Order Execution Policy

1. Introduction

The Select Platform has appointed Seccl Custody Limited (“SCL”) to provide custody services. The Order Execution Policy is aimed at providing a general understanding of the typical dealing arrangements provided by SCL when using the Select Platform.

These arrangements may vary for different categories of investment types and are described below. In addition to the terms and conditions of the service you (acting in each case on behalf of your clients as applicable) consent to this policy and it will apply each time we receive and place a client order for execution.

This document outlines our Order Execution Policy (the “Policy”), which details SCL’s obligation to take all sufficient steps to obtain, on a consistent basis, the best possible result (“Best Execution”) when transmitting client orders for execution.

2. Transmission

Exchange traded orders

We place all Exchange Traded orders (equities, investment trusts and exchange traded funds (ETFs)) with Winterflood Business Services (“WBS”) for execution. In selecting WBS as our
third party broker for execution, we have considered a number of factors, including (but not limited) to:

• the size and type of the transaction/order and the broker’s capabilities with respect to the relevant type of order, including its ability to execute the order in an appropriate timeframe;
• the competitiveness of applicable fees and commissions, which may be based on the size of the order or the price of the financial instrument;
• the broker’s reputation and responsiveness to requests for trade data and other financial information;
• the broker’s system capabilities of routing orders to execution venues where good liquidity is likely to be present;
• statistics and other information by independent consultants on the relative quality of execution services/financial services delivered by the broker;
• past performance in terms of the general value and quality of services provided by the broker;
• consistency of execution services provided.

We have satisfied ourselves that WBS has arrangements in place that enable us to meet the best execution obligation to our clients.

The execution factors applied by WBS when executing any client orders that we place with them are set out in Section 3 of this policy. The current execution venues used by WBS are detailed in Section 10 of this policy.

Unit trusts and OEICs

For Unit Trusts and OEICs, client orders will generally be routed to the appropriate fund manager for execution at the next available valuation point for that particular fund. Clients’ orders may be aggregated as described in Section 6.

3. Best Execution Factors Applied by WBS

When executing orders, unless otherwise specifically instructed, WBS will use price as the primary measure for achieving Best Execution. The following execution factors will be considered, and how these may be considered as part of the decision-making process in the context of the details below (listed in order or priority for a typical trade). Their importance will vary depending on the characteristics of the client order.

Price

Price will be determined with reference to the execution venues to which WBS connects and on which the security is traded. WBS use automatic execution technology which will source the best price from a range of retail service providers and market makers (see Section 10). Where an electronic price is not available the order will be dealt manually by WBS’s dealing team.

Cost

For orders where brokerage or exchange fees are applicable, WBS will not seek to pass these on to you. For international orders, certain costs (e.g. foreign exchange ‘FX’) may be passed through to you within the price spread, but WBS deem this to still result in the best overall outcome and hence total consideration for you. Any relevant commission rates will have been agreed with the client in advance.

Likelihood of Execution and Settlement

Likelihood of execution is very high due to the relationships WBS has forged with its market maker and broker counterparties. Likelihood of settlement is difficult to assess pre-trade, but WBS monitors the settlement performance of each counterparty so there is a historical track record to base this decision on.

Size

The size of the trade in relation to the liquidity of the stock may have significant influence on the best execution process and is directly correlated to the market impact (implicit costs).

Nature

Consideration will be given to the liquidity of the stock on the order book at the relevant time. Execution may be heavily influenced by the level of on or off order book trading patterns in the stock. These factors plus the size of the order will determine the appropriate execution method. This may include the working of an order into the market place using an appropriate benchmark or immediate execution on an outright bid/offer price, for example.

Speed

The importance of speed of transactions will vary. For example, to reduce the implicit costs associated with market impact, an order might be worked over a day or more. Different order types and specific instructions may also have a bearing on the speed of execution.

Other Relevant Considerations

Careful consideration shall be given not just to each element in isolation, but also to any compromise or interaction between these factors. For example, size against market impact or speed against price, any of which might also be influenced by a client’s specific instruction.

4. Order Types

At present, we offer one exchange traded order type:

At Best Order – Deal immediately at the best available price for that size of order based on the execution venues available, without the client viewing the price in advance.

5. Specific Instruction

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 and you should be aware that doing so may prevent us from applying this policy to achieve best execution. Where your specific instructions relate to only part of the client order, we will continue to apply our policy to those aspects of the order not covered by those instructions.

6. Aggregation and Priority

For Unit Trusts and OEICs, client orders may be aggregated with other client orders and bulked prior to executing with the fund manager. For exchange traded orders, WBS may combine client orders with orders for the account of other clients, or for its own account (including in relation to fractional orders). The aggregation of orders may operate on some occasions to a client’s (or its customers’) advantage and on some occasions to a client’s (or its customers’) disadvantage in relation to a particular order. The decision to aggregate will be taken in WBS’s sole discretion and where orders have been aggregated they will be allocated to clients on a pro-rata basis in accordance with WBS’ order allocation policy.

Depending on price and the consideration received, the disaggregation of bulked proceeds may result in penny rounding differences which cannot be allocated at individual client level.

7. Charges, Dilution Levy or Exit Charges

For Unit Trust or OEIC orders fund managers may levy an initial charge on purchase orders and there is a risk that fund managers apply a “dilution levy” to the order. This normally results where there are sizeable buy or sell orders in the market. This is an extra charge placed on the transaction and will be applied proportionately to an order placed. Should this occur it will be clearly detailed on the order confirmation that we will provide to you.

8. Venues

For exchange traded orders, WBS may use one or more of the execution venues listed in Section 10 to enable it to obtain the best possible outcome on a consistent basis when executing client orders. WBS will regularly assess the execution venues available to ensure the best outcome for the client. The non-exhaustive list of factors which influence their decisions include:

• Cost of Execution
• Level of liquidity available on a consistent basis – market share
• General quality of pricing available
• Cost, speed and reliability of connectivity; and
• Means and costs of clearing and settlement

9. Monitoring

We will monitor the effectiveness of our policy to ensure that it consistently achieves the best possible result for our clients and to identify whether more favourable results could consistently be achieved by transmitting orders to other brokers or on alternative execution venues. We will review our execution arrangements and this policy at least annually, or whenever a material change occurs that affects our ability to obtain the best possible result for our clients.

Where we identify any deficiencies, we will take appropriate measures and effect suitable changes to our execution arrangements and/or this policy to address such deficiencies.
We will notify you of any material changes to our execution arrangements where they are relevant to you (or your clients) and any changes to this policy. Any such changes will come into
effect the next time that we receive a client order for execution.

If you wish to discuss the above or have any further questions, please contact us.

10. Order Venues and RSPs

WBS currently use the following execution venues:

• London Stock Exchange (LSE); including the Alternative Investment Market (AIM).

WBS currently use the following Retail Service Providers (Market Makers/Brokers):

• Canaccord
• Flow Traders B.V
• Investec Bank
• Jane Street Financial Limited
• Jeffries International Limited
• N+1 Singer
• Numis Securities
• Panmure Gordon Limited
• Peel Hunt
• Philip Securities
• Shore Capital
• Stifel Nicolaus Europe Limited
• Susquehanna
• Virtu Financial
• UBS Switzerland AG and
• Winterflood Securities