Best execution policy

Version 7.0 February 2025

1.       Introduction

It is in the interests of our clients, and our firm that we obtain the best possible result when placing orders for execution on behalf of our clients, with third parties such as platforms, fund managers or stockbrokers. We are required to take all sufficient steps to provide best execution when carrying out such transactions and, on your request, to provide you with a copy of the policy that we have adopted to achieve that objective.

1.1 Policy objective

The objective of this Policy is to have a clear process in place to ensure we take all reasonable steps to provide best execution when carrying out transactions and to ensure all clients of Saltus are treated fairly.

1.2 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 (“SLLP”)
• Saltus Partnership Limited (“SPL”)
• Saltus Wealth Partnership Limited (“SWPL”)

This best execution 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.

1.3 Ownership

This policy is owned by the Chief Compliance Officer and will be reviewed by the Saltus Operating Board (SOB) annually to ensure it remains fit for purpose.

2.     Execution venues and third parties

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

2.2 What is an execution venue?

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 policy. We choose the execution venue based on which venue will most likely[KB1]  provide the best overall result for the client.

2.3 Execution venues and third parties

2.3.1 Saltus Partners LLP (“SLLP”)

We 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 VWAP (Volume Weighted Average Price).
• 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 Gordon
• Deutsche Bank
• Goldman Sachs
• Singer Capital

The brokers above are, or have access to, MTFs (multilateral trading facilities)/systematic internalisers or market makers.

2.3.2 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, we’ll place orders on behalf of our clients with appropriate third parties as explained below:

• Investments on a platform: 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).

In some instances, we may use alternative platforms, subject to the requirements of our clients. We can provide a list of alternative platforms upon request.

• Investments not on a platform: For investments held directly with individual fund managers, client orders will be placed directly with the relevant fund manager for the particular investment.

2.3. 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 your orders. The above list will then be updated, where necessary, following such assessment.

The third parties have responsibilities in relation to best execution and client order handling themselves and we assess these for adequacy as part of our third party due diligence process. We’ll also undertake periodic monitoring to ensure that they’re meeting the relevant requirements.

2.          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

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.

3.          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

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 (please refer to the Saltus Platform terms and conditions, and fee schedule) in addition to passing on the cost of executing the trade.

4.          Client specific instructions

If you’ve given instructions where price is not the most important factor in executing your instructions, we’ll 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 investment you wish to trade in.

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.

If we do accept any client specific instructions, you should be aware that this may prevent us from following the processes set out in this policy which have been designed to obtain the best possible results for the execution of those orders in respect of the elements covered by those specific instructions.

5.           Charges

It’s our policy that commission and charging structures won’t 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. We’ll therefore not discriminate between the third parties used to arrange execution of your orders.

6.          Monitoring and review of our execution policy

We’ll regularly monitor the effectiveness of our best execution policy to identify and, where appropriate, correct any deficiencies. In particular, this will cover the third parties to which we transmit client orders in terms of their quality of execution.

This review will be carried out regularly (on at least an annual basis) or whenever a material change occurs that affects our ability to continue to obtain the best possible result for our clients.

7.            Staff understanding

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