Best execution policy
Version 2026.1 | April 2026
1. Introduction
The focus of the Best Execution Policy is to ensure that we take all sufficient steps to provide best execution when placing orders on behalf of our clients, with third parties such as platforms, fund
managers or stockbrokers. This policy applies to orders in investments such as funds and other securities and should be read in conjunction with the Saltus Asset Management Terms and Conditions.
Compliance with this policy is mandatory for all individuals associated with the Saltus Group, and failure to adhere to its provisions may result in disciplinary action or termination of employment or partnership, as well as both legal and regulatory consequences.
2. Execution venues and third parties
An execution venue is effectively a trading venue, such as a regulated stock market, where investment transactions are executed.
We do not operate a single execution venue approach. We choose the execution venue based on which venue will most likely provide the best overall result for the client.
2.1 Types of financial instrument
The types of financial instruments that we may accept dealing instructions for are:
- Mutual funds such as unit trusts and open-ended investment companies (OEICs)
- Equities, including exchange traded funds and investment trusts
- Fixed interest securities including corporate bonds and gilts
- Private Equity investment
- Structured products (in limited circumstances)
2.2 Third parties
We’ll regularly assess the third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging the execution of client orders. For
more information on the execution venues used by the Group, please see Appendix B. Each third party we work with has responsibility for best execution and client order handling undertaken through them, and we assess their adequacy as part of our due diligence process. We’ll also undertake periodic monitoring to ensure that they continue to meet the relevant requirements.
3. Execution factors
When transmitting orders to a third party, we’ll make every effort to ensure the best possible result for our clients taking into account the following factors:
- Price
- Cost
- Speed
- Likelihood of execution and settlement
- Size
- Nature of the order
- Any other considerations relevant to the execution of the order
3.1 Relative Importance
In determining the relative importance of the execution factors, we will use our commercial judgement and experience in the light of the market information available and take into account the
following characteristics:
- The client
- The order
- The financial instruments that are the subject of the order
- The execution venues to which that order can be directed
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. We’ll therefore assume that this is the most important outcome for your transaction unless you tell us otherwise.
There may be occasions where we will change the priorities given to the execution factors, and other factors other than prices and cost should take precedent to achieve the best possible outcome for the client. For example, in times of severe market disruption or in the event if a system outage, speed and certainty of execution and settlement may be prioritised. In such circumstances, we will follow the process and procedures in place and will consider whether or not our ability to continue trading has been materially affected by such disruptions.
Saltus may, in limited circumstances, charge clients a transaction-based commission in addition to passing on the cost of executing the trade. Please refer to the Saltus Platform terms and conditions, and fee schedule for more detail.
3.2 Client specific instructions
If we receive instructions where price is not the most important factor execution, we’ll make every effort to comply with these instructions but cannot guarantee this. This may be due to either the nature of the order, or the type of investment being traded. If we are able to comply with such instructions, this may prevent us from obtaining the best possible results for the execution of such an order.
We’ll make all decisions as to where the orders are placed and may not accept specific instructions from clients regarding which third parties to use.
3.3 Charges
Commission and charging structures do not influence either the selection of third parties to which we place client orders, or the order flow that follows as a result of the execution process.
Appendix A – Scope, objective and ownership
Scope and Application
This policy applies to all UK regulated firms within the Saltus Group including, but not limited to:
- Saltus Financial Planning Limited (“SFP”)
- Saltus Partners LLP (“SPLLP”)
- Saltus Partnership Limited (“SPL”)
- Saltus Wealth Partnership Limited (“SWPL”)
This policy applies to all employees, partners, contractors, and entities within Saltus Group and governs all activities related to referrals and introductions by third-party introducers.
Policy Objective
The purpose of this policy is to establish the Groups approach to best execution, ensuring that we take all reasonable steps to achieve this when carrying out transactions on behalf of our clients.
Ownership and Review
This policy is owned by the Chief Compliance Officer. The Saltus Operating Board (“SOB”) will review this policy annually to ensure it remains fit for purpose or if there are any material changes required.
This policy is next due for review by April 2027.
Appendix B – Entity specific information
Saltus Partners LLP (“SLLP”)
SLLP may execute client orders:
- Using a broker supplied electronic trading product (algorithm) designed to access multiple execution venues and /or trade in line with a benchmark i.e. Volume Weighted Average Price (“VWAP”)
- With a third-party investment firm, brokers with whom we have entered into an agreement for handling orders
- For investments held on the Saltus Platform, client orders may be placed directly with the custodian, Multrees Investor Services, for onward execution. Multrees are connected electronically to a range of retail service providers (“RSPs”) to execute your trade.
At Saltus our dealers have access to a range of execution venues via approved counterparties to facilitate best execution for our clients. Counterparties, including the custodian, are reviewed regularly by our Investment Committee to ensure we have sufficient relationship and coverage for our clients.
We may use the following counterparties, to execute your instructions:
- Panmure Liberum
- Deutsche Bank
- Goldman Sachs
- Singer Capital
The brokers above are, or have access to, MTFs (multilateral trading facilities)/systematic internalisers or market makers.
Saltus Financial Planning Limited (“SFP”), Saltus Partnership Limited (“SPL”), Saltus Wealth Partnership Limited (“SWPL”)
SFP, SPL and SWPL do not execute orders or deals directly with execution venues. Instead, these entities place orders on behalf of our clients with appropriate third parties:
- Investments on a platform (SFP only): For investments held on our preferred platform (an online investment administration service), client orders will be placed directly with the relevant
platform. Our preferred platform is the Saltus platform (which is custodied by Multrees Investor Services) - Investments not on a platform: For SPL and SWPL, and in some instances for SFP, we may use alternative platforms, subject to the requirements of our clients. For investments held directly with individual fund managers, client orders will be placed directly with the relevant fund manager for the particular investment. We can provide a list of alternative platforms upon
request.