Order Execution
Disclosure Statement - Equity and Fixed Income
Under the EU Markets in Financial Instruments Directive (MiFID) and COBS 11.2 of the Financial Services Authority Handbook, London & Capital Asset Management Limited (“LCAM”) is required to take all reasonable steps to obtain the best possible result (or “best execution”) on behalf of its clients either when executing clients’ orders or receiving and transmitting orders for execution.
Consequently LCAM has in place policies and procedures that are designed to obtain the best possible result, subject to and taking into account the nature of the orders, products and markets in question. These policies and procedures aim to provide the best balance across a range of factors that may conflict.
This Order Execution Policy only applies to Retail and Professional Clients.
Determining Best Execution
When LCAM executes or arranges a transaction that is a client order, in taking all reasonable steps to obtain the best result for its clients a range of different factors, such as price and speed of execution are taken into consideration.
LCAM also takes into account:
- The nature of the order and the dealing service the client requires;
- Characteristics of the order such as size,
- The execution venues available;
- Any specific and general instructions from the client which may prioritise how orders are filled.
Execution Factors
When considering the execution approach for its clients, LCAM will consider specific factors such as price, speed of execution and costs that it views as important in achieving the best result for the client. These are termed “Execution Factors”.
In the absence of “specific instructions” (see below) from the client, we may consider various factors to determine the manner in which the client’s order will be executed including:
- Price;
- Costs of execution;
- Speed of execution;
- Likelihood of execution or settlement;
- Size of order;
- Nature of order.
LCAM recognises that different clients have different priorities and our order execution policy is designed to be flexible enough to cater for those different priorities, as well as allowing us to take a different factor into account depending on the nature of the relevant financial instruments and the relevant markets. Ordinarily, price will merit a high relative importance in obtaining the best possible result for retail and professional clients.
Specific Instructions from Clients
Where a client provides LCAM with a specific instruction about where or how it must execute an order these instructions will be followed. Client instructions take precedence over the ranking of best execution factors and may eliminate some of the factors from consideration or modify their importance.
Order Priority
LCAM is required to ensure that client orders are executed in a prompt, fair and expeditious manner for the type of order in question. This requirement is satisfied through implementation of policies and procedures that:
- Execute order as soon as practical, unless postponing is in client’s best interest.
- Allow for execution or otherwise comparable client orders in the sequence it which they are received.
Execution Venues
On an annual basis LCAM will review the effectiveness of its execution arrangements and the quality of execution achieved by the venues that it uses. Such reviews may occur on an ad hoc basis should there be a material change that affects its ability to obtain the best possible result for execution of client orders.
Monitoring and Review
We will also review our execution policies and order execution arrangements annually and whenever a material change occurs that affects our ability to continue to obtain best execution.
We will notify clients of any material changes to our execution arrangements or our Execution policy by posting an updated version of this document on www.londonandcapital.com/executionpolicy.