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Overview
It is in the interests of our clients and Whitehead Group Limited that we obtain the best possible result when placing orders with other firms (e.g. third party brokers) for the execution of client orders or when transmitting orders on behalf of clients. We are required under the Rules of the Financial Services Authority to take all reasonable steps to provide Best Execution when carrying out such transactions and to provide you with a copy of the Policy (upon request) that we have adopted to achieve that objective.
This Policy applies to all of our clients and services and it should be read in conjunction with our Client Agreement.
Order execution – obtaining the best overall result
When placing orders with other firms for the execution of orders or when transmitting orders, Whitehead Group Limited will make every effort to ensure the best possible result for our clients taking into account the following factors:
- price;
- costs,
- speed;
- likelihood of execution and settlement;
- size or nature of the order; and
- 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, and Whitehead Group Limited 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, Whitehead Group Limited
- will use a third party broker to execute your order;
- may trade as an agent (where our scope of regulatory permissions allow us to do so);
Execution venue
All orders placed by Whitehead Group Limited are executed through the following routes:
- Mercater Asset Management Limited, Skandia, Cofunds Ltd, Brewin Dolphin;
- When dealing in securities that are not listed on the LSE, we will provide details of an LSE member firm who will then execute the transaction on the appropriate venue
Whitehead Group Limited will periodically assess the execution venues available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when executing orders. The list of execution venues will then be updated, where necessary, following such assessment.
Specific instructions
If you have given instructions that price is not the most important factor in executing your instructions, Whitehead Group Limited 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.
Unless otherwise instructed, Whitehead Group Limited will make all decisions as to where the orders are placed in relation to the execution venue.
Use of third parties
Our terms and conditions with our counterparties (e.g. third party brokers) provide that they will make all reasonable efforts to provide best execution when we instruct transactions through them.
Dealing in collective investment schemes
When Whitehead Group Limited deals in collective investment schemes (e.g. Unit Trusts, OEICs and Investment Trusts), we will deal directly with the fund manager and/or the operator of the collective investment scheme.
Providers of Unit Trusts and OEICs generally calculate and set their prices once a day, in accordance with Financial Services Authority requirements.
Charges
It is Whitehead Group Limited policy that its commission and charging structure will not influence either the selection of execution venues, or the order flow that follows as a result of the execution process. Whitehead Group Limited will not therefore discriminate between the execution venues we use to arrange execution of your orders.
Monitoring and review of our best execution policy
Whitehead Group Limited will ensure appropriate controls and procedures are put in place to ensure we obtain the best possible results for you when arranging execution of orders. These processes will be periodically monitored.
We will also review this best execution policy and our order execution arrangements 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. We will also monitor all of our ’execution venues‘ (as referred to above) to ensure we continue to obtain the best possible results.
Staff understanding
All of our relevant employees are made aware of this policy to highlight and emphasise the importance of best execution.