1. Introduction
This order execution policy or Best Execution Policy is applicable to all clients and categories of business conducted by ISEC Wealth Management Ltd.
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.
2. Scope
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 our clients and the Funds we manage, 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 the brokers that we are satisfied that the can provide the “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:
In determining the relevant importance of each of the above factors, when executing an order, we will use our commercial judgement, experience in light of current market information as well as the following criteria:
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:
All brokers are reviewed/assessed on an on-going basis against mentioned above factors in accordance with our obligation to provide the client with the best possible execution results on a consistent basis.
We undertake an annual review of all brokers utilised. This includes assessments of execution quality, service delivery, regulatory status and the financial standing of the firm.
A list of top 5 brokers that we use for execution is published on our website as a part of RTS28 execution quality summary statement annually. An execution venue used for execution of any particular order placed by us in relation to the Client is displayed in the Client Area of our website. The full list of brokers currently used by the Company is published on our website and we reserve the right to change the Brokers we use from time to time, as we deem appropriate, subject to our internal authorisation process and this Policy.
In order to minimise the risk of potential conflicts of interests, we do not receive any form of remuneration, discount or non-monetary benefit for directing orders to a particular venue or broker for execution. The selection of a broker for an order is driven solely by the factors and inputs as described in this Policy.
Where practical, we will look to aggregate purchase or sale orders for the same security or other instrument for multiple accounts so that the clients may be able to benefit from the better prices achieved through the larger bulk transactions in line with our obligation to treat customers fairly. We will aggregate order when we consider doing so appropriate and in the interest of the clients generally and may elect block trade treatment, when available.
Although we may do so in certain circumstances, we do not always aggregate orders for different accounts. If the portfolio management decisions relating to the orders are made by separate portfolio management teams, if aggregating is not appropriate or practicable from our operational or other perspective or if doing so would not be appropriate in light with applicable regulatory considerations.
6. 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:
7. 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; we will notify any affected clients of any changes in this policy via an update in the Clients’ Area.
8. 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 protected].
Investing in financial instruments involves a high degree of risk and may not be suitable for all investors. 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.
CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. The vast majority of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.
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 .
Company information, Terms and conditions agreement, Portfolio management addendum, Custody addendum, Risk disclosure and warning, Conflict of interest, Order execution policy, Investor compensation fund, Client categorisation policy, Privacy policy, Commission and charges schedule, Complaints procedure for clients, Terms of use of website
RISK WARNING: Investing in financial instruments involves a high degree of risk and may not be suitable for all investors.
CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. The vast majority of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.
RISK WARNING: Investing in financial instruments involves a high degree of risk and may not be suitable for all investors.
CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. The vast majority of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.