Best Execution and Order Execution Policy

Introduction

In accordance with regulatory requirements set by the European Union’s Markets in Financial Instruments Directive II (known as “MiFID II”) and the rules, guidance, principles and codes in the Handbook of Rules and Guidance issued by the UK Financial Conduct Authority or any successor regulatory body or bodies (the “FCA”), City Asset Management is required to put in place an order execution policy and to take all sufficient steps to obtain the best possible result (or "Best Execution") when executing client orders on behalf of Retail and Professional Clients.

Scope

Our Best Execution Policy is applicable to our clients who have been classified as either Retail or Professional, where we have received an order in respect of financial instruments: such as shares, collectives, bonds or financial instruments, or which we pass on (i.e. transmit) at our discretion to another broker or dealer (‘third party’) for execution.

From May 22nd 2020, CAM does not execute investment orders directly but transmits order exclusively to one custodian who will execute orders on the firm’s behalf. CAM has selected Platform Securities Limited as the custodian responsible for executing its orders.

When selecting Platform Securities CAM considered the main factors to be

  • Access to multiple venues and markets

  • Systems capabilities to facilitate speed of execution

  • Expertise in order execution

  • Proven track record in provision of best execution

CAM carries out monitoring of trades to ensure that the firm obtains quality execution from its custodian.  There is no close link or shared ownership between CAM and Platform Securities.

Details of Platform Securities execution venues can be found on the website link below.

Order Execution

Subject to any specific instructions received, when executing orders on behalf of clients, Platform Securities will take all sufficient steps to obtain the best possible result for clients, taking into account the execution factors listed below. CAM will receive MI reporting from Platform Securities to ensure their executions have met our expectations for our clients.

Dealing Rules

  • We will not transact buy orders on unsettled funds

  • If an allocation is done in the 24 hours after a deal has been instructed, no connected parties can be involved in the deal allocation to the extent that they were not involved in the initial deal. This will ensure we abide by our own Treating Customer Fairly and Conflict of Interest objective.

  • Market abuse, e.g. “Front Running”, is explicitly prohibited and a Personal Account Dealing policy is one of the measures that we have in place to mitigate the risk of this activity occurring.

Which executing venues will we use?

For purposes of MiFID II, an “Execution Venue” includes an exchange, a multilateral trading facility (“MTF”) and a broker. Details on Platform Securities’ execution venues can be found on their website (link provided below).

Conflicts of Interest

To avoid conflicts of interest and to discriminate unfairly between execution venues listed above, we do not receive any remuneration, discount or non-monetary benefits for routing client orders to any particular trading or execution venue.

Specific customer instructions

Where clients give us a specific instruction as to the execution of an order, for example, asking us to deal through a particular broker or at a specific price, we will execute it in accordance with that instruction. Where the instruction relates to only part of the order, we will apply our order execution policy to the parts of the order not covered by specific instructions. Clients should be aware that providing specific instructions may prevent us from taking the steps set out in our order execution policy to obtain the best possible result for those elements covered by those instructions.

Limit orders

If an order has been placed with us with a ‘limit’ on the price for execution, Platform Securities may not be able to execute it immediately. Consequently, in accordance with regulatory requirements and unless otherwise specifically instructed, we will publicly disclose details of any unexecuted part of such ‘limit’ order. However, with client consent, we can exercise discretion as to how and when unexecuted limit orders are shown to the market. We believe that this allows us to achieve the best possible result for our clients. We therefore seek a client’s express consent on this matter – please see ‘Consent’ below.

Aggregation and Allocation

We may combine (‘aggregate’) a transaction for an individual client with orders of other clients. The effect of aggregation may on some occasions work to a client’s disadvantage.  If we make an application on a client’s behalf for a new issue, clients should be aware that if the allocation is scaled back it will be applied pro rata across all clients, in the event of any scale backs no member staff will be included in the allocation to the extent they did not form part of the initial allocation.

Monitoring and review

We regularly monitor Platform Securities’ execution arrangements, as well as the quality of both execution and that of third parties to whom they may have passed orders. Such reviews enable us to request changes to the execution arrangements as necessary.

Review of Platform Securities’ performance in execution will be separate from our Outsourcing Framework and will be conducted by a member of the IM team.

On a yearly basis, Platform Securities Top 5 Execution venues (counterparties) by type of financial instruments in line with MiFID II rules will be available through PSL via the link below.

Clients 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.  We will notify clients about any material changes to our Execution Factors, Execution Venues, and Best Execution Policy by posting an updated version of this document on our website. Clients will not be notified separately about changes to the Best Execution Policy or Execution Venues.

Consent

Our Regulator, the FCA, requires us to obtain clients’ prior consent to our Best Execution Policy. Clients will be deemed to provide such consent when they instruct us to act on their behalf in relation to an order or, if clients only wish us to provide discretionary portfolio management services, when they appoint us to provide these services.  We are required to obtain clients’ prior express consent before we execute orders in instruments admitted to trading on regulated markets or multilateral trading facilities away from a regulated market or multilateral trading facility.

All clients can request a hard copy of our Order Execution Policy at any time by contacting their Investment Manager.

Platform Securities’ Execution Policy

Details of Platform Securities Order Execution Policy and execution venues can be found here –

https://empower1.fisglobal.com/resource-centre.html

Compliance Code:  DG2369 January 2024