Order Execution Policy
Information on Castlefield Investment Partners LLP (“CIP”) Execution Policy
When executing orders on your behalf in relation to financial instruments, we will take all reasonable steps to achieve what is called “best execution” of your orders. This means that we will have in place a policy and procedures which are designed to obtain the best possible execution result, subject to and taking into account the nature of your orders, the priorities you place upon us in filling those orders and the market in question and which provides, in our view, the best balance across a range of sometimes conflicting factors.
We will also take into account your understanding and experience of the market in question, your dealing profile, the nature of the service you require of us and the specific and general instructions given to us by you which may prioritise how we are to fill your orders. In the absence of express instructions from you, we will exercise our own discretion in determining the factors that we need to take into account for the purpose of providing you with “best execution”.
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 as may be otherwise contracted between us.
In considering how we might achieve the best possible result for an underlying client order, we will take a number of factors into account, including price (or total consideration), costs, speed, likelihood of execution and settlement, size, nature of the order or any other considerations relevant to the execution of that order.
In determining the relative importance of these factors, we will use our own commercial experience and judgment, as well as take into account how we have categorised you (e.g. as Retail Client or as a Professional Client), together with the size and nature of the order, the characteristics of the financial instruments to which the order relates, as well as the possible execution venues to which that order can be directed.
In general, we will regard price as the most important of these factors for obtaining the best possible result. However, we recognise that there may from time to time be circumstances for some clients, particular instruments or markets where other factors may be deemed to have a higher priority. In the case of 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.
We have identified a variety of different execution venues that we could or intend to use as we consider that these should enable us to obtain the best possible result on a consistent basis, when executing orders on behalf of clients. It is therefore possible that client orders may be executed on a venue which is not a Regulated Market or a Multilateral Trading Facility (‘MTF’ – see later). In other cases, our choice of venue may be limited (even to the fact that there may only be one platform/market upon which we can execute your order) because of the nature of your order or of your requirements, notably if we execute a trade for units in a fund, the venue will be the fund manager or the fund itself.
A list of the execution venues on which we place significant reliance can be found on our website (www.castlefield.com). We will regularly assess the execution venues available so that we can continue to include those which enable us to obtain the best possible result on a consistent basis. You should, from time to time, refer to our website for the current list of principal execution venues, as changes will not be separately notified.
We may transmit client orders to another broker or dealer (including a retail service provider (‘RSP’ – see later) for execution. In such cases we may:
- Determine the ultimate execution venue ourselves by accessing specific execution venues through such third parties; or
- Instruct this other broker or dealer accordingly (having already satisfied ourselves that they have arrangements in place to enable us to comply with our execution obligations to you).
Where we direct an order to an RSP, then the RSP and not CIP may be executing the order.
Where we receive specific instructions from you, we shall follow those instructions and to the extent they apply we may not be able to apply our Execution Policy and this may have an effect on whether we can obtain the best possible result for the execution of your order.
If an order has been placed with us with a limit on the price for execution, we may not be able to execute it immediately. Consequently, in accordance with regulatory requirements and unless otherwise specifically instructed, we may publicly disclose details of any unexecuted part of such a ‘limit’ order.
Monitoring and Review
We are obliged to monitor regularly our order execution arrangements, as well as the quality of both our execution and that of third parties to whom we have passed orders. Such review will enable us to identify and implement changes to our Execution Policy and execution arrangements as necessary. You should note that it may not always be possible to make an effective comparison of execution performance because reliable data is not always available for some markets.
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.
Clients will be advised of any material changes to our policy as necessary.
Regulations require that we must obtain clients’ prior consent to this Execution Policy. We must also obtain your prior express consent to executing a deal outside a Regulated Market or MTF, in an instrument admitted to trading on a Regulated Market or an MTF. If you choose to withhold such consent, we may be prevented from achieving the best possible result where this is achieved by executing your order outside of a Regulated Market or MTF. We will deem that you have provided such express consent where we receive a copy of our Terms of Business agreement from you which has been duly executed in accordance with the instruments related to it.
Glossary of Terms
MTF’s: Multi-lateral Trading Facilities are systems where firms provide services similar to those of exchange venues by matching client orders.
Regulated Markets: These include UK Recognised Investment Exchanges and other major exchanges in the EEA.
Retail Service Providers: A company that provides access to dealing in shares.