Order Execution Policy
1. Overview
MiFID’s best execution regime requires Fox-Davies Capital Limited (“FDC”) to take all reasonable steps to obtain the best possible results for clients, taking into account: price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of an order.In order to comply with the best execution requirement stated above, FDC will ensure that appropriate execution policies and/or arrangements are effectively implemented for carrying out all orders.FDC however are under no obligation to obtain the best possible result for each individual order; rather, FDC will apply its execution policy to each order with a view to obtaining the best possible result in accordance with the execution policy.The detailed policy for order execution contained below will be reviewed regularly and clients will be informed of any material changes to the policy.
2. Best Execution Policy
This policy is intended, in as clear a way as possible, to demonstrate how FDC operates and provides best execution.
3. Execution Venues
Generally, all orders will be executed on a Regulated Market or Multilateral Trading Facility (“MTF”). The execution venues and clearers (each an “Execution Venue”) that FDC uses are:
| Clearer | Venue |
| Direct as Members: | London Stock ExchangeAIM |
| Via other brokers: | Toronto Stock ExchangeAustralian Stock ExchangeNew York Stock ExchangeNASDAQ |
FDC believes that the Execution Venues are appropriate to providing best execution to the client as these Execution Venues enable FDC to obtain, on a consistent basis, the best possible result for executing client orders. The charges passed down to the client are consistent with the cost to the firm of dealing with each execution venue/clearer so as not to unfairly discriminate against any one Execution Venue.FDC will assess regularly the Execution Venues available in respect to any product that FDC trades in order they continue to be the most appropriate for our clients.
4. Execution Factors
The decision of which Execution Venue is used for any one trade will be reached based on: price, costs, speed likelihood of execution and settlement, size, nature, or any other consideration relevant to the execution of an order. This decision may be influenced by the Execution Venue’s own fees and commissions.When executing an order, FDC will generally treat price as the highest priority for ensuring the best execution. Only under exceptional circumstances would this not be the case.In order to calculate the price, FDC will pay due attention to the total consideration; this is represented by the price of the financial instrument and the costs related to execution, which must include all expenses incurred by the client which are directly related to the execution of the order, including Execution Venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.
5. Execution Criteria
When executing a client order, FDC will take into account the following criteria for determining the relative importance of the above noted factors:
a. The characteristics of the client including the categorisation of the client;
b. The characteristics of the client order;
c. The characteristics of the financial instruments that are the subject of that order;
d. The characteristics of the Execution Venues to which that order can be directed.
6. Selecting an Execution Venue
The following methodology will be used when selecting an execution venue for an order:
a. Subject to proper consideration of the execution criteria and execution factors referred to above, FDC will choose the Execution Venue where it believes it can trade to the best advantage (or at no disadvantage) for the client;
b. When dealing on a Regulated Market or MTF, FDC will select the Execution Venue FDC considers the most appropriate.
7. Specific Client Instructions
FDC can accept specific instructions from a client which may override this policy; however, FDC may not induce any client to do so. If a client chooses to give specific instructions to FDC relating to an order, FDC will attempt to provide best execution as far as possible. However, a client’s specific instruction may prevent FDC from taking the steps that it has designed and implemented in its execution policy to obtain the best result for the execution of that order in respect of the elements covered by those instructions.
8. Limit Orders
If an order has been placed with FDC with a limit on the price for execution, we may not be able to execute it immediately. FSA rules require unexecuted client ‘limit orders’ to be made public immediately unless the client expressly instructs otherwise. By signing the consent that follows, you are expressly instructing Fox-Davies Capital Limited to exercise their discretion whether it is appropriate to make public the order. Please note that FDC is required to obtain in writing your prior written consent to this policy.
9. Execution Venue other than on a Regulated Market or Multilateral Trading Venue (“MTF”)
In order for FDC to achieve the best results for your orders when we execute them on your behalf, FDC may sometimes seek to place your orders with an Execution Venue other than a Regulated Market or MTF. However, for a financial instrument that is admitted to trading on a Regulated Market or MTF, FDC is required to obtain in writing your prior express consent before FDC executes an order in such a Financial Instrument outside a Regulated Market or MTF (save where no Regulated Market or MTF is included in the list of Execution Venues for that Financial Instrument). Please note that FDC is required to obtain in writing your prior written consent to this policy, and by signing the consent that follows you are expressly consenting to FDC effecting transactions on your behalf outside a Regulated Market or MTF.
