Order Execution Policy
In accordance with regulatory requirements set by the Financial Conduct Authority (‘FCA’), SSUK is required to put in place an order execution policy and to take all reasonable steps to obtain the best possible result (or "best execution") when executing client orders on behalf of Retail and Professional Clients. We are also required to provide a summary to Retail and Professional Clients of our order execution policy and obtain your consent to such a policy.
Our Best Execution Policy is applicable to Sanlam Securities UK Limited (‘SSUK’) clients who have been classified as either Retail or Professional, where we have received an order in respect of financial instruments: such as shares; derivatives, or bonds, or which we pass on (ie transmit) at our discretion to another broker or dealer (‘third party’) for execution.
In considering how we might achieve the best execution, we will take a number of factors into account: including price (or total consideration in the case of retail clients); costs; speed; likelihood of execution and settlement; size; nature of the order; or any other considerations relevant to the execution of that order.
In determining the relative importance of these factors, we will use our commercial experience and judgement with consideration to the characteristics of the financial instruments to which the order relates, as well as the possible execution venues to which that order can be directed. In general, we will regard ‘price’ as the most important of these factors for obtaining the best possible result. However, we recognise that there may from time to time be circumstances for some clients, particular instruments or markets where other factors may be deemed to have a higher priority. 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.
An execution venue is the term used to describe a place where a client order is executed. For reasons of cost, appropriateness, efficiency and settlement, we execute most client orders in listed shares and other listed securities, such as options, warrants and debt securities, on the London Stock Exchange, another EU Regulated Market, or on a Multilateral Trading Facility (‘MTF’) – a system operated by another investment firm, or a market operator, which brings together multiple third party buying and selling interests in the system and in accordance with non-discretionary rules.
The vast majority of our client’s orders are executed on an EU Regulated Market or MTF, but we may also execute orders outside a EU Regulated Market or MTF (including, for instance, where the securities are admitted to trading on a market which is not a Regulated Market, or where securities are traded solely over the counter (‘OTC’)). In some cases we access execution venues direct, but where we are not a direct member we may access them through a third party. We select third parties to execute orders by taking into account their ability to execute orders in accordance with our priorities set out above; their ability to deal with us efficiently and the costs involved.
Where the security concerned is a unit in a regulated collective investment scheme or open-ended investment company, or other unlisted security, then acquisitions and redemptions of the investment will take place usually with the unit trust manager/investment company or issuer itself. For certain types of investment for example, shares in private companies, there may be no formal market value.
We select the venue we consider the most appropriate for the order taking account of the execution factors we have described above. In relation to some financial instruments there may be only one possible execution venue. When we execute an order on a client’s behalf in such circumstances it will be assumed that we have achieved best execution.
We reserve the right to use other execution venues where we deem it appropriate to do so in accordance with a client’s specific instructions.
Where we receive specific instructions from a client, we shall follow those instructions and to the extent they apply we may not be able to apply our Best Execution Policy and this may have an effect on whether or not we can obtain best execution for the client’s order.
Where you place a limit order with us that is not immediately executed, we will not publish your unexecuted order during the period that it remains unexecuted unless we believe that it would be in your best interest to do so, or you expressly request otherwise.
As an FCA regulated firm, we are obliged to and will report trades executed on a Regulated Market to the FCA. Unless we agree with clients otherwise, we will also report details about transactions in securities that are transacted outside a Regulated Market.
Monitoring and review
We regularly monitor our order execution arrangements, as well as the quality of both our execution and that of third parties to whom we have passed orders. Such review will enable us to identify and implement changes to our Best Execution Policy and execution arrangements as necessary. Clients’ should note that it may not always be possible to make an effective comparison of execution performance because reliable data is not always available for some markets.
We will notify clients about any material changes to our Execution Factors, Execution Venues, and Best Execution Policy by posting an up-dated version of this document on our website. Clients will not be notified separately about changes to our Best Execution Policy or Execution Venues.
Our Regulator, the FCA, requires us to obtain clients prior consent to our Best Execution Policy. Clients will be deemed to provide such consent when they instruct us to act on their behalf in relation to an order or, if clients only wish us to provide discretionary portfolio management services, when they appoint us to provide these services.
Whilst we anticipate that orders will not generally be executed outside an EU Regulated Market or a MTF, there may be circumstances in which it is in client’s best interests to do so. For example this could occur where we execute an order on a non-European market. In this instance, express consent from the client is required to execute such an order.