Execution Policy

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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 wealth manager will follow our order execution policy.

In order to obtain the best result for you we will take into account the following factors when determining how and where to execute an order:

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 UK stocks that are up to normal market size, your wealth manager can use an electronic trade execution system. This system is a portal that automatically and simultaneously requests a quote from up to 14 potential market makers on the London Stock Exchange, and selects the best quote. Market makers participating in the electronic trade execution system as at 25th January 2017 include:

If we can match your order with that of another client of Raymond James, 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.

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 Stifel, Winterflood Securities Limited, Instinet Limited or Peel Hunt LLP. 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 wealth manager will follow our order execution policy.

In order to obtain the best result for you we will take into account the following factors when determining how and where to execute an order:

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

Other important information regarding our processes for delivering best execution

Whilst we will take all reasonable steps based on those resources available to us to satisfy ourselves that we have processes in place that can reasonably be expected to lead to the delivery of best execution of your orders, we cannot guarantee that we will always be able to provide best execution of every order executed on your behalf.

The diversity in those markets and instruments and the kind of orders that you may place with us mean that different factors may have to be taken into account when we assess the nature of our execution policy in the context of different instruments and different markets. For example, there is no formalised market or settlement infrastructure for over-the-counter transactions. In some markets, price volatility may mean that the timeliness of execution is a priority, whereas in other markets that have low liquidity, the fact of execution may itself constitute best execution. In other cases, our choice of venue may be limited. For example, the nature of your order or requirements may mean that there is only one platform or market upon which we can execute your orders. You need to be aware that if you want to buy investments not listed on a regulated market in the UK we cannot guarantee best execution.

Please note that if you give us a specific instruction regarding the execution of your order we will execute that order according to your instructions but only to the extent to which your instructions relate.

Because our execution policy has been designed to obtain the best possible result for you, you should be aware that any specific instructions from you regarding the execution of your order may prevent us from obtaining the best result for you.

In the absence of specific instructions from you we will exercise our discretion in determining the factors that we need to take into account for the purpose of providing you with “best execution”.

If you have any questions, please ask your wealth manager.

Full details of the execution venues used by RJ&A can be found here.