Order Execution Policy

 

It is important that you read this policy as we will deem that you agree to the terms of the policy and our Dealing Policy when you request us to act on your behalf.

 

All instructions are acted upon at our sole discretion and we may refuse to accept any dealing instruction without giving a reason. We draw your attention in this regard to regulatory rules on tipping off where, for example, we may suspect financial crime or where we are acting upon the instructions of proper authorities such as regulators or law enforcement agencies.

 

Mayfair Capital Limited (“Mayfair”) order execution policy complies with the Markets in Financial Instruments Directive II (“MiFID II”) and the associated regulation MiFIR. Part of our method of achieving this is through our Order Execution Policy that is summarised here and which we will abide by when handling any standard dealing instructions from investors or instructing parties.

 

Our Order Execution Policy must be read in the context of our Dealing Policy and our Conflict of Interest Policy, and our General Terms and Conditions of Business, all of which are usually available in their most up to date forms on our website www.mayfair-capital.co.uk The most up to date versions that we have published always apply. FCA regulatory rules and appropriate legislation and relevant European Union directives (or UK equivalents) also apply. We may update or amend our Order Execution Policy at any time and without notice for reasons of compliance and risk management or any appropriate commercial purpose and any such amendment will supersede previous policies.

 

Best execution requirements apply to all financial instruments as listed in the Annex I of MiFID II, section C. The Firm has permission to carry out regulated activities allowing the Firm to execute and transmit client orders in these instruments in accordance with this policy.  For further information on the Firm’s permitted regulated activities please see the FCA register at https://register.fca.org.uk/s/firm?id=0014G00002VooSTQAZ

When you instruct, or request us to buy or sell an investment, we will take all sufficient steps to obtain, the best possible result for you.  To achieve this, we will consider the execution factors summarised below:

 

  • The characteristics of your client classification (retail, professional or eligible counterparty)
  • The characteristics of the financial instrument
  • Price, cost, speed and likelihood of execution and settlement
  • The type of order, its size, and its nature, including where the order involves securities financing transaction (SFT)
  • The execution venues on which it can be dealt (‘execution venue’ includes a regulated market, an MTF, an OTF, a systematic internaliser, or a market maker or other liquidity provider or an entity that performs a similar function in a third country to the function performed by any of the foregoing)
  • Whether there is a liquid market for the instrument
  • Plus, any other factors that we are aware of or are made aware of that seem to us to be relevant to the execution of the order request or instruction.

 

In the absence of specific instructions from you, we will determine in our sole judgement the relative importance of these factors by judgement, experience in the light of market information available, and by considering any other execution factors. All executions will also adhere to our dealing policy. Judgements are determined by us by reference to information available to us at the time of trade or just before the time of trading. Hindsight is not pertinent to this where factors were not apparent or available to us, or when clients or instructing parties withhold relevant or potentially relevant information from us.

 

When in receipt of specific execution instructions, we will action them so far as reasonably possible and we will be treating this as providing you with best execution. Such instructions may prevent us from following the steps for obtaining the best possible result as outlined in this policy

 

Mayfair Capital Limited acknowledges when executing an order on behalf of retail and professional clients, the best possible result must be determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution, which must include all expenses incurred by the client which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. This, however, should not be considered the sole determining factor. In some circumstances, for some clients, speed, likelihood of execution and settlement, the size and nature of the order, market impact and any other implicit transaction costs may be given precedence over the immediate price and cost consideration only insofar as they are instrumental in delivering the best possible result in terms of the total consideration of the order.

 

Total Consideration

Total Consideration is defined as the sum of the price and the costs incurred by the client and it represents the price of the financial instrument and all costs associated with the execution of client’s order including execution venue fees, clearing and settlement fees, and any other fees paid to third parties involved in the execution of the order.

Eligible counterparties

This policy does not apply to Eligible Counterparties where carrying out Eligible counterparty business and as such, the Firm does not owe best execution to transactions undertaken by clients classified as such.

The Firm will use third party platforms all of which are regulated in their respective jurisdiction which are detailed in their Terms of Business and can be found on the website www.mayfair-capital.co.uk.

Regulated Markets we will use:

All UK exchanges

All European Markets

All US markets

All Major Asian Markets

When selecting venues, the Firm reviewed the following:

  • Standard corporate documentation available on Companies House such as incorporation, directors and accounts
  • FCA Register
  • News and reputation
  • T&C
  • Services to be provided
  • Controls and availability of Assurance Report
  • Meetings and visits

 

Inducements

 

Mayfair Capital Limited officers and employees are not allowed to accept gifts, entertainment or any other inducement from any person which might benefit one customer at the expense of another when conducting investment business. Mayfair Capital Limited gifts and entertainment policy is maintained and monitored by Compliance for the purpose of ensuring that the Firm always act in the best interests its clients.

 

Client instructions

Where the client provides the Firm with specific instruction in relation to an order, or any particular aspect of that order, including an instruction for the trade to be executed on a particular venue, the Firm will execute the order in accordance with the client’s instruction.

The Firm will take all the steps it has designed in this policy to obtain the best possible results for the client in respect of the order, or aspect of the order, not covered by the specific instruction. It is, however, possible that the specific instruction may prevent the Firm to take all the steps it has designed in its order execution policy to obtain the best possible results in respect of the elements of the order not covered by the specific instruction.

Where the client provides the Firm with specific instruction in relation to an order, the Firm will also transmit the specific instruction to the entity to which the order is transmitted in order to ensure that the other entity will execute the order in accordance with the client’s instruction. It is, however, possible that the specific instruction may prevent the other entity to take all the steps it has designed in its order execution policy to obtain the best possible results in respect of the elements not covered by the specific instruction.

 

Material Changes

The Firm will notify clients of any material changes to its order execution arrangements or order execution policy as described above by posting the information on its website.

 

NO FIDUCIARY RELATIONSHIP

The Firm’s commitment to providing clients with “best execution” does not mean that it owes clients any fiduciary responsibilities over and above the specific regulatory obligations placed upon it or as may be otherwise contracted between the Firm and clients.

Clients remain responsible for their own investment decisions and the Firm will not be responsible for any market trading loss clients suffer as a result of those decisions.

 

Breaches of Order Execution Policy

Any breaches of the Order Execution Policy will be recorded on the Firm’s breach log in conjunction with its regulatory breach policy.