< RETURN TO POLICIES

Best Execution and Order Execution Policy

Introduction

Under the regulatory requirements set by the European Union’s Markets in Financial Instruments Directive II (‘MiFID II’) and the Handbook of the UK Financial Conduct Authority (the ‘FCA’), City Asset Management (‘CAM’) must put in place an order execution policy. We must 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.

CAM does not execute investment orders directly but transmits orders exclusively to our custodian, who executes orders on CAM’s behalf. CAM has selected Third Platform Services Ltd (‘Third Financial’) as our custodian.

When selecting Third Financial to execute orders, 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 the provision of Best Execution

CAM carries out monitoring of trades to make sure that CAM obtains quality execution from Third Financial.  There is no close link or shared ownership between CAM and Third Financial.

Details of Third Financial’s 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, Third Financial will take sufficient steps to obtain the best possible result for clients, taking into account the execution factors listed below. CAM will receive reporting from Third Financial to make sure their executions have met our expectations.

Dealing Rules

  • CAM 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.

  • Market abuse, e.g. ‘Front Running’, is explicitly prohibited and a Personal Account Dealing policy is one of the measures 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 and a broker. Details on Third Financial’s execution venues can be found on their website (link provided below).

Conflicts of Interest

To avoid conflicts of interest between execution venues, CAM does not receive any remuneration, discount or non-monetary benefits for placing client orders on any particular execution venue.

Specific customer instructions

Where clients give CAM a specific instruction as to the execution of an order, CAM will execute it in accordance with that instruction. Where the instruction relates to only part of the order, CAM will apply its order execution policy to the parts of the order not covered by specific instructions. Clients should be aware that providing specific instructions may prevent CAM from taking the steps set out in the 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 a ‘limit’ on the price for execution, CAM may not be able to execute it immediately. Consequently, in accordance with regulatory requirements and unless otherwise specifically instructed, CAM will publicly disclose details of any unexecuted part of such ‘limit’ order. However, with client consent, CAM can exercise discretion as to how and when unexecuted limit orders are shown to the market. This allows CAM to achieve the best possible result for clients.

Aggregation and Allocation

CAM 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 CAM makes 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.

Monitoring and review

CAM regularly monitors Third Financial’s execution arrangements, the quality of execution and the execution by third parties to whom they may have passed orders. Such reviews allow CAM to request changes to the execution arrangements as necessary.

Review of Third Financial’s performance will be conducted by a member of the Investment Management team.

Every year, the Top 5 Execution venues (counterparties) by type of financial instruments will be available from Third Financial 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.  CAM 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 the website.

Consent

The FCA requires CAM to obtain clients’ prior consent to this Best Execution Policy. Clients will be deemed to provide such consent when they instruct CAM to act on their behalf in relation to an order or, if clients only wish CAM to provide discretionary portfolio management services, when they appoint CAM to provide these services.  CAM is required to obtain clients’ prior express consent before it executes 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 the Order Execution Policy at any time by contacting their Investment Manager.

Third Financial’s Order Execution Policy

Details of Third Financial’s Order Execution Policy and execution venues can be found here.

October 2025