Best Execution Policy
This policy sets out the Oakglen Wealth Limited (“Oakglen”) Order Execution Policy. It is applicable to clients who are categorised as Retail or Professional Clients, and applies when, on behalf of clients, Oakglen:
- Receives and transmits orders on a client’s behalf for execution; and/or
- Undertakes portfolio management services.
Oakglen will obtain the prior consent of its clients to the execution policy, which forms part of the client relationship opening procedure.
Oakglen has an obligation to establish and implement an order execution policy. Oakglen must also establish and implement effective arrangements for complying with the obligation to take all sufficient steps to obtain the best possible results for its clients, unless circumstances require to do otherwise in the client’s interests or there is a specific written instruction not to from the client. The purpose of this policy is to set out how Oakglen meet these obligations to achieve best execution.
Oakglen must take all sufficient steps when executing orders, to obtain the best possible result for its clients, considering the execution factors. The execution factors are:
- Likelihood of execution and settlement
- Or any other consideration relevant to the execution of an order
Each of these factors will not necessarily be given equal weighting however will form part of an evaluation of how to obtain the best possible result.
To determine the relative importance of the execution factors, Oakglen will consider the following criteria:
- the characteristics of the client including the categorisation of the client as retail or professional;
- the characteristics of the client order, including where the order involves a securities financing transaction (SFT);
- the characteristics of financial instruments that are the subject of that order; and
- the characteristics of the execution venues to which that order can be directed.
In assessing the most favourable route to carry out a client’s order, Oakglen we will consider the ‘total consideration’ representing the price of the financial instrument and the costs related to execution, which must include all expenses incurred by the client which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.
Speed, likelihood of execution and settlement, the size and nature of the order, market impact and any other implicit transaction costs will only be given precedence over the immediate price and cost consideration if they are instrumental in delivering the best possible result in terms of the total consideration.
When executing orders or taking decision to deal in Over the Counter (OTC) products, including bespoke products, Oakglen will check the fairness of the price proposed to the client, by gathering market data used in the estimation of the price of such product and, where possible, by comparing with similar or comparable products.
In some circumstances for some clients, orders, financial instruments or markets, the policy may appropriately determine that other execution factors are more important than price in obtaining the best possible execution result.
Commissions and Inducements
Oakglen will not structure or charge its commissions in a way that discriminates unfairly between execution venues. Nor will Oakglen receive any remuneration, discount, or non-monetary benefit for routing client orders to a particular trading venue or execution venue which would infringe the requirements on conflicts of interests or inducements.
Oakglen’s own commissions and the costs for executing an order in each of the eligible execution venues will be considered when assessing and comparing the results that would be achieved for a client by executing the order on each of the execution venues listed in the firm’s execution policy that is capable of executing that order.
Types of Financial Instrument
The types of Financial Instruments that Oakglen can facilitate, and will generally be subject to best execution requirements include the following:
- Equity investments – e.g., Shares;
- Fixed Income investments – e.g., Bonds, notes, debenture stock, loan stock, certificates of deposit, commercial paper or other debt instruments including any government, public agency, municipal or corporate issues;
- Fund investments – Units and shares in collective investment schemes;
- Derivative contracts – e.g.
- Warrants to subscribe for, or purchase, investments falling within the above definition of Financial Instruments;
- Forwards or futures on investments falling within the definition of Financial Instruments;
- Options on investments falling within the definition of Financial Instruments;
- Structured Investment Products;
- Precious metals
Initial Public Offerings (IPO’s) – primary issuance of securities
Where an order relates to an IPO, the share allocation process will be governed by several factors, and as such best execution will not be a primary concern. There are several factors that will be considered in the share allocation process, including the ‘retail’ and ‘institutional’ split.
In the absence of any specific instructions from a client for orders initiated by Oakglen, orders will typically be directed by the client’s nominated Custodian to the venue where it is believed it will provide the best possible result. This may be any one of:
- regulated markets
- liquidity providers or market makers
- third party brokers
- multilateral trading facilities (systems operated by an investment firm that bring together multiple third party buying and selling interests in financial instruments, also known as an organised trading facility); and
- systematic internalisers (“SIs”) (these are investment firms that on an organised and frequent and systematic basis deal on their own account by executing client orders outside a regulated market or a multilateral trading facility)
Oakglen has reviewed the best execution policies of the nominated custodians and are satisfied that they operate to provide best execution on a consistent basis. Oakglen are satisfied that the custodians have taken into consideration the reliability, financial health and reputation, costs, settlement risk and depth of liquidity of the execution venues used.
Copies of the custodian’s best execution policies can be provided to clients by Oakglen, or sought directly from the custodian.
Specific Client Instructions
Where a client provides Oakglen with specific instructions in how the order is to be dealt, or on certain elements of the order, these instructions may prevent Oakglen from following this Best Execution Policy to ensure the best possible outcome. However, Oakglen will execute the order in accordance with those instructions and this will satisfy best execution obligations under this policy.
The fact that a client has given specific instructions which cover one part or aspect of the order does not release Oakglen from its best execution obligations in respect of any other parts or aspects of the order that are not covered by such instructions.
For each order executed, the client will receive a contract note from the nominated custodian detailing all relevant characteristics of the trade, which will include the trading venue.
Oakglen will maintain vigilance in relation to all aspects of the order execution process, including best execution.
This policy will be reviewed on at least an annual basis, along with the order execution arrangements. If Oakglen make any significant changes to this policy, clients will be issued with an updated version.
A review will also be carried out whenever a material change occurs that affects Oakglen’s ability to continue to obtain the best possible result for the execution of its client orders on a consistent basis using the venues included in its execution policy. Oakglen will assess whether a material change has occurred and will consider making changes to the relative importance of the best execution factors in meeting the overarching best execution requirement.