Order Execution Policy Summary & Disclosure Statement

Disclosure Statement

Under the FCA’s rules and the Markets in Financial Instruments Directive (MiFID) Marlborough Investment Management Ltd (Marlborough) are required to take all sufficient 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.

Marlborough 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 sufficient 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.

For Retail Clients, the best possible result will be focused on the total consideration or cost they incur, representing the price of the financial instrument and the costs related to execution. Ordinarily price will merit a high relative importance in obtaining the best possible result for Professional Clients (including the funds we manage) but in some circumstances for some clients, orders, financial instruments or markets, other execution factors may be deemed to carry more importance than price in obtaining the best possible execution result.

Execution Venues

MIM does not execute client orders directly. We use 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. Marlborough are required to monitor whether these firms are delivering best execution for our clients.

Marlborough maintains a list of approved brokers which is subject to regular review.

When dealing in collective investment schemes (CIS) the deal is placed directly with the product provider so there is no choice of venue.

Order Handling

Marlborough will seek to ensure that our executing entities execute client orders in a prompt, fair, accurate 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, MTF (Multi-Lateral Trading Facility) or OTF (Organised Trading Facility) we will require your express consent prior to transmission of the trade.

Specific Instructions

Where Marlborough receives specific instructions from a client relating to the execution of an order Marlborough will execute the order following the specific instructions and will have satisfied its best execution obligations in respect of that order or that part of the order to which the client instructions relate. Any specific instructions given to Marlborough by a client may prevent Marlborough from taking the steps needed to obtain the best possible execution results.

Providing Information

Following the execution of a transaction (that is not a CIS) on behalf of a client Marlborough will inform the client where the order was executed.

Publishing Information on Execution Quality

Marlborough will publish on its website on an annual basis a summary for each class of financial instrument, of the top five execution venues, in terms of trading volumes, where we executed client orders in the preceding year, together with information on the quality of execution obtained. This is known as an RTS 28 Disclosure.

Monitoring

Marlborough will monitor the effectiveness of our order execution arrangements and whether third party entities are delivering Best Execution for our clients, in line with our Order Execution Policy.

Your Consent

Marlborough is required to obtain the prior consent of our clients to our Order Execution Policy. This consent is provided through client agreements which are agreed prior to trading taking place.

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