Best execution policy

Top 5 Execution Venue Report 2020 – Client Dealing execution

Part 1: Top five entities used for the transmission or placing of client
orders

Where we send investment applications or orders on your behalf to third parties (for example, to buy or sell investment holdings), we make every effort to ensure the best possible result for our clients. This is referred to as best execution. In arranging for the execution of your order:

  • We may place the order via a third party broker or platform (an online investment administration services) to execute your order
  • We may place the order directly with a fund manager

We’re obliged to disclose on an annual basis the top 5 investment firms that we send our client orders to. The tables below relate to the calendar year 2020. Our clients are all classed as retail clients.

100% of our “Other instruments (includes collectives investments)” are placed via Multrees Investor Services (LEI: 213800KPD9LZ8ZFP1X08). A breakdown of the top 5 venues for the underlying client portfolio trades can be seen below:

 

Class of Investment Other instruments (includes collectives investments)
Notification if <1 average trade per business day in
the previous year
Yes
Top 5 Venues ranked in terms of volume (descending
order)
Proportion of volume transmitted as a percentage of
total in that class
Proportion of orders transmitted as a percentage of
total in that class
1 S&W Saltus Global Equity FundLEI: 2138001W7BX44Q6AAW53 12.2% 2.9%
2 Legal & General Cash FundLEI: 2138004W4IS3AHH78Y26 7.8% 5.7%
3 Fidelity Institutional Liquidity fund GBPLEI: 549300F7SB0QYNXNG825 7.7% 4.9%
4 M&G – Global Macro Bond FundLEI: 549300R8FGIWC884LP39 6.6% 1.6%
5 S&W Saltus Fixed Income FundLEI: 213800A4WWM4X9WQC787 6.2% 2.5%

 

Class of Investment Equities
Notification if <1 average trade per business day in
the previous year
Yes
Top 5 Venues ranked in terms of volume (descending
order)
Proportion of volume transmitted as a percentage of
total in that class
Proportion of orders transmitted as a percentage of
total in that class
Percentage of Passive Orders Percentage of Aggressive Orders Percentage of Directed Orders
1 Multrees Investor ServicesLEI: 213800KPD9LZ8ZFP1X08 63.8% 96%
2 LiberumLEI: 213800U6KUF87S1KCC03 29.9% 2%
3 NumisLEI: 213800P3F4RT97WDSX47 5.5% 1%
4 GoldmanLEI: W22LROWP2IHZNBB6K528 0.9% 1%
5
  • Please note that the data reported here represents only a small percentage of our overall business
  • As the data here relates to only a very small number of cases, for this type of investment we usually only send orders to one firm

 

Class of Investment Bonds
Notification if <1 average trade per business day in
the previous year
Yes
Top 5 Venues ranked in terms of volume (descending
order)
Proportion of volume transmitted as a percentage of
total in that class
Proportion of orders transmitted as a percentage of
total in that class
Percentage of Passive Orders Percentage of Aggressive Orders Percentage of Directed Orders
1 City & Co2138005IBYJDKUZMN564 83% 50%
2 Multrees Investor Services213800KPD9LZ8ZFP1X08 17% 50%
3
4
5

 

  • Please note that the data reported here represents only a small percentage of our overall business
  • As the data here relates to only a very small number of cases, for this type of investment we usually only send orders to one firm

Part 2: Monitoring and Review

  • We operate in accordance with our best execution Please ask, if you want to see a copy of our policy.
  • Under the terms of our policy, we 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 arrangingfor the execution of your orders.
  • The third parties that we use, also have responsibilities in relation to best execution and client order handling. We undertake periodic monitoring to make sure that they continue to meet our requirements. This review is carried out at least annually or whenever a significant change occurs that we feel could affect our ability to continue to obtain the best possible results for our clients.
  • There are no close links, conflicts of interest or common ownership with respect to any of the firms we pass orders to.
  • There have been no changes to platforms or brokers used during the period reported.
  • The large majority of our investment business is conducted through investing directly in other OEICS via the relevant fund manager/administrator. These investments are at a single price and are by definition deemed to comply with our Best Execution Policy.
  • When placing orders for execution, we will seek to obtain the best possible result taking into account the range of execution factors specified by MiFID, namely:
    • the execution price;
    • the execution costs;
    • the execution speed;
    • the likelihood of execution and settlement;
    • the size of the order to be executed;
    • the nature of the order to be executed; or
    • any other consideration relevant to the execution of the order including implicit costs, availability of liquidity, market impact and where appropriate, availability of credit lines
    • In the absence of specific instructions we will exercise our sole discretion in determining which factor or combination of factors will be relevant to achieve the best result.

