BEST EXECUTION POLICY
1. Scope
1.1 This document applies only to clients classified by ECL as ‘Clients’ and only to those dealings in ‘Equities Instruments and other forms of advisory services’.
Best Execution is only owed when ECL accepts an order to execute a transaction on client’s behalf or in other circumstances where it has otherwise expressly agreed to accept such Best Execution obligations.
2. Best Execution Obligation and Relevant Factors
2.1 ECL will generally give price a higher relative importance when obtaining the best possible result for orders executed on client’s behalf. However, ECL may also take into consideration a range of different factors, including, the need for timely execution, availability of price improvement, the liquidity of the market (which may make it difficult to execute an order), potential price impact, the size of the order, the nature of the transaction including whether or not such transactions are executable on a Regulated Market or via either route and the quality and cost effectiveness of any related clearing and settlement facilities.
3. Execution Venues
3.1 ECL will, on request, provide further details to clients of the execution venues included in our Execution Policy.
4. Order Execution Policy
4.1 ECL shall take all reasonable steps in obtaining the best possible overall result for our Clients, taking into account the following execution factors in no order of priority;
✓The price at which the Order could be executed
✓ The size and nature of the Order
✓The speed of execution of the Order
✓The likelihood that the Order will be executed and
✓ Any other consideration that is relevant to the execution of the Order
4.2 ECL will always acknowledge that price will generally merit a high relative importance when obtaining the best possible result for the client, and will also take into account the following criteria when determining the relative importance of the execution factors which may result in ECL affording a higher priority to one of the execution factors;
✓The characteristics of the Client
✓The size and any other characteristics of the Order
✓The characteristics of Securities that are the subject of the order and
✓The characteristics of the execution venues to which the Order may be directed
4.3 ECL must act in accordance with the best interest of Client when placing Orders with other entities or transmitting Orders to other entities, for execution, including taking all reasonable steps to obtain the best possible result for the client taking into account the execution factors and the execution criteria described above, except to the extent that ECL places an Order with or transmits an Order to, another entity for execution following a specific instruction from the Client.
5. Monitoring and Review
5.1 ECL will monitor the effectiveness of its execution arrangements and Policy and assess on a regular basis whether the Execution methods and venues it has selected provide for the best possible result for orders it executes on client’s behalf.
5.2 ECL will review this Policy and its order execution arrangements at least annually and will also notify clients where necessary of any material changes to its order execution arrangements or this Policy.
