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: https://tattoninvestments.com/order-execution-policy/
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.
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.
Order execution factors
Order execution factors include the following:
- 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.
Tatton aims to take 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. Before we engage a third party to execute them Tatton will always conduct robust due diligence on the third party and where required will monitor their performance in relation to this.
By transmitting an order to another party for execution, Tatton will place reliance on that other party. This means Tatton’s best execution obligation will have indirect application. Tatton annually reviews the governance of ‘any third- party’s execution policy to ensure they meet both the regulators and Tatton standards.
Tatton – Model Portfolio Service
In its role as a discretionary investment portfolio manager offering a portfolio management service exclusively to clients who hold their investments through a UK adviser investment (wrap) platform, Tatton invests in Collective Investment Schemes (CIS). These are financial instruments so technically fall under the best execution requirements; however, the portfolio trades are in open ended funds and not exchange traded. Orders are usually arranged directly with a third-party product provider or their appointed administrator.
The CIS is the only venue in which to transact orders. An individual CIS will state in its prospectus the way subscriptions and / or redemptions can be purchased / made. This information will include how frequently liquidity will be provided, the time frames for the calculation of the net asset value and receiving orders. All orders will be executed directly with the CIS in question. All activities are undertaken per the requirements set out in the FCA Collective Investment Schemes (COLL) handbook.
All portfolios managed by us are held on UK adviser investment (wrap) platforms as Tatton is not permitted to hold or control client monies or assets.
In most instances, Tatton places its trading instruction(s) at the model portfolio level using the platform portfolio trading capability. Consequently, trade execution and custody of assets is entirely under the control of the respective platform and Tatton cannot be held responsible for any third- party failures.
Tatton – Funds
In its role as an investment manager of UK mutual funds, regulated by the FCA under the UK’s Non-UCITS Retail Scheme (NURS) rules, the FCA best execution requirements do apply.
In respect of the Tatton Oak and Tatton Blended Fund Ranges we submit orders to Valu-Trac as Authorised Corporate Director and rely on their best execution policy.
For the Sinfonia Fund Range, we submit orders to IFSL as Authorised Corporate Director and rely on their best execution policy.
Throughout the execution of orders Tatton cannot be held accountable for any third-party failures.
Tatton will ensure that it maintains the Financial Conduct Authority regulatory permissions required to permit trading as a Discretionary Fund Manager and will actively monitor compliance with its Order Execution Policy. We will regularly, and at a minimum, annually review the policy and notify you of any material changes.
Tatton – AIM portfolio
Tatton also offers an Alternative Investment Market (AIM) portfolio service to retail clients. The portfolios are held on UK adviser investment (wrap) platforms where trading takes place using the platforms preferred broker. Custody of assets is also arranged through the platform.
In most instances, Tatton places its trading instruction(s) at the model portfolio level using the platform portfolio trading capability. The platform will then send the aggregated instructions to its preferred broker who will action them according to the agreed and contractual (between platform and broker) Best Execution Policy. Consequently, Tatton is not directly responsible for the trading execution on client portfolios as it must adhere to, the platforms ‘Best Execution Policy’ for all the AIM trades. This responsibility is carried out by the relevant platform dealing desk from orders placed by Tatton.
Tatton will, during normal trading, give guidance pertaining to prices to the platform’s dealing desk in the form of limit orders and direct discussions with the dealing desk.
Tatton views best execution in a holistic way in the context of the whole portfolio and not purely on a single trade by trade basis. Best execution, in this context, can only be achieved through single bulk orders that are directed by Tatton due to the nature of certain trades, such as illiquidity. Single bulk orders will ensure the fair and equal treatment of all clients across all portfolios and platforms as well as limit unnecessary disruption across client portfolios.
Where Tatton, as the discretionary manager, initiates, and sources a transaction and directs the trade to the relevant dealing desk then the best execution duties will be transferred to Tatton and the best execution factors will be adhered to as set out below.
When orders are placed, the same execution factors as for funds and the model portfolio service are considered.
Tatton will generally give price a higher relative importance but will also consider the other execution factors noted above to obtain Best Execution which may not result in the best available price. Other considerations may include the liquidity of the market which may make it difficult to execute an order. Tatton cannot be held responsible for any failures in third parties or messaging infrastructure during the execution of orders.
Market abuse e.g. Front-Running is explicitly prohibited, and Tatton has a Personal Account Dealing policy in place to mitigate the risk of this activity occurring.
The AIM Investment Market is the only execution venue available for AIM stocks.
Tatton will actively monitor compliance with its Order Execution Policy which will be reviewed at least annually.