Best Execution Policy Disclosure Statement

Introduction

Following the implementation of MiFID, Astaire Securities will, as it has always done, endeavour to provide transaction execution of the highest quality with regard to efficiency and cost effectiveness. The primary objective of its Best Execution Policy is to provide clients the best possible result on a consistent basis.

We will take all reasonable steps, based on the resources available to us, to satisfy ourselves that we have adequate processes in place to deliver the best possible results for transactions executed on behalf of clients. Disclosure of our Best Execution Policy does not override or affect any other fiduciary responsibilities we owe you arising from our regulatory obligations or as may be otherwise contracted between us.

Execution Venues

For each instrument we execute on behalf of clients it is our policy on an ongoing basis to consider the variety of trading venues or sources of liquidity available from time to time. This enables us to obtain on a consistent basis the best possible result for the execution of transactions. In satisfying this policy, we may consider the use of one or more of the following venue types:

  • Regulated Markets
  • Multilateral Trading Facilities
  • Systematic Internalisers
  • Third party investment firms and/or affiliates acting as Market Maker or other liquidity providers
  • Non-EU entities performing similar functions

Where we believe that best execution can be achieved on clients’ behalf outside Regulated Markets or Multilateral Trading Facilities it is our policy to do so, however, your consent is required for this.

In certain financial instruments there may only be one execution venue. In executing a trade in such circumstances we will presume that we have provided the best possible result in this respect for these types of instruments.

Execution Factors

We will consider the following factors, in relation to each instrument type, to determine the counterparts we may chose, the manner in which we instruct them or whether we directly execute your orders in the market place:

  • Price
  • Costs
  • Speed
  • Settlement quality
  • Size of order
  • Investment objectives of the portfolio
  • Any other matters we consider relevant to the efficiency and cost effectiveness of the order

We will determine the relative importance of each factor using the following criteria:

  • Your characteristics (including your regulatory client categorisation)
  • The characteristics and nature of your order, including whether any specific instructions are given in relation to any individual or series of transactions
  • The characteristics of the financial instruments that are the subject of your order
  • The characteristics of the execution venues to which your order can be directed

Ordinarily price will merit a high relative importance in obtaining best execution. In our experience the next most important characteristic is typically liquidity of the market. However, in certain circumstances, for some instructions, instrument types or markets, Astaire Securities at its absolute discretion may decide that other factors may be more important in ensuring the best execution result.

Order Handling

Astaire Securities is committed to prompt and fair treatment of all clients’ orders. Astaire Securities will exercise its discretion in publicly displaying uncompleted limit orders to achieve Best Execution, unless clients expressly instruct otherwise.

Monitoring

Astaire Securities will actively monitor compliance with its Best Execution Policy.