Best Execution & Order Execution Policy

Overview

It is in the interests of our clients and Henry Spain Investment Services Limited that we obtain the best possible result when placing orders with other firms for the execution of client orders or when transmitting orders on behalf of clients. We are required under the rules of the Financial Conduct Authority to take all sufficient steps to provide Best Execution when carrying out such transactions and to provide you with a copy of our policy (upon request) that we have adopted to achieve that objective.

This policy applies to all our clients and services and it should be read in conjunction with our Client Agreement.

Client classification

Clients of Henry Spain Investment Services Limited will be categorised as ‘retail’ unless they specifically request to be class as ‘professional’ clients.

Professional clients are clients with a higher degree of investment knowledge and prior investment experience and are afforded less regulatory protection than retail clients are, although in all instances we will ensure that we act in our client’s best interests when arranging for client orders to be executed.

Order execution

When placing orders with other firms for the execution or when transmitting orders, Henry Spain Investment Services Limited will consider the following:

• Your characteristics (including your regulatory client classification)
• The characteristics of the financial instrument concerned
• The execution venues we could use to carry out your order (i.e. – to which firms/entities we could transmit your order)

We will also make every effort to ensure the best possible result for you considering the following factors:

Price

For most liquid financial instruments price will be the overriding factor in our choice of execution venue, although for instruments such as collective investment schemes (i.e. – unit trusts/OEICs) price will not be a determining factor as these types of investment are ‘open ended’ investments whereby the fund manager can cancel/issue units based on the level of demand so are not as price sensitive.

Cost

When transmitting orders for execution we will also consider any ancillary costs associated with the execution of the order. Where we have recommended that you use a platform service to hold your investments, we will usually transmit orders for any collective investments to that platform rather than transmitting orders directly to the individual fund managers.

Where we transmit orders for instruments that are exchange traded (e.g. – ETFs, investment trusts), where available via any platform on which you already hold investments this will be our preferred execution venue. Where this is the case, we will rely on the platform obtaining the best execution possible based on the brokers/entities to which it ultimately passes the order for execution.

In circumstances where orders are transmitted to another entity (e.g. broker) for execution the firms/entities we may send orders to are outlined below in the section entitled ‘execution venues’

Speed

Speed of execution may be important for some types of order or client. For example, speed will be a high priority for a retail client executing an order in frequently traded shares.

Speed is unlikely to be a consideration for investments that are not price-sensitive such as collective investment schemes and/or which are priced at single daily valuation points but in terms of meeting our obligations to act in our clients best interests we will transmit orders promptly and in a timely manner.

Likelihood of execution and settlement

In some instances, ensuring an order is executed may be the principle consideration when deciding to who we transmit an order for execution, for example where a financial instrument is rarely traded or illiquid. In these circumstances, this may mean that price may not be the crucial factor in the choice of entity to whom we transmit an order.

Size or nature of the order

The best price for certain securities or financial instruments may only be available for specific order quantities (e.g. – number of shares, units, contracts etc) and therefore we may not be able to obtain the best price where an individual clients order does not match these terms. As we will not be executing transactions directly we will not have control over this, although the firms/entities to which we transmit orders may be able to aggregate orders or transact your order in ‘stages’ to obtain the best terms available.

Certain investments will have a single price which is not affected by the size or nature of the order (e.g. units/shares in regulated collective investment schemes such as unit trusts and OEICs), although there may be instances where entities where which we transmit orders (e.g. – platforms) have access to share/unit classes with lower annual management charges because they are able to aggregate client orders. Where we transmit individual clients orders directly to fund managers we may not have access to these share classes.

Other considerations relevant to the order

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 we 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, we:

• May use a third-party broker to execute orders; or
• May trade as an agent

Execution venues

Investment Types	Execution Venues
Collective Investment Schemes & Investment Trusts (Unit Trusts/OEICs)	Raymond James Investment Services & A J Bell We may also transmit orders for units in collective investment  schemes directly to the relevant fund managers, rather than via a platform.
Exchange Traded Products (e.g – ETFs)	Raymond James Investment Services & A J Bell
Equities	Raymond James Investment Services & A J Bell
Debt instruments (e.g. – bonds, money market instruments)	Raymond James Investment Services & A J Bell
Structured Products	Raymond James Investment Service & A J Bell

All orders placed by Henry Spain Investment Services Limited are executed through the following routes:

Henry Spain Investment Services 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. Our 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, Henry Spain Investment Services 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.

Henry Spain Investment Services Limited will make all decisions as to where the orders are placed in relation to the execution venue. We will therefore not accept specific instructions from clients regarding the venue where your order is executed.

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 we arrange deals in collective investment schemes (e.g. Unit Trusts, OEICs), we may deal directly with the fund manager and/or the operator of the collective investment scheme or may arrange the deal through a third party.

Providers of Unit Trusts and OEICs generally calculate and set their prices once a day, in accordance with the Financial Conduct Authority requirements, over which we usually have little influence.

Charges

It is Henry Spain Investment Services Limited’s policy that our remuneration structure will not influence the selection of execution venues. We will not therefore discriminate between the execution venues we use to arrange execution of your orders. We will also choose what we believe to be the most suitable investment platform for the client among our preferred providers.

Monitoring and review of our execution policy

Henry Spain Investment Services 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 as will our execution policy and this will be at least annually.

Staff understanding

All our relevant employees are made aware of this policy to highlight and emphasise the importance of best execution.

If you require any further information on our ‘Best Execution Policy’, please contact Compliance@henryspain.co.uk