Order Policy

1. Best Execution
1.1. Introduction

Multrees Investor Services (Multrees) provides safe custody (including ISA plan manager services) and related investment administration services to its wealth manager clients (Managers) and their underlying retail customers (Customers).

The Order Execution Policy (the Policy) sets out Multrees’ approach for obtaining the best possible result when executing orders on behalf of Managers and their Customers, in accordance with section 11.2 of the FCA’s Conduct of Business Rules (COBS) and the term “Best Execution” therefore has the meaning given to it at COBS 11.2.

It is likely that Managers will owe their own separate best execution obligations under the terms of their discretionary agency appointment and the investment management services they provide to their Customers. Multrees recommends that all Managers reading this Policy familiarise themselves with the relevant FCA Rules and the duties they have to their Customers in this context.

For the avoidance of doubt, Multrees owes best execution obligations to its Managers and Customers; Managers in turn need to discharge their own best execution obligations to their Customers.

1.2. Scope

This Policy applies to the following asset types which Multrees executes on behalf of its Managers:

  • Exchange traded assets (e.g. Equities, Investment Trusts and Exchange Traded Funds)
  • Fixed Income (e.g. Corporate Bonds and Gilts)
  • Derivatives (e.g. Forward Foreign Exchange).

Collective Investment Scheme transactions (e.g. OEICS, Unit Trusts and Private Equity funds) are usually executed directly with a platform or fund provider. Multrees will transmit these trades to the relevant party in order to meet the next available valuation point. Other aspects of this Policy are not relevant to these transactions, as Multrees has no discretion over how to carry out these transactions.

2. Forward Foreign Exchange
2.1. General

For Forward Foreign Exchange (FFX) trades, Multrees trades on a “Matched Principal basis”, meaning that the Customer transacts with Multrees, and Multrees place an identical order at the same time with its Market Counterparty. A full list of current market counterparties is available upon request.

FFX deals are traded Over the Counter (OTC), i.e. the execution of customer orders is conducted outside of organised markets or trading facilities. Prices for the relevant order are checked with our available market counterparties using a real time order routing and execution service, and the order is traded with the one offering the best price. Depending on the size and nature of the order, Multrees cannot guarantee that it will be able to access more than a single market counterparty for FFX transactions.

The predominant Execution Factors which Multrees will consider when deciding how best to effect a FFX transaction are (i) the overall pricing and (ii) the availability of the relevant currency. For example, whilst Multrees will aim to execute orders as soon as possible and in the order they are received, it may group orders together in order to obtain a more advantageous end result for Customers. Multrees may also consider counterparty risk when deciding which market counterparty to be used for a specific transaction.

The decision to add a market counterparty is based on a number of commercial aspects in addition to best execution requirements; these may include creditworthiness, fee structure and other commercial terms. The decision as to which market counterparty to use for a particular transaction will only be made based on the Execution Factors set out in this policy. When executing orders the market counterparties will also follow their own Order Execution Policies.

Best execution for trades executed by the selected market counterparties will be monitored and reviewed on a regular basis to ensure appropriate customer outcomes.

3. Other Financial Instruments

Multrees is not a member of any market or other trading venue, and it does not directly execute Customer orders. Instead, these orders are transmitted to selected market counterparties for execution, and Multrees in turn monitors the market counterparty for best execution factors which are listed in the appendix to this document. The decision as to which market counterparty to use for a particular transaction will only be made based on the Execution Factors set out in this policy.

The selected market counterparty will execute the trade on market, on an OTC basis, cross the trade internally with another third party, or be the counterparty to the trade itself. The market counterparty will make this decision at its own discretion, and may decide to split a trade into multiple tranches which may execute in different ways; however, it will only do so if it believes the end result would be more advantageous for the Customer than if the trade was executed on a market. The selected market counterparty will execute orders in the sequence in which they are received, unless the characteristics of the order make this impossible, for example due to limited liquidity, or it believes a better outcome will be achieved for all customers by batching orders together.

When fulfilling an order, the market counterparty will give regard to the Execution Factors listed in the Appendix of this Policy. In normal circumstances the primary factor will be price, although others may be given priority if it is regarded as being in the Customer’s best interests.

The selected market counterparty will also comply with its own Order Execution Policy when carrying out orders on behalf of Multrees’ Customers.

Best execution for trades executed by the selected market counterparties will be monitored and reviewed on a regular basis to ensure appropriate customer outcomes.

4. Review of this Policy

This Policy is reviewed by Multrees at least annually (or more frequently as required). Multrees will notify Managers of any material change to Multrees’ execution arrangements by providing each of our Managers with an updated version of this Policy by email. Updated versions of this Policy will also be made available on the Multrees website.

5. Consent

Failure to consent to this Policy would limit Multrees’ ability to obtain best execution for its Customers. Under the terms of the Multrees Custody Agreement, Managers are able to consent to Policies on Customers’ behalf – therefore, by opening an account with Multrees, Customers will be deemed to have consented to the application of this Policy.

Appendix – Execution Factors

Multrees will have regard to the following Execution Factors when executing an order on behalf of a Manager/Customer in accordance with this Policy. As detailed above, the nature of each particular order – as well as any specific Manager instructions – will have a bearing on which Execution Factors are considered in priority to others.

Execution Factor

Commentary

Manager Instructions

Multrees’ best execution obligation is subject to the nature and specificity of the relevant orders. If a Manager provides Multrees with any specific instructions regarding the execution of a particular order then such instructions will take precedence over the default factors referred to in this Policy.

Where a Manager gives specific instructions to only part of an order, the rest of the order will be carried out based on this Policy.

Cost

Any and all relevant charges will be agreed with the Manager under the terms of the relevant Fees Letter.

Counterparty Risk

In order to mitigate counterparty risk to both customers and itself, Multrees may spread trades across different counterparties.

Instruments

Different Execution Factors will be relevant to different instruments depending on their nature, characteristics and how they are traded.

Market Impact

The obligation for Multrees to take into account any impact that the order may have on the relevant market(s).

Nature of the Order

The size of the order, the types of instruments being traded, the settlement mechanics and any other order characteristics relevant to determining how the order should be executed. All orders will be executed on a prompt, fair and expeditious basis.

Consideration will need to be given to the liquidity of the instrument at the relevant time.

Price

Price will be determined with reference to the Execution Venues to which Multrees connects and on which the order is placed.

Quality of Execution

This includes the speed and likelihood of execution, and the availability and incidence of price improvement.

Size

As per the nature of the order, the size of the order in relation to the liquidity of the stock may also have significant influence on the best execution process.

 

MiFID 2 RTS 28 Execution Quality disclosures

The attachments below set out the top 5 venues that Multrees has used to execute trades, split by asset type.  Also attached is a qualitative assessment of our monitoring of execution quality, in accordance with MiFID 2 requirements set out in RTS 28.  Information will be available here for 2 years from publication.

2020:

Multrees RTS28 table 2020 csv.xls

 

Multrees RTS28 table 2020.pdf

 

Multrees RTS28 qualitative report 2020.pdf

2019:

Multrees RTS28 table 2019 csv.xls

 

Multrees RTS28 table 2019.pdf

 

Multrees RTS28 qualitative report 2019.pdf