Common use of Summary Order Execution Policy Clause in Contracts

Summary Order Execution Policy. This statement summarises the Investment Manager’s policy in respect of its client order execution for taking all sufficient steps to obtain the best result for its clients when executing transactions on behalf of clients in accordance with MiFID II. A copy of the full policy is available on request. A list of approved execution venues is available on request. These execution venues are all counterparties that have been selected and approved by the Investment Manager. When executing orders on behalf of its clients the Investment Manager will take all sufficient steps to achieve ‘best execution’ through each stage of the execution process. The Investment Manager has in place a policy and procedures which are designed to obtain the best possible execution result taking into account the nature of client orders, the priorities placed in filling those orders and the market in question which, in the view of the Investment Manager, will provide the best balance across a range of sometimes conflicting factors. In the case of UCITS Schemes that are priced on a regular basis, execution can only be effected through the UCITS Scheme manager acting under COLL. The Investment Manager will seek the most favourable terms reasonably available to fulfil its clients’ orders. In all orders the Investment Manager will carefully consider the elements in the Order Execution Policy to ensure that their regulatory obligations are met. The Investment Manager will employ all resources available to it including the Investment Manager’s order management system and information technology systems to ensure executions are routed efficiently and monitored to ensure the execution quality is in the best interest of its clients. The Investment Manager will review the Order Execution Policy on a periodic basis or when material changes are made from a regulatory perspective to ensure that the Investment Manager’s policy and methods of execution continue to be current and in line with market and regulatory developments. In addition, the Investment Manager will, on a regular basis review and assess the quality of execution afforded by those venues on which it executes client orders. Whilst the Investment Manager takes all sufficient steps based on those resources available to be satisfied that the Investment Manager has processes in place that can be expected to lead to the delivery of best execution of Client orders, the Investment Manager does not guarantee that it will always be able to provide best execution of every order executed on behalf of its clients.