Order Execution

Introduction

This Order Execution Policy outlines all of the reasonable steps taken by us to ensure that we achieve ‘best execution’; that is the best possible result for all transactions undertaken on your behalf. In pursuit of this, and in accordance with the regulatory requirements set out by the FCA, our Order Execution Policy covers, amongst other things, the relevant factors involved in obtaining best execution and the execution venues we choose. A summary of the policy is set out below.

Our commitment to provide you with best execution does not mean that we owe you any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or may be otherwise contracted between us.

Scope

Our Order Execution Policy applies to all retail and professional clients and refers to financial instruments which are defined under the Markets in Financial Instruments Directive (MiFID). The policy applies where we:

Execute on your behalf an order in respect of a financial instrument; or

Pass on (i.e. transmit) an order to another broker or dealer (‘third-party’) for execution.

Execution factors

In considering how to achieve the best possible result, the execution factors that we will take into account are:

• client type,
• price,
• costs (fees, commissions and third-party charges),
• ease of dealing and speed,
• likelihood of execution and settlement,
• order size,
• nature of the order or any other consideration relevant to the execution of the order
• the financial standing and reputation of the execution venue and their ability to consistently provide the best outcome.

In determining the relevant importance of these factors, we will use our commercial experience and judgement, as well as take account of how we have categorised you (e.g. as a retail client or as a professional client), together with the size and nature of the order, the characteristics of the financial instrument to which the order relates, as well as the possible execution venues to which that order can be directed.

In general, in the absence of specific client instructions, we will regard the best possible result in terms of the total consideration i.e. the price and the costs relating to execution as the most important of these factors. However we recognise that there may from time to time be circumstances where other factors may be deemed to be of higher priority. For example, some securities such as shares in smaller companies may be more difficult to transact, or more complex and difficult to settle satisfactorily, in which case, the size of the transaction, the speed of transaction and likelihood of execution and settlement may be relevant factors which we will take into account.

For 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.

Where you have provided us with specific instructions for execution of a transaction, for example a specific venue, this may prevent us from obtaining the best possible result as per our execution factors. We reserve the right to refuse specific instructions from you regarding the execution of your order, where in our opinion such instructions are not practicable or may be contrary to your best interests.

Execution venues and entities

In establishing this Order Execution Policy we have identified a variety of execution venues to obtain the best possible result on a consistent basis when executing orders on behalf of clients.

• Regulated Markets (“RM”) – A market over which a government body exerts a level of control which is authorised and functions regularly in accordance with the provisions of Title III of MiFID.
• Multilateral Trading Facilities (“MTFs”) – A multilateral system, operated by  an investment firm or a market operator, which brings together multiple third-party buying and selling interests in financial instruments – in the
system and in accordance with non-discretionary rules – in a way that results in a contract in accordance with the provisions of Title II of MiFID.
• Systematic Internalisers (“SIs”) – An investment firm which, on an organised, frequent and systematic basis, deals on its own account by executing client orders outside a regulated market or an MTF.
• Retail service providers or other liquidity providers.
• Other FCA authorised firms and EU or non-EU institutions (for overseas instruments).
• Acting ourselves as the Execution Venue.

In exceptional circumstances, where we believe that we can trade to your advantage we may transact a trade with you as principal.

We may deem it appropriate or advantageous to execute your order outside a RM or MTF even where the investment is trading on a RM or MTF. We are required to obtain your consent before executing orders outside a RM or MTF.

Any entity to which we may transmit an order for execution will itself be subject to a regulatory or contractual obligation to provide best execution.

