Order Transmission and Execution Policy

1. Introduction

This document outlines our Order Transmission and Execution Policy (the “Policy”), which details our obligation to take all sufficient steps to obtain, on a consistent basis, the best possible result (“Best Execution”) when transmitting client orders for execution.

The following information is aimed at providing the client (“You”) with a general understanding of our typical dealing arrangements. These arrangements may vary for different categories of investment types and are described below.

In addition to the terms and conditions of the service you (acting in each case on behalf of your clients as applicable) consent to this policy and it will apply each time we receive and place a client order for execution.

2. Transmission

Exchange traded orders

We transmit all Exchange Traded orders (equities, investment trusts and exchange traded funds (ETFs) with Wealthkernel (“WK”) for execution. WK are responsible for executing your order and are obligated to act in accordance with the FCA’s Best Execution rules (COBS 11.2). 

3. Best Execution Factors applied by WK

When executing orders, unless otherwise specifically instructed, WK will use price as the primary measure for achieving Best Execution. The following execution factors will be considered, and how these may be considered as part of the decision-making process in the context of the details below (listed in order or priority for a typical trade). Their importance will vary depending on the characteristics of the client order.

• General prices available 
• Cost of execution
• Depth of liquidity
• Relative volatility in the market
• Speed of execution
• Creditworthiness of the counterparties used by the Third Party or the central counterparty
• Quality and cost of clearing and settlement.

4. Order Types

At present, WK offer one exchange traded order type:

At Best Order – Deal immediately at the best available price for that size of order based on the execution venues available, without the client viewing the price in advance.

5. Specific Instruction

Where you give us a specific instruction as to the execution of an order, we will execute the order in accordance with those specific instructions and you should be aware that doing so may prevent us and WK from applying this policy to achieve best execution.

Where your specific instructions relate to only part of the client order, we will continue to apply our policy to those aspects of the order not covered by those instructions.

6. Aggregation and Priority

For exchange traded orders, WK may combine client orders with orders for the account of other clients. The aggregation of orders may operate on some occasions to a client’s (or its customers’) advantage and on some occasions to a client’s (or its customers’) disadvantage in relation to a particular order. The decision to aggregate will be taken in WK’s sole discretion and where orders have been aggregated, they will be allocated to clients on a pro-rata basis in accordance with WK’s order allocation policy.

Depending on price and the consideration received, the disaggregation of bulked proceeds may result in penny rounding differences which cannot be allocated at individual client level.

Should this occur, it will be clearly detailed on the order confirmation that we will provide to you.

7. Venues

For exchange traded orders, WK’s chosen Third Party uses the following to obtain best execution for its customers:  

Wealthkernel deals only for retail clients.

8. Monitoring

We will monitor the effectiveness of our policy to ensure that it consistently achieves the best possible results when transmitting orders to WK for our clients and to identify whether more favorable results could consistently be achieved by transmitting orders to other brokers or on alternative execution venues. We will review our arrangements and this policy at least annually, or whenever a material change occurs that affects our ability to obtain the best possible result for our clients.

Where we identify any deficiencies, we will take appropriate measures and effect suitable changes to our arrangements and/or this policy to address such deficiencies.

We will notify you of any material changes to our arrangements where they are relevant to you (or your clients) and any changes to this policy. Any such changes will come into effect the next time that we receive a client order for execution.

If you wish to discuss the above or have any further questions, please contact us.

For more information on WK’s Best Execution Policy, please visit: 

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https://www.wealthkernel.com/policies 

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