Best Execution Policy

Overview

It is in the interests of our clients and our firm that we obtain the best possible result when placing orders with other firms e.g. third party brokers and fund managers for the execution of client orders or when transmitting orders on behalf of clients. We are required to take all reasonable steps to provide best execution when carrying out such transactions and, on your request, to provide you with a copy of the policy that we have adopted to achieve that objective.

This best execution policy applies to orders in financial instruments such as funds and other securities. You should read this policy in conjunction with your discretionary management agreement.

Execution Factors

When placing orders with other firms for the execution of orders or when transmitting orders, we will make every effort to ensure the best possible result for our clients taking into account the following factors:

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

For retail clients, the price and cost of execution of the order will normally be the most important aspect in obtaining the best possible result. We will therefore assume this is the most important outcome for your transaction unless you tell us otherwise.

Executing your order

In arranging for the execution of your order:

• We may use a third party broker or platform to execute your order;
• We may trade as an agent (where our scope of regulatory permissions allow us to do so); Execution venues

All orders placed by us are executed through the following venues/third parties:

Throgmorton Capital Management Limited (TCM) has agreements with the Zurich Intermediary Platform and with Parmenion Capital Partners LLP under which these companies provide TCM with an investment management platform and dealing services. A copy of the ‘Best Execution Policy’ for either the Zurich Intermediary Platform or Parmenion Capital Partners LLP is available upon request. Their ‘Best Execution Policy’ lists all execution venues available to them.

We reserve the right to use another execution venue should we deem appropriate in accordance with our Best Execution Policy. We also reserve the right to execute orders outside a regulated market should we deem appropriate.

We will regularly assess the venues/third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging the execution of your orders. The list will then be updated, where necessary, following such assessment.

The third parties have responsibilities in relation to best execution and client order handling. We will also undertake periodic monitoring to ensure that they are meeting the relevant requirements.

Client Specific Instructions

If you have given instructions that price is not the most important factor in executing your instructions, we will make every effort to comply with your instructions but cannot guarantee this. This may be due to either the nature of the order, or the type of financial instrument you wish to trade in.

We will make all decisions as to where the orders are placed in relation to the execution venue. We will therefore not accept specific instructions from clients regarding the venue where your order is executed.

Collective investment schemes

For orders in collective investment schemes e.g. Unit Trusts, OEICs and Investment Trusts we will place the order with the Zurich Intermediary Platform or with Parmenion Capital Partners LLP or directly with the fund manager/operator of the collective investment scheme.

Charges

It is our policy that commission and charging structures will not influence either the selection of execution venues, or the order flow that follows as a result of the execution process. We will therefore not discriminate between the execution venues we use to arrange execution of your orders.

Monitoring and review of our execution policy

We will regularly monitor the effectiveness of our best execution policy to identify and, where appropriate, correct any deficiencies. In particular, this will cover the execution quality of any third parties referred to in the policy.

This review should be carried out regularly (on at least an annual basis) or whenever a material change occurs that affects your ability to continue to obtain the best possible result for your clients. We will also review this best execution policy at least annually and whenever there is a significant change that affects our ability to continue to obtain the best possible results for our clients.

Staff understanding

All relevant staff are made aware of this policy to highlight and emphasise the importance of best execution.