The execution venues may change and updated details are available on request. The venues on which we place significant reliance are:

1) Member firms of the London Stock Exchange and ISDX
2) Member firms of overseas stock exchanges
3) Managers and administrators of collective investment schemes
4) Other UK and overseas Execution Venues that we deem appropriate and that accord with our order execution policy

Main markets we use:

London Stock Exchange
ISDX
New York Stock Exchange
Nasdaq
All European markets
Hong Kong
Malaysia
Singapore
Tokyo
Australia
New Zealand
Canada
South Africa

Market makers used for UK equities:

Canaccord Genuity Limited
Cantor Fitzgerald Europe
Cenkos Securities Plc
Davy
Finncap Ltd
Goodbody Stockbrokers
Investec Bank Plc
JP Morgan Securities
KCG Europe Ltd
Liberum Capital Ltd
NPLUS1 Singer Capital Markets Ltd
Numis Securities Ltd
Panmure Gordon (UK) Ltd
Peel Hunt LLP
Shore Capital Stockbrokers Ltd
Stifel Nicolaus Europe Ltd
Susquehanna International Securities Ltd
Stockdale Securities Ltd
Winterflood Securities Ltd

Market makers used for International equities:

Pershing Securities Ltd
Bank of New York Mellon (International) Ltd
Peel Hunt LLP
Winterflood Securities Ltd
DBS Vickers Securities UK Ltd

Market makers used for Fixed Income:

Canaccord Genuity Ltd
Cantor Fitzgerald Europe
Cenkos Securities Plc
Citigroup Global Markets Ltd
Investec Bank Plc
King and Shaxson Capital Ltd
Lloyds Bank Plc
NCL Investments Ltd
Nomura International Plc
Numis Securities Ltd
Peel Hunt LLP
Cooperatieve Rabobank UA
Royal Bank of Canada
RIA Capital Markets Ltd
Shore Capital Stockbrokers Ltd
TD Securities Ltd
Winterflood Securities Ltd

Market makers used for Exchange Traded Funds (ETFs)

Flow Traders BV
Susquehanna International
Securities Ltd
Winterflood Securities Ltd
Peel Hunt LLP
KCG Europe Ltd
Cantor Fitzgerald Europe

Collective investment schemes / UCITS

We execute orders in collective investment schemes / UCITS directly with the fund manager.

Structured products are executed on an ‘over the counter’ (OTC) basis with the product provider concerned, rather than a centralised market exchange.

We also have access to MTFs and dark pools offered by Bank of New York Mellon (International) Ltd, Pershing Securities Ltd, Stifel Nicolaus Europe Ltd and Liberum Capital Ltd.

Limit orders

By placing an order with a limit you are requesting us to either sell or buy the security at the specified price or better. It may not always be possible to execute that order under the prevailing market conditions. We would then be required to make such orders public ahead of execution, unless you agree that we need not do so. We believe that it is in your best interests if we exercise our discretion as to whether or not we make such orders public, taking into account what we believe to be your best interests. Where you place a limit order with us that is not immediately executed, unless we believe that it would be in your best interest to do so, or you expressly request otherwise, we will not publish your unexecuted limit order during the period that it remains unexecuted. Where we are unable to execute the full amount of your order we may make a partial execution.

Aggregation

There may be occasions where we will combine your order with our own order or those for other clients when we reasonably believe that it will be to your advantage to do so. On occasions, however, aggregation may not work to your advantage and may result in you obtaining a less favourable price.

Execution timing and priority

We will execute your order as soon as reasonably possible unless we believe that by postponing your order is in your best interests. Orders will be executed in the order they are received, except where there are special conditions such as limited liquidity, price limits or where conditions exist that may require additional time to ensure we achieved the best possible result.

Monitoring and review

We will monitor compliance with our order execution arrangements and take reasonable steps to monitor the performance and quality of our execution and that of third parties to whom we have passed orders for execution. Such review enables us to identify and implement changes to this Execution Policy and execution arrangements as necessary. We will notify you of any material changes to our Execution Policy by posting updates on our website, www.whirelandplc.com.

Consent

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

We are required to obtain your consent to our Order Execution Policy and your express consent should we need to undertake a transaction outside a regulated market or MTF. Similarly, your express consent is required should you not wish us to make public any limit order that you place with us.

By signing or agreeing to the declaration within the Declaration and Signing Authority section of the Client Information & Agreement form you consent to our Order Execution Policy.

To find out more call us on +44 (0)20 7220 1666