By agreeing to this you agree to us not making your orders public, save where we consider it is in your best interests to do so. stocktrade.co.uk 5

8 Professional Clients Stocktrade will execute Professional client orders in accordance with this Order Execution Policy. Retail client execution venues may be unavailable to certain classes of Professional client. If you have any questions regarding such venues, please contact Stocktrade. 9 Monitoring And Review Stocktrade will actively monitor compliance with its Order Execution Policy. We will notify you of any material changes to our Order Execution Policy as outlined in our terms and conditions with you. All clients may request a hard copy of our Order Execution Policy at any time by contacting Stocktrade. As this Order Execution Policy is required by our Regulator, we cannot accept any amendments to this policy. 10 General By signing the declaration in the account opening form, you (or your authorised intermediary) consent to our Order Execution Policy. 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. Should you require further information or assistance in relation to the Order Execution Policy please contact Stocktrade. 6 stocktrade.co.uk

Appendix One UK Member Firms of the London Stock Exchange Member Firms of ICAP Securities & Derivatives Exchange Ltd. MTF S BATS, Chi-X, Equiduct, Turquoise Nyse Arca Europe Overseas Broker Broker Nomura Far East Deutsche Bank Europe/US/Bonds UBS US Merrill Lynch US/Bonds Goldman Sachs J B Were Australia Winterflood Securities US/Canada/Europe/ Bonds WH Ireland Australia CSFB US/Europe/Bonds Prudential US Citigroup/Saloman US/Bonds Sasfin South Africa RBC Capital Markets Canada E.I.F.B France ABN Bonds United Banks of Finland Finland Barclays Bonds Swiss American Securities US Bank of America Bonds Merck Finck Germany BNP Bonds Banca I.M.I Italy Danske Bank Bonds Bank Vontobel A.G Switzerland Fortis Bonds Leo Stevens et Cie Belgium ING Bonds ICAP Europe Rabobank Bonds Kempen & Co Amsterdam RBS Bonds Van Doorn (AEK) Amsterdam TD Securities Bonds RIA Capital Bonds Altrushare US/Canada Glintir Securities Norway Fidelity Capital Markets US/Canada West LB Europe Brown Brothers Harriman UOB Far East Goodbody Ireland Patersons Securities Australia Tolhurst Noall Australia CIBC/Woodgundy US/Australia Baillieu Australia Legg Mason (Stifel, Nicolaus & Co) US CLSA Far East US stocktrade.co.uk 7

Broker Broker Robert Baird US DBS Vickers Far East Macquarie US/Japan/Asia Renaissance South African/Australian HG Wellington US Cowen & Co US Northern Securities US Scotia Holdings US/Canada Griswold Various US ING Various A G Edwards US/Canada US Canaccord US/Canada BMO Nesbitt Burns Canada Credit Agricole Securities Various Wachovia US NCL Bonds Keppler Switzerland/Europe Daiwa Bonds Helvea Switzerland HSBC Bonds Knight Securities US Guy Butler Bonds Davy Ireland Danske Bank Bonds First Energy Corporation Canada JPM Bonds LCF Rothschild Australian/Bonds King & Shaxon Bonds Ord Minnet Australia Bridport Bonds Hampton Securities Canada UBS Bonds Tokyo Mitsubishi Bonds Bonds Sutherlands Bonds ZKB Bonds Lloyds Bonds Oppenheimer Bonds Commonwealth Bank Australian/Bonds Westend Brokers AG European Redburn European Sanford Bernstein US/Canada Jeffries Bonds Exotix Emerging Markets Clarkson US Williams Capital Group US 8 stocktrade.co.uk

Stocktrade is the execution only division of Brewin Dolphin Limited, which is authorised and regulated by the Financial Conduct Authority (Financial Services Register reference number: 124444). Brewin Dolphin Limited is a subsidiary of Brewin Dolphin Holdings PLC, which is a member of the London Stock Exchange. Brewin Dolphin s registered office details are: Brewin Dolphin Limited, 12 Smithfield Street, London, EC1A 9BD. VAT No. GB-690 8994 69. ST009/05/13