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.
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 I and II). The policy applies where we:
In considering how to achieve the best possible result, the execution factors that we will take into account are:
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.
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.
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.
Other factors to be considered when evaluating existing or proposed Execution Venues , in order of importance may include:
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 for cash equities:
Market makers used for UK equities:
Market makers used for International equities:
Market makers used for Fixed Income:
Market makers used for Exchange Traded Funds (ETFs):
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.
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.
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.
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 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. Periodically, and at least on an annual basis, we will review the Execution venues we access, taking into account the execution factors mentioned above,. We will also review Execution venues we do not have access to, which may help us achieve a better outcome for our clients on a consistent basis. Such reviews enables us to identify and implement changes to this Order Execution Policy and relevant arrangements as necessary. We will notify you of any material changes to our Order Execution Policy by posting updates on our website, www.whirelandplc.com.
In accordance with reporting requirements under the MiFID II regulatory technical standard 28, we will publish annually on our website the top five execution venues in terms of trading volumes for all executed client orders per class of financial instrument together with information on the quality of execution obtained.
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 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.