Best Exectution Policy Disclosure Statement

Disclosure Statement 

Under the FCA’s rules and the Markets in Financial Instruments Directive (MiFID) Marlborough Investment Management Ltd (MIM) are required to take all reasonable steps to obtain the best possible results for its clients when receiving and transmitting orders on their behalf.  The obligation to deliver Best Execution applies in relation to all types of financial instrument.

MIM has in place an Order Execution Policy and procedures that are designed to obtain Best Execution on a consistent basis, subject to and taking into account the nature of the orders and markets in question.

This disclosure statement provides clients with information concerning our Order Execution Policy in respect of transactions we undertake on your behalf.

Execution Factors 

The overriding requirement is that we must take all reasonable steps to obtain the best result, in relation to each type of financial instrument, taking into account the following:

Price;
Cost;
Speed;
Likelihood of execution and settlement;
Size;
Nature of the order; and
Any other consideration relevant to the execution.

Ordinarily price will be the most important aspect in obtaining the best possible result.  If you have been classified by MIM as a Retail Client we will assume that the best available price is the most important outcome for your transaction.

If you have been classified by MIM as a Professional Client we may take different factors into account, when assessing best execution, depending on the nature of the relevant financial instrument and the relevant market.

Execution Entities 

MIM does not execute client orders directly.  It uses third party entities – brokers – to execute the client orders that we transmit.  Each of these entities must have execution arrangements in place that meet the relevant regulatory requirements.  MIM are required to monitor whether these firms are delivering best execution for our clients.

MIM has a Register of approved brokers which is subject to regular review.

Order Handling 

MIM will seek to ensure that our executing entities execute client orders in a prompt, fair and expeditious manner, for the type of order in question and that orders are allocated fairly.

Where a limit order is not immediately executed our executing entity may immediately display the limit order unless you have provided us with express consent to the contrary prior to transmission of the trade.

Where orders require execution outside a regulated market or MTF we will require your prior express consent prior to transmission of the trade. 

Specific Instructions 

Where MIM receives specific instructions from a client relating to the execution of an order the client should be aware that adhering to a specific instruction may prevent us and our executing entity from achieving the best possible result for the execution of that order.

Monitoring 

MIM will monitor compliance of our Best Execution obligations and whether third party entities are delivering Best Execution for our clients, in line with our Order Execution Policy.

Your Consent 

MIM is required to obtain the prior consent of our clients to our Order Execution Policy.  Clients are deemed to have provided such consent when they place an order with MIM unless you have been classified by MIM as a Retail Client where MIM will need to obtain your express, two-way consent before we can transmit your orders for execution. 

Review 

We will review our Order Execution Policy on an annual basis.  We may also amend our policy as necessary and where a material change has occurred.

MIM will notify you of any material changes to our Order Execution Policy.