This Order Execution Policy outlines all of the sufficient 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 Financial Conduct Authority (“FCA”), our Order Execution Policy covers, amongst other things, the relevant factors involved in obtaining best execution, the execution venues we choose and order handling. 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. The Policy should be read in conjunction with your WHI Terms and Conditions.
While we take all sufficient steps based on the resources available to us to satisfy ourselves that we have processes in place that can sufficiently 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 (RM) or a multilateral trading facility (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.
When executing or routing orders on your behalf we take into account certain criteria for determining the relative importance of the ‘execution factors’. This means that we have policies and procedures which are designed to obtain the best possible execution result, subject to and taking into account:
Our policy applies to both retail and professional customer, and to certain types of transactions in ‘Financial Instruments’. Financial Instruments is a defined term under the Markets in Financial Instruments Directive (MiFID I and II) and the rules of the FCA and includes, but is not limited to, shares, bonds, ETFs, derivatives (excluding certain categories of commodity derivatives) and units in collective investment schemes.
It does not include, for example, FX spot, deposits, loans and physical commodities (‘Financial Instruments’).
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 places upon us, or as may be otherwise contracted between us.
When placing orders on your behalf, we will take all reasonable steps to obtain the best possible result for them by taking into account the following execution factors:
Acting on specific instructions from you may prevent us from taking the necessary steps set out in the document to achieve best execution. Where specific instructions are provided and we are able to comply with those instructions, we will execute the order in accordance with those instructions. Where the instructions relate to only part of the order, we will continue to apply our order execution policy to the aspects of the order not covered by your specific instructions.
We have specific strategies outlining the process for executing retail and professional customer orders to ensure your order is executed in accordance with Best Execution obligations.
There may be occasions where we 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.
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.
We do not operate a proprietary book, however, our Market Makers may execute client orders whilst operating a principal book. We have implemented segregation of duties – such that traders manage client orders and Front Office Relationship Managers do not direct orders straight to the Market Makers. This ensures that we obtain the best available price for clients and that knowledge of impending client orders cannot be used to pre-hedge the Market Makers’ principle position to client(s)’ disadvantage.
We have identified a variety of execution venues to obtain the best possible result on a consistent basis when executing customer orders.
The execution venues may change and updated details are available on request. The venues on which we place significant reliance are:
Other factors used when evaluating existing or proposed execution venues may include (in order of importance):
In exceptional circumstances, where we believe that we can trade to a client’s advantage, WHI may transact a trade with a client 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. By agreeing to WHI’s Terms of Business, you consent to this Order Execution Policy which includes consenting to the Firm undertaking a transaction outside a RM or MTF.
When we transmit an order to another entity for execution, they will be subject to a regulatory or contractual obligation to provide best execution.
| Instrument | Execution venue |
|---|---|
| Cash equities | London Stock Exchange Aquis Exchange New York Stock Exchange Nasdaq All European markets Hong Kong Malaysia Singapore Tokyo Australia New Zealand Canada South Africa |
| UK equities | Canaccord Genuity Limited Cavendish Capital Markets Ltd Cowen Davy Goodbody Stockbrokers Investec Bank Plc JP Morgan Securities Liberum Capital Ltd Singer Capital Markets Ltd Numis Securities Ltd Deutsche Numis Panmure Gordon (UK) Ltd Peel Hunt LLP Pershing Shore Capital Stockbrokers Ltd Stifel Nicolaus Europe Ltd Susquehanna International Securities Ltd Winterflood Securities Ltd Jane Street Financial |
| International equities | Pershing Securities Ltd Peel Hunt LLP Winterflood Securities Ltd DBS Vickers Securities UK Ltd RBC Europe Wells Fargo |
| Fixed Income | Canaccord Genuity Ltd Cavendish Capital Markets Ltd Guy Butler Investec Bank Plc Lloyds Bank Plc Numis Securities Ltd Deutsche Numis Peel Hunt LLP Royal Bank of Canada RIA Capital Markets Ltd Shore Capital Stockbrokers Ltd Singer Capital Markets Ltd Winterflood Securities Ltd |
| Exchange Traded Funds (ETFs) | Flow Traders BV Susquehanna International Winterflood Securities Ltd Peel Hunt LLP Jane Street Financial Jefferies International Royal Bank of Canada Investec Bank |
We execute orders in collective investment schemes / UCITS directly with the fund manager or a third party appointed by the Fund Manager. Before we can execute certain UCITS and collective investment scheme orders, we are required by regulation to provide you with a Key Information Document. Where this regulation applies, the order will not be deemed as a valid order until the KID is disclosed.
We execute structured products on an ‘Over the Counter’ (OTC) basis with the product provider concerned, rather than a centralised market exchange.
If you are either an Advisory Managed and/or Discretionary client wishing to deal in WH Ireland stock, your Investment Manager is required to seek approval from the firms Compliance and Company Secretary. Where this applies, the order will not be deemed as a valid order until approval is granted.
WHI also has access to MTFs and dark pools for Professional clients only and are offered by Pershing Securities Ltd, RBC Europe and Wells Fargo.
WH Ireland has implemented a governance framework and control process through which it monitors the effectiveness of the order execution arrangements (including this Policy), to identify and, where appropriate, correct any deficiencies. Through this governance framework and controls process, WHI is able to assess whether the Execution Venues included in this Policy consistently provide the best possible result for you or whether changes are needed to the execution arrangements.
We review the order execution arrangements and Policy at least annually or whenever a material change occurs that affects the ability to obtain the best result for the execution of Client Orders on a consistent basis using the venues found on WH Ireland’s internet site. Material changes include, but are not limited to:
Any material changes to this Policy will be updated via the WHI website where the latest Order Execution Policy can be found. In addition to adhering to this Policy, we follow internally defined Best Execution guidelines in order to ensure that the right systems and processes are in place to enable Best Execution delivery on a consistent basis.