Best Execution for ‘Execution Only’ Transactions
Introduction
Under The Licensees (Conduct of Business) Rules 2009, Kleinwort Benson (Channel Islands) Limited ("Kleinwort Benson") is required to take all reasonable steps to obtain, when executing orders, the best possible result for our clients taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.
In order to achieve this Kleinwort Benson is required to establish and implement a Best Execution policy in order to achieve the best possible result when executing orders or receiving and transmitting orders for execution. This policy is in place to enable Kleinwort Benson not only to achieve the best possible result, but also to enable you to make a properly informed decision about whether to utilise the execution services offered by Kleinwort Benson.
General Obligations
Kleinwort Benson will ordinarily determine the best possible result in terms of total consideration, representing the price of the financial instrument and the costs related to the execution.
Notwithstanding the above, speed, likelihood of execution and settlement, the size and nature of the order and market impact may be given precedence over the immediate price and cost consideration, but only in so far as they are instrumental in providing the best result in terms of the total consideration to you.
This policy contains information regarding the different execution venues and the factors affecting the choice of execution venue. Kleinwort Benson has set out below information on our order execution arrangements and the criteria, which determine how Kleinwort Benson selects the different venues on which we may execute your order. Kleinwort Benson has also identified those venues on which we will most regularly seek to execute your orders and which we believe offers the best prospects for providing best execution. Kleinwort Benson will also assess, on a regular basis, the quality of execution afforded by those venues on which we execute your orders and whether we need to change the execution arrangements.
In selecting the most appropriate venues for the purpose of executing customer orders, Kleinwort Benson will take into full account the factors relevant to the order:
- What we reasonably assess to be your best interests in terms of executing your orders; and
- Such other factors as may be appropriate, including the ability of the venue to manage complex orders, the speed of execution, the creditworthiness of the venue and the quality of any related clearing and settlement facilities.
In selecting the best execution venues, Kleinwort Benson will not take into account the fees and commissions that such venue will charge its clients but the best venue for execution of the order from the client’s perspective.
Execution Venues
All transactions are executed in Guernsey through dedicated Dealing Teams.
Kleinwort Benson have assessed the execution venues available and identified those that will enable us, on a consistent basis, to obtain the best possible result for executing your orders.
Kleinwort Benson has market counterparties and approved brokers which it may access (depending upon currency and value).
A schedule of current market counterparties and approved brokers is available from us directly. This list is accurate at the time of distribution but may be changed from time to time.
Where we rely on best execution to be fulfilled by a third party, in the event that access is unavailable to a specific market using their own dealing avenues reasonable endeavours are made to ensure that the third party’s best execution policy is of a similar standard to our own.
Information on Order Execution Arrangements
Foreign Exchange (‘FX’)
Kleinwort Benson has access to and uses, indicative wholesale market rates from Reuters (widely accepted as the industry standard data source).
Specific Client Instructions
Executing against specific instructions is our normal policy. Where you give a specific instruction as to the execution of an order, the relevant part of the order will be executed in accordance with those instructions. You should be aware that provision of specific instructions may prevent Kleinwort Benson from taking the steps that they have designed and implemented to obtain the best possible result for the execution of such order in respect of the elements covered by those instructions.
General Terms of Order Handling
Kleinwort Benson is required under The Licensees (Conduct of Business) Rules 2009 to execute your orders in a prompt, fair and expeditious manner relative to other client orders. Kleinwort Benson will execute otherwise comparable client orders sequentially in accordance with the time of their receipt unless:
- Otherwise instructed by that other client; or
- The characteristics of the order or prevailing market make this impracticable;
Your order will not be carried out in aggregation with another client’s order unless:
- It is unlikely that the relevant aggregation of orders will work overall to the disadvantage of any client whose order is to be aggregated; and
- It has been disclosed to each client whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to a particular order
Review and Monitoring
The effectiveness of Kleinwort Benson’s execution arrangements (including this policy) will be monitored to identify and, where appropriate, correct any deficiencies. Kleinwort Benson will review 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 client orders on a consistent basis. Kleinwort Benson will inform you of any material changes to the execution arrangements or execution policy.
Consent
Kleinwort Benson is required to make details of the execution policy available to you. This will normally be provided as part of the application, categorisation and acceptance process. Once you order Kleinwort Benson to execute a transaction this will be construed as giving consent to this policy.