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.

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. 

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, Tatton Blended and Sinfonia Fund Ranges we submit orders to Valu-Trac as Authorised Corporate Director and rely on their best execution policy. 

For the Verbatim Funds managed by Tatton we submit orders to Waystone 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. 

For ETF trading, Tatton places orders using our ACDs. We discuss implementation of large trades with fund managers in advance to understand the most cost effective/efficient way of trading given our goals for the trade. Tatton will ensure that ACDs have access to appropriate trading venues and sufficient counterparties to facilitate competitive quotes for trades. On a quarterly basis Tatton will review the achieved prices from these trades at ICM to monitor performance and parties to the trading process.

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