Within these factors price will usually be accorded relatively greater importance although in the case of less liquid securities or financial instruments, or in more volatile market conditions other factors may need to be afforded relatively more weight to achieve the best outcome for you.

Top 5 Execution Venue Report 2020 – In house Fund dealing

Part 1: Top five entities used for the transmission or placing of client orders

Where we send investment applications or orders on your behalf to third parties (for example, to buy or sell investment holdings), we make every effort to ensure the best possible result for our clients. This is referred to as best execution. In arranging for the execution of your order:

  • We may place the order via a third party broker or platform (an online investment administration services) to execute your order
  • We may place the order directly with a fund manager

We’re obliged to disclose on an annual basis the top 5 investment firms that we send our client orders to. The tables below relate to the calendar year 2020. Our clients are all classed as retail clients.

Class of Investment Other instruments (includes collectives investments)
Notification if <1 average trade per business
day in the previous year
Yes
 

Top 5 Venues ranked in terms of volume (descending
order)

Proportion of volume transmitted as a percentage of
total in that class
Proportion of orders transmitted as a percentage of
total in that class
1 Artemis Funds (LUX) US Extended Alpha (549300HMOLY35UJG8Y31) 11.2% 5.4%
2 Fidelity Index US P (54930081UPGUR4ZZBM56) 10.3% 3.2%
3 Polar Capital Funds PLC – UK Absolute Equity Fund
(549300PEFBYPHCSXR068)
5.2% 3.2%
4 KLS Sloane Robinson Emerging Markets
(635400JVQPIXHEW9JX19)
4.5% 3.8%
5 Allianz Strategic Bond Fund (529900UKCDRMO9GNPV27) 4.1% 3.2%

 

Class of Investment Equities
Notification if <1 average trade per business day in
the previous year
Yes
Top 5 Venues ranked in terms of volume (descending
order)
Proportion of volume transmitted as a percentage of
total in that class
Proportion of orders transmitted as a percentage of
total in that class
Percentage of Passive Orders Percentage of Aggressive Orders Percentage of Directed Orders
1

Liberum (213800U6KUF87S1KCC03)

100.0% 100.0% 100.0%
2
3
4
5

 

  • Please note that the data reported here represents only a small percentage of our overall business
  • As the data here relates to only a very small number of cases, for this type of investment we usually only send orders to one firm
Class of Investment Bonds
Notification if <1 average trade per business day in
the previous year
Yes
Top 5 Venues ranked in terms of volume (descending
order)
Proportion of volume transmitted as a percentage of
total in that class
Proportion of orders transmitted as a percentage of
total in that class
Percentage of Passive Orders Percentage of Aggressive Orders Percentage of Directed Orders
1 N/A 0.00%
2
3
4
5

 

  • Please note that the data reported here represents only a small percentage of our overall business
  • As the data here relates to only a very small number of cases, for this type of investment we usually only send orders to one firm

Part 2: Monitoring and review

  • We operate in accordance with our best execution Please ask, if you want to see a copy of our policy.
  • Under the terms of our policy, we 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 for the execution of your orders.
  • The third parties that we use, also have responsibilities in relation to best execution and client order handling. We undertake periodic monitoring to make sure that they continue to meet our requirements. This review is carried out at least annually or whenever a significant change occurs that we feel could affect our ability to continue to obtain the best possible results for our clients
  • There are no close links, conflicts of interest or common ownership with respect to any of the firms we pass orders to
  • There have been no changes to platforms or brokers used during the period reported
  • The large majority of our investment business is conducted through investing directly in other OEICS via the relevant fund manager/administrator. These investments are at a single price and are by definition deemed to comply with our Best Execution Policy
  • When placing orders for execution, we will seek to obtain the best possible result taking into account the range of execution factors specified by MiFID, namely:
    • the execution price;
    • the execution costs;
    • the execution speed;
    • the likelihood of execution and settlement;
    • the size of the order to be executed;
    • the nature of the order to be executed; or
    • any other consideration relevant to the execution of the order including implicit costs, availability of liquidity, market impact and where appropriate, availability of credit lines
    • In the absence of specific instructions we will exercise our sole discretion in determining which factor or combination of factors will be relevant to achieve the best result.

Within these factors, price will usually be accorded relatively greater importance although in the case of less liquid securities or financial instruments, or in more volatile market conditions other factors may need to be afforded relatively more weight to achieve the best outcome for you.

Saltus Asset Management is a trading style of Saltus Partners LLP which is authorised and regulated by the Financial Conduct Authority and is incorporated as a limited liability partnership registered in England and Wales. Registered office: Solent Business Park, 4500 Parkway, Whiteley, Fareham PO15 7AZ. Registered number: 308328. VAT number: 843472226

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