This Order Execution Policy Summary sets out the approach that Tatton Investment Management Limited (Tatton) take to achieve the best possible result for our investors. We treat all investors with honesty, fairness, and professionalism and always in their best interests.

All Tatton clients are classified as retails clients for achieving best execution.

This policy should be read in conjunction with other contractual information.

This document provides information about our Order Execution Policy as required by the Market in Financial Instruments Directive (MiFID and MiFID II) and the Financial Conduct Authority (FCA) under COBS 11.2A.22R.

This policy is available directly from us upon request or online at:


Our responsibility for best execution applies when we are:

  •  Executing an order in a financial instrument or 
  • Transmitting an order in a financial instrument to another party for execution during:
    • Portfolio management
    • Investment activities as an investment manager of an undertaking for collective investments in transferable securities (‘UCITS Fund’) 
    • Investment activities as an alternative investment fund manager and
    • Carrying out an order provided by an investor. 

Financial instruments include:

  • Shares in companies, securitised debt and bonds, warrants, options, futures and convertible bonds, securitised cash settled derivatives and shares in investment trusts. 
  • Money Market instruments
  • Units or shares in alternative investment funds and UCITS Funds 
  • Certain options, futures, swaps and forward rate agreements (including foreign exchange forward transactions) 
  • Derivative instruments for transferring credit risk; and 
  • Financial contracts for difference and structured products. 

Order placement

Due to the nature of our business, orders are typically generated by investments, disinvestments or an adjustment to the investments selected by the Tatton investment team on a discretionary basis.

Order are typically placed to be executed at the same time. Due to different operational conditions across different third parties Tatton works with, Tatton may stagger implementation across different third parties with the aim of providing equivalent outcomes to clients of the firm.


Units in collective investment schemes can only be executed with the fund’s management company. When we submit an order, ordinarily via a third party, we send the order to the fund manager for execution at the next valuation point. Most funds are priced once a day at the ‘Assured Valuation Point’ (AVP), when its assets are valued and the unit price set. Most funds will have a cut-off time before the AVP by which orders need to have been placed with the fund house, any order placed after this time will be dealt at the next AVP. Provided all deals are executed at the same time, all investors will receive the same outcome.

For all other asset classes, Tatton will transmit orders via a third party. Tatton will conduct robust due diligence on any third party who orders are routed to, and where required will monitor their performance. Tatton reviews the governance standards and best execution policies of all parties orders are transmitted to on an annual basis.

Tatton takes all sufficient steps to obtain the best possible result for its clients on a consistent basis but relies on other FCA regulated parties for the execution of these. By transmitting an order to another party for execution, Tatton will place reliance on that party. Tatton’s best execution obligation will have indirect application.

Order execution factors

Order execution factors include the following:

  • price,
  • cost,
  • speed of execution,
  • likelihood of execution and settlement,
  • size and nature of the order and
  • any other consideration relevant to the execution of the order. 

The relative importance of these criteria will be judged on an order by order basis, but will typically give precedence to price and cost, or total consideration when executing orders for retail clients.

Order aggregation

We may combine client orders. Client orders may only be aggregated where Tatton deems the aggregation of the purchase or sale of the same security to be in the best interests of two or more of its portfolios. In relation to a particular order, the effect of aggregation may disadvantage portfolios, although all reasonable steps will be taken to protect the interests of all clients.

Tatton will actively monitor compliance with its Order Execution Policy which will be reviewed at least annually.