Order Execution


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.

General principles


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:

  • your characteristics as a customer
  • your customer categorisation (e.g. retail or professional)
  • the characteristics or the order and the security that is the subject of that order
  • the execution venues to which that order can be directed

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.

Execution Factors

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:

  • Price – we will always strive to achieve the most advantageous price for an order and it is usually the highest priority in attaining the best execution.
  • Costs of the transaction – when assessing which venue to execute an order on, we will take into account any charges which may be passed onto you and ensure the total consideration of the order is the best outcome, this may lead to executing the deal at a worse price than the best available. This will be a high priority for securities listed on multiple venues.
  • Ease of dealing and speed of execution – in liquid securities where prices can move quickly, the speed of the execution can be the highest priority as delays in the execution process can lead to a detrimental price being attained.
  • Likelihood of execution and settlement – for illiquid securities, the likelihood of execution can be the overriding factor in the absence of competing prices from multiple venues. As the majority of orders are executed ‘on exchange’ this reduces settlement risk due to the settlement rules of the exchange and is therefore low priority in the execution factors, the priority may increase if competing quotes are retrieved for the same security both ‘on and off exchange’ as the settlement risks increase if trades are executed outside of a regulated exchange.
  • Order size, nature or other consideration relevant to the execution of the order – the best price displayed on execution venues is for a particular size; orders which are over this size will be executed in line with our processes and we will employ the best strategy we consider would lead to the most advantageous price being attained. Some strategies employed could lead to delays on the execution of the full order given the impact any immediate execution may have on the price. Market impact may also be taken into account.

Specific Instructions

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.

Execution strategies

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.

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.

Segregation of duties between market makers and traders

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.

Execution venues and entities

We have identified a variety of execution venues to obtain the best possible result on a consistent basis when executing customer orders.

  • Regulated Markets (RM) – A securities exchange which is regulated by the relevant authority in the country in which the exchange operates.
  • Multilateral Trading Facilities (MTFs) – A system, operated by an investment firm or a market operator, which brings together multiple third-party buying and selling interests in financial instruments.
  • 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.
  • Organised Trading Facility (OTF) – A system which is not a RM or an MTF and in which multiple third-party buying and selling interests in bonds or derivatives are able to interact in the system in a way that results in a contract.
  • Retail service providers or other liquidity providers.
  • Other FCA authorised firms and EU or non-EU institutions (for overseas instruments).
  • WHI acting itself as the Execution Venue.

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

  • Member firms of the London Stock Exchange and Aquis Exchange;
  • Member firms of overseas stock exchanges;
  • Managers and administrators of collective investment schemes;
  • Other UK and overseas Execution Venues that WHI deems appropriate and are in accordance with this Policy.

Other factors used when evaluating existing or proposed execution venues may include (in order of importance):

  • Level of liquidity available on consistent basis – market share;
  • General quality of pricing available – execution quality;
  • Cost, speed and reliability of connectivity;
  • Cost of execution; and
  • Means and costs of clearing and settlement.

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
All European markets
Hong Kong
New Zealand
South Africa
UK equities Canaccord Genuity Limited
Cavendish Capital Markets Ltd
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
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

Specific orders

In the case of collective investment schemes / UCITS

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.

In the case of structured products

We execute structured products on an ‘Over the Counter’ (OTC) basis with the product provider concerned, rather than a centralised market exchange.

In the case of WHI Stock

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.

Access to MTFs and dark pools

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.

Monitoring, Review and Reporting

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:

  • Changes in the applicable regulatory framework
  • Significant changes to WH Ireland’s organisational setup that could impact its ability to achieve the best possible result for the clients on a consistent basis

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.