Vintage Asset Management Limited
Best execution policy
Overview
For Vintage Asset Management (VAM) it is in the interests of our clients and therefore our firm that we obtain the best possible result when placing orders with trading platforms, and through them with third party brokers and fund managers, for the execution of client orders or when transmitting orders on behalf of clients.
VAM cannot guarantee best execution under FCA rules but we endeavour to obtain the best result available bearing in mind the circumstances and the services offered by an executing broker. We take all reasonable steps to ensure that the administrative platforms that we use provide best execution when carrying out such transactions.
We are able to provide clients on request with a copy of the policy that we have adopted to achieve our objective of delivering the best result for them; it is included within our terms of business. We are able also to provide a list of the current execution venues we may use, for which we provide an annual update on our website. We will advise clients of any material changes to our policy as necessary and we are aware that the regulations require that we obtain a client’s consent to our policy.
This best execution policy applies to orders in financial instruments such as securities and collective funds.
We do not ourselves hold cash on behalf of clients nor act as custodian of their investments.
Execution factors
When dealing on behalf of clients we will exercise our discretion in assessing the criteria that we need to take into account in order to obtain the best possible result. In our dealings with retail clients the most influential factor in determining the final decision on execution will be that of the total consideration, which represents the price of the financial instrument and the costs related to the execution. Depending on the characteristics of the financial instrument concerned we may also consider the following criteria: speed of execution; likelihood of execution and settlement; order size; nature of the order; and any other criteria relevant to the execution of the order. Commission and charging structures will not influence either the selection of execution venues or the order flow that follows as a result of the execution process.
When purchasing units in a collective investment scheme, wherever possible our policy is to only purchase institutional units and to purchase them at or near the creation price.
Where a client is invested in assets that may be considered illiquid, e.g. property funds, there may be occasions where there is a delay in turning the investment back into cash on sale or redemption.
Executing an order
In arranging for the execution of a client order, we use a third party platform to execute depending upon the custodian for the client’s portfolio assets. This has been Raymond James Investment Services and Lombard Odier (Europe) SA.
Execution venues
All orders we place are executed through the venues or third parties as described by the platform in the various appendices. The venue will depend on the nature of the financial instrument concerned. These will include regulated markets such as the London Stock Exchange. We are only able to trade some financial instruments on one venue, in particular if we purchase units of a collective investment scheme for which the venue will be the fund manager or operator itself.
We do not trade outside of regulated markets.
We regularly assess the platforms available to us to identify those that will enable us to obtain the best possible result when arranging the execution of your orders; we consider such execution as part of a wider range of services.
The third parties themselves have responsibilities in relation to best execution and client order handling, as stated in the appendices. We undertake periodic monitoring to ensure that they are meeting the relevant requirements. Under FCA rules we will be deemed to have complied with the best execution requirement to the extent of that instruction.
Client specific instructions
If a client has given specific instructions that price is not the most important factor in executing an order, we will make every effort to comply with such instructions but we cannot guarantee this. This may be due to either the nature of the order or to the type of financial instrument.
We will usually make appropriate decisions as to where the orders are placed in relation to the execution venue. However, we will accept specific instructions from clients as to the venue where an order is executed, in particular in relation to placings. If we do accept any client specific instructions this may prevent us from following the processes set out in this policy.
Monitoring and review of our execution policy
We regularly monitor the effectiveness of our best execution policy to identify and, where appropriate, correct any deficiencies. In particular, we monitor the quality of execution of the third parties with which we transact. We undertake such a review on at least an annual basis and whenever a material change occurs that might affect our ability to continue to obtain the best possible result for your clients.
Staff understanding
All relevant staff are aware of this policy and the importance of best execution.
Appendix 1 Raymond James’s best execution policy is available on their website at https://www.rjis.co.uk/legal-regulatory/execution-policy.