COMPLIANCE

Under the Markets in Financial Instruments Directive (“MiFID II”) and the Financial Conduct Authority (FCA) rules, we have an obligation to take all sufficient steps to obtain the best possible result for our clients when executing orders or transmitting orders to other financial institutions for execution.

ORDER EXECUTION POLICY

Introduction

Under the Markets in Financial Instruments Directive (“MiFID II”) and the Financial Conduct Authority (FCA) rules, we have an obligation to take all sufficient steps to obtain the best possible result for our clients when executing orders, or transmitting orders to other financial institutions for execution. This is known as “Best Execution”.

This Order Execution Policy (“Policy”) provides information on how KW Investment Management or “Kingswood” intends to comply with this obligation and implement effective arrangements to enable us to obtain the best possible result for our clients.

Scope

This policy applies to Retail and Professional clients of Kingswood and covers any transaction conducted in financial instruments falling under the scope of MiFID II (Equities, Fixed Interest, Exchange Traded Funds, Collective Investment Schemes, Derivatives, Forward FX and Structured Products):

Executing Orders

Subject to any specific instructions that you may give us, Kingswood, and Third Platform Securities (TPS)) will take all sufficient steps to obtain the best possible result when executing orders.

All fund orders will be transmitted to TPS for execution via the FnZ investment platform. TPS will take reasonable steps to execute client orders in a prompt, fair, and efficient manner relative to other client orders. TPS will execute comparable client orders sequentially in accordance with the time of their reception unless otherwise instructed by Kingswood; or the characteristics of the client order or prevailing market makes this impracticable.

All Exchange Traded Funds (ETFs) and direct equities will be executed directly by Kingswood via the Fidessa RSP platform, provided to Kingswood by TPS. Kingswood will take reasonable steps to execute client orders in a prompt, fair, and efficient manner relative to other client orders. Kingswood will execute comparable client orders sequentially in accordance with the time of their reception unless otherwise instructed; or the characteristics of the client order or prevailing market makes this impracticable.
This will generally be the total consideration (price and related execution costs) paid by/to a client. However, in certain circumstances (see Execution Factors) TPS may decide that other execution factors are more important than price and cost in determining the best possible result.

As the attainment of similar end investment performance for all clients within the same investment strategy is important to us, we may aggregate orders if we reasonably believe that this will work to the advantage of our clients (for example achieving a better price through benefits of scale). We will not aggregate orders if we consider that this is likely to disadvantage our clients, however, on some occasions the effect of aggregation may be disadvantageous.

Transmission of orders:

• Where we are appointed Discretionary Manager orders will be transmitted / executed at our discretion.

• Where we are acting on a client instruction, the order will be transmitted / executed as soon as practicably possible following receipt.

• We transmit orders as agent only (i.e. we facilitate our clients; we do not purchase from/sell to our clients from our own account).

• Orders are dealt with in the order that they are received by Kingswood.

Where we transmit an order to another entity, we will take all reasonable steps to achieve the best possible result in line with this policy.

Specific Instructions

Where we receive a specific instruction from you, this may prevent us (or TPS) from achieving the best possible result in respect of the elements of the order covered by those instructions.

Execution Factors

Kingswood will take into account various factors to determine how an order should be dealt to achieve the best possible result, including:

• Price – this will usually be considered the most important factor in achieving best possible result.

• Cost of transaction – we will always assess the charges made by Execution Venues.

• Speed of execution – the price of liquid securities can move quickly and a delay in execution may cause a detrimental price to that expected being achieved.

• Likelihood of the execution or settlement – there may not be multiple trading venues/competing prices in relation to some illiquid securities therefore actually being able to buy/sell at a required price may be difficult.

• Size and nature of order – the prices displayed on execution venues are for dealing in a certain size. Orders greater than this size will be managed in line with this policy.

• Any other consideration relevant to the execution of the order – this may include the need for timely execution, the time zone of the execution venue or the diversity in markets for different types of financial instrument.

Kingswood will determine the relative importance of these factors based on the characteristics of the client, the order and of the financial instrument, in relation to the trade venues we use. Kingswood will decide in its absolute discretion, the factors that are most important to any order.

Execution Venues

Subject to any specific client instruction, Kingswood and TPS may use one or more of the following venues to enable us to obtain the best possible result when executing orders:

• Regulated Markets;
• Multilateral Trading Facilities;
• Organised Trading Facilities;
• Systematic Internalisers;
• Other liquidity providers e.g. market makers acting as principal;
• Inter-dealer brokers; Unrelated third parties performing similar functions; and
• Equivalent third country venues to the above

Kingswood’s choice of venue may be constrained by there being only one market or trading platform where an order can be executed because of the nature of the order or a specific client instruction.

Top 5 Execution Venues

In accordance with MiFID II Level 2 Delegates Regulation (2017/565) we are required to provide information on the top five investment firms (in terms of trading volumes by asset class), used to execute client orders in the preceding year. This applies to all instruments in the scope of MiFID II. This information will be published on our website by the end of April each year.

Publication of Unexecuted Limit Orders

Where you place a Limit Order with us (in shares that are admitted to trading on a Regulated Market or traded on a Trading Venue) that is not immediately executable, you permit Kingswood not to immediately make the order public and allow Kingswood to exercise their discretion in accordance with this policy.

Monitoring and Review

We review all trades on a regular basis for timely execution and price achieved.
We review this policy annually or when there is any material change to our arrangements. We will notify you of any material changes by providing an updated policy.

Consent

We are required to obtain your prior agreement to this Policy, as well as your consent to (1) not publish Limit Orders and (2) Kingswood to execute orders outside a Trading Venue.

Signing our Investment Management Agreement and agreeing to our Terms and Conditions constitutes this acceptance/consent.

LEGAL DOCUMENTS

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COMPLAINTS

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PRIVACY POLICY

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TERMS OF BUSINESS

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conflicts of interest

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PILLAR 3 DISCLOSURE

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Top 5 Broker Report

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