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Compliance

ORDER EXECUTION POLICY

Introduction

Under the Markets in Financial Instruments Directive (“MiFID II”) and the Financial Conduct Authority (FCA) rules, we have an obligation to take all sufficient steps to obtain the best possible result for our clients when executing orders, or transmitting orders to other financial institutions for execution. This is known as “Best Execution”.

This Order Execution Policy (“Policy”) provides information on how KW Investment Management and KW Trading, together “KW”, intends to comply with this obligation and implement effective arrangements to enable us to obtain the best possible result for our clients.

Scope

This policy applies to Retail and Professional clients of EIM and covers any transaction conducted in financial instruments falling under the scope of MiFID II (Equities, Fixed Interest, Exchange Traded Funds, Collective Investment Schemes, Derivatives, Forward FX and Structured Products):

Executing Orders

Subject to any specific instructions that you may give us, we will take all sufficient steps to obtain the best possible result when executing or transmitting orders for execution.

This will generally be the total consideration (price and related execution costs) paid by/to a client. However, in certain circumstances (see Execution Factors) we may decide that other execution factors are more important than price and cost in determining the best possible result.

As the attainment of similar end investment performance for all clients within the same investment strategy is important to us, we may aggregate orders if we reasonably believe that this will work to the advantage of our clients (for example achieving a better price through benefits of scale). We will not aggregate orders if we consider that this is likely to disadvantage our clients, however, on some occasions the effect of aggregation may be disadvantageous.

Transmission and execution of orders:

• Where we are appointed Discretionary Manager orders will be executed or transmitted at our discretion.

• Where we are acting on a client instruction, the order will be executed or transmitted as soon as practicably possible following receipt.

• We execute or transmit orders as agent only (i.e. we facilitate our clients, we do not purchase from/sell to our clients from our own account).

• Orders are dealt with in the order that they are received by KW.

Where we transmit an order to another entity we will take all reasonable steps to achieve the best possible result in line with this policy.
Specific Instructions

Where we receive a specific instructions from you, this may prevent us (or the entity to which we transmit the order) from achieving the best possible result in respect of the elements of the order covered by those instructions.

Execution Factors

We will take into account various factors to determine how an order should be dealt to achieve the best possible result, including:

• Price – this will usually be considered the most important factor in achieving best possible result.
• Cost of transaction – we will always asses the charges made by Execution Venues.
• Speed of execution – the price of liquid securities can move quickly and a delay in execution may cause a detrimental price to that expected being achieved.
• Likelihood of the execution or settlement – there may not be multiple trading venues/competing prices in relation to some illiquid securities therefore actually being able to buy/sell at a required price may be difficult.
• Size and nature of order – the prices displayed on execution venues are for dealing in a certain size. Orders greater than this size will be managed in line with this policy.
• Any other consideration relevant to the execution of the order – this may include the need for timely execution, the time zone of the execution venue or the diversity in markets for different types of financial instrument.

We will determine the relative importance of these factors based on the characteristics of the client, the order and of the financial instrument, in relation to the trade venues we use. We may decide in our absolute discretion the factors that are most important to any order.

Execution Venues

Subject to any specific client instruction, we may use one or more of the following venues to enable us to obtain the best possible result when executing or transmitting orders:

• Regulated Markets;
• Multilateral Trading Facilities;
• Retail Service Providers;
• Third Party Brokers and Investment Firms (or non-EU entities performing similar functions) which may take proprietary positions, or act as Market Makers or Liquidity Providers;
• Internal sources of liquidity (matching client orders); and
• Unit Trust Managers/Fund Providers directly or through via a fund custodian.

Our choice of venue may be constrained by there being only one market or trading platform where an order can be executed because of the nature of the order or a specific client instruction.

See Appendix A for details of the execution venues on which KW places significant reliance.

Executing Orders outside a Trading Venue

Where we believe that doing so will achieve the best possible result for you we may execute orders outside of a Trading Venue.
Top 5 Execution Venues

We are required to provide information on the top five execution venues (in terms of trading volumes by asset class), used to executed client orders in the preceding year. This applies to all instruments in the scope of MiFID II. This information will be published on our website by the end of April each year.

Publication of Unexecuted Limit Orders

Where you place a Limit Order with us (in shares that are admitted to trading on a Regulated Market or traded on a Trading Venue) that is not immediately executable, you permit us not to immediately make the order public and allow us to exercise our discretion in accordance with this policy.

Monitoring and Review

We review all trades on a regular basis for timely execution and price achieved.

We review this policy annually or when there is any material change to our arrangements. We will notify you of any material changes by providing an updated policy.

Consent

We are required to obtain your prior agreement to this Policy, as well as your consent to (1) not publish Limit Orders and (2) execute orders outside a Trading Venue.

Signing our Investment Management Agreement and agreeing to our Terms and Conditions constitutes this acceptance/consent.

The value of investments and any income from them can fall and you may get back less than you invested. KW, KW Wealth, KW Protect, KW Wellbeing, KW Institutional, KW Partner and KW Private Office are trading names of KW Wealth Planning Limited (registered number 01265376), KW Investment Management Limited (registered number 06931664 ) and KW Trading Services Limited (registered number 03109469) which is a member of the London Stock Exchange. Each of these companies is authorised and regulated by the Financial Conduct Authority and has its registered office at 13 Austin Friars London EC2N 2HE. KW investment Management Limited is also regulated in South Africa by Financial Sector Conduct Authority. All these companies are wholly owned subsidiaries of Kingswood Holdings Limited (registered number 42316) which is incorporated in Guernsey with registered office at Regency Court, Glategny Esplanade, St Peter Port, Guernsey, GY1 1WW.