RJIS Execution Policy

Our processes for delivering best execution (except for clients whose investments are held by Raymond James & Associates)

When executing orders on your behalf, or when dealing in the course of managing your portfolio, we take all reasonable steps to obtain the best result for you on a consistent basis. Upon receipt of your order, or following the decision to deal, your Adviser will follow our order execution policy. We have determined that the most important factor affecting best execution is the cost of the trade to you (i.e. the price, plus any fees, commissions and third-party charges). The additional factors that we take into consideration are the ease of dealing (speed and accuracy); the financial standing and reputation of the execution venue, and the venue’s ability consistently to provide the best outcome.

1. For simple sales and purchases in quoted UK stocks that are up to normal market size, your adviser will use an electronic trade execution system provided by Proquote. This system is a portal that automatically and simultaneously requests a quote from up to 19 potential market makers on the London Stock Exchange, and selects the best quote. Market makers participating in the Proquote electronic trade execution system as at 1 November 2007 are:

   Arbuthnot Arden Partners Cazenove Collins Stewart

   Evolution HSBC Jefferies JP Morgan

   Panmure Seymour Pierce Winterflood

   
   

2. If we can match your order with that of another client of RJIS, we may execute your order by instructing our custodian to “cross” the trade. This is known as an “agency cross trade”, and means that the transaction will not take place on an exchange, but be a book transfer at mid-market price. We will only deal on this basis if it is in your best interests so to do.

3. For sales and purchases that are for securities quoted outside the United Kingdom, or are complex, or are above normal market size, our dealers will use their discretion in placing the trade. The execution venue that they will use will depend on the exact nature of the trade, but will typically be executed through ODL Securities, Winterflood Securities or Merrill Lynch. These market makers have been selected according to the criteria outlined above.

Our processes for delivering best execution (for clients whose investments are held by Raymond James & Associates)

When executing orders on your behalf, or when dealing in the course of managing your portfolio, we take all reasonable steps to obtain the best result for you on a consistent basis. Upon receipt of your order, or following the decision to deal, your Adviser will follow our order execution policy. We have determined that the most important factor affecting best execution is the cost of the trade to you (i.e. the price, plus any fees, commissions and third-party charges). The additional factors that we take into consideration are the ease of dealing (speed and accuracy); the financial standing and reputation of the execution venue, and the venue’s ability consistently to provide the best outcome.

For simple sales and purchases in quoted US stocks that are up to normal market size, your adviser will use an electronic trade execution system provided by Raymond James and Associates (RJ&A). If you place your orders directly using the RJ&A Investor Access service, your order will also be routed via this electronic trade execution service.

In addition to cost, there are many factors that determine RJ&A’s routing practices. Some of these factors include the type of order (for example stop/stop limits), the number of shares, the overall quality of execution of the provider of liquidity, customer service levels, execution speed, volume of shares executed, computer system downtimes and price improvement.

Alternatively, your Adviser may place the deal directly with RJ&A’s dealing desk in Florida, which follows the same order routing procedures.

Full details of the execution venues used by RJ&A can be found at www.raymondjames.com/order_disclosure.htm.