Our order execution policy is applicable to all clients and categories of business conducted by ISEC Wealth Management Limited.
We manage portfolios of investments on a discretionary basis for managed account clients ("clients"). The Company is authorised and regulated in Cyprus by the Cyprus Securities and Exchange Commission with Licence Number 356/18 to undertake Portfolio Management Services.
We will take all sufficient steps to obtain the best possible result for our clients by abiding by this policy when executing orders.
This document outlines the Order Execution Policy ("the Policy") for executing a client order as required
Aside from the explicit best execution rules explained in this policy, we have an overriding duty to act honestly, fairly and professionally in accordance with the best interests of our clients at all times.
Our Order Execution Policy applies to the execution of orders on behalf of Retail and Professional Clients for the following classes of financial instruments: Equities, Derivatives (both Exchange-traded and OTC, Fixed Income Instruments, Money market and cash instruments, as well as any other financial instruments in which we may execute orders from time to time.
We will always execute client orders as Agent, which we pass on (i.e. transmit) at our discretion to another broker-dealer (\\\'Third Party\\\') for execution.
3. Client Orders
These may result from:
A decision by us to deal on behalf of a discretionary client;
Due to the fact that we will be acting as Discretionary Manager the timing of transmitting orders will be at our discretion.
4. Execution Factors
When executing trades on behalf of its clients and the Funds it manages, we place all orders with another entity for it to execute on behalf of the client (e.g. a broker or investment bank). In these instances, Article 24 of MiFID II and Article 65 of the Delegated Regulation will apply. In such scenarios, while we will owe our client a duty of Best Execution, we will also receive a duty of best execution from the third party. We select brokers that we are satisfied provide "Best Execution" in accordance with MiFID II regulations and we have established and implemented order execution arrangements that enable us to obtain on a consistent basis the best possible result for our own clients. Subject to any specific instructions received, we will take the following execution factors into consideration in determining how to obtain the best possible result for the order, namely:
5. Execution venues
An execution venue is the term used to describe a place where a client order is executed and includes Regulated Markets, Multi-lateral Trading Facilities (MTF), Organised Trading Facilities (OTF) Systematic Internalisers (SI) and market makers or any other liquidity providers.
We will, in all instances, place client orders with, a broker for execution. The broker will choose the execution venue used for a particular trade. In choosing which broker to use, we will take into consideration the following factors relating to that broker:
6. Execution Venues
The Financial Institutions used as our brokers/dealers are listed below:
1. Cowen International Limited
2. Dealing Finance Company AD
3. Tickmill Europe Ltd
4. Royal Financial Trading (Cy) Ltd.
7. Execution Methodology for Financial Instruments
Equities, Fixed Income & Exchange Traded Funds (ETF\\\'s)
In order to meet these distinct needs of each order, we consider the following factors:
a) Price and liquidity - as a general rule, we will try to identify brokers which are sources of natural liquidity before entering an order into the market; deep liquidity is likely to provide material opportunities which may take the form of a better price and the ability to trade significant additional size at a similar price
b) Speed and likelihood of execution - this is the rate at which we are able to progress your order; we will seek a balance between creating market, and thereby potentially moving the price, and executing your order in a timely manner so as to reduce execution risk.
c) Size and nature of the order
d) Costs - we believe that one of the steps to achieve best execution is equity markets is to negotiate the lowest possible terms for the explicit cost of trading (such as commissions) and minimise the implicit costs (such as market impact and opportunity cost).
e) Likelihood of settlement - our approved broker selection process as described in Section 6 helps us mitigate the credit and settlement risk we may face. We will generally not use a broker if we cannot either settle a transaction or resolve failed settlements
8. Review of our Execution Policy
We review this execution policy annually, as well as whenever there is a material change that affects its ability to continue to obtain the best possible result for the execution of orders on a consistent basis.
9. Questions on this policy
Should you require any further information and/or have any questions about the order execution policy please direct your request and/or questions to email@example.com
Investing in financial instruments involves a high degree of risk and may not be suitable to all investor. Trading in financial instruments can result in both an increase and decrease in capital. Please refer to our Risk Disclosure available in our web site for further information.
For more information about the company's policies when using this website and the contract terms that are used when opening an account with ISEC, please go to CONTRACT TERMS .