Best Execution Policy
As a regulated firm DJWM Ltd is required by the Financial Conduct Authority (FCA) to put in place a Best Execution Policy to ensure when transmitting orders on your behalf that we take all suitable steps to achieve the best possible result for you.
For the great majority of our clients we refer all trades through our recommended Custodian, Raymond James. We therefore rely on Raymond James’s own Best Execution Policies and procedures in so far as they are carrying out any orders on your behalf. However, to meet your best interests, we regularly scrutinise and review their processes and effectiveness, and if we were to consider that they were not achieving the best possible result we would report to you and consider other options.
For sales and purchases that are for securities quoted outside the United Kingdom, or are above normal market size, Raymond James dealers will use their discretion in placing the trade. The execution venue that they will use will depend on the exact nature of the trade, but will typically be executed through Stifel, Winterflood Securities Limited, Instinet Limited or Peel Hunt LLP. These market makers have been selected by Raymond James according to the criteria outlined below.
A small number of our clients have decided to directly appoint their own Custodians. Where this happens, we rely on those Custodians to ensure best execution on your behalf. Here the dealing arrangements are out with our control, and we will only comment on them if requested to do so by you.
The execution factors that we will take into account are:
- Cost/Commission of transaction
- Client category
- Size and complexity of the order
- Speed of execution
- Likelihood of execution and/or settlement
- Characteristics of the order
DJWM Ltd has determined that, in almost all cases, the most important factor affecting best execution for our clients custodied with Raymond James is the cost of the trade to the client (i.e. the price, plus any fees, commissions and third-party charges).
DJWM Ltd.’s policy on timely execution is that trades should be placed as soon as reasonably practicable on receipt from the client.
If we are proposing a deal for both our advisory and discretionary managed clients, we will not delay dealing on behalf of our Discretionary Managed clients until consent is obtained from our advisory managed clients unless, in our opinion, all our clients will benefit from the aggregation of the orders.
For discretionary clients, the relevant time is the time at which we reach a decision. For advisory clients, the relevant time is the time we receive your consent.
Customer Order Priority
DJWM Ltd will deal for customers in the order in which their orders are received. Where we decide to deal for all discretionary customers in a similar manner, these trades will be allocated in order that all clients benefit from price improvements that may be available to more substantial orders. Similarly, we will aggregate dealer initiated trades if this is to your advantage. However, you should be aware that in volatile markets this may not be possible.
Clients who give specific instructions
You may, on occasion, give a specific instruction relating to an order (execution-only). If this is the case, we are relieved of the duty of best execution, but only to the extent that it relates to an execution-only deal
We are forbidden from persuading you to execute an order in a particular way.
We will keep a record of the fact that you have directed the order. We are required to disclose to you that the execution-only instruction may prevent us (including Raymond James) from achieving the best outcome for you. However, as this warning is contained in Raymond James’ Terms of Business, it does not have to be given on a case-by-case basis.
Circumstances where best execution may be achieved outside the best execution policy
There are a number of circumstances in which the fact that execution took place is evidence of best execution. These include:
- Collective investment schemes that are traded directly with the fund manager
- Over-the-counter derivative trades (available on US platform only)
- Some structured products
- Exchange traded stocks with limited liquidity (e.g. AIM stocks with a single market maker)
However, at the present time, DJWM Ltd does not trade any of the above-mentioned products, except for the collective investment schemes.
Churning and Switching
DJWM Ltd will not enter into transactions of an unnecessary frequency (“churn”) or switch between packaged products unless we can demonstrate that we have taken reasonable steps to ensure that the deal or switch is suitable for you.
You can learn more about Raymond James’s best execution policy by reading their Execution Policy. The procedure may help you further understand the process used to analyse the quality of execution obtained and as to how Raymond James monitors and verifies that the best possible results were obtained for its clients.
Please follow this link for details:
V1/ Rev.3 September 2021