The purpose of this document is to provide clients of Punter Southall Wealth Limited (‘Punter Southall Wealth’) with information on our Order Execution Policy (this ‘Policy’). This Policy forms part of both the Punter Southall Wealth Service Terms and Conditions and the Investment Service Terms and Conditions (as applicable), acceptance of which provides your consent to this Policy.

This Policy is designed to ensure that we take all sufficient steps to achieve the best possible result (best execution) for you when we buy or sell investments on your behalf or when receiving and transmitting orders or passing orders onto others for execution as part of discretionary investment management services. Punter Southall Wealth must also be able to demonstrate upon request that orders have been executed in accordance with this Policy.

The rules regarding best execution are set out by the Financial Conduct Authority (‘FCA’) and are further enhanced under the EU Market in Financial Instruments Directive (2014/65/EU) (MiFID). The rules apply to professional and retail clients and relate to all financial instruments dealt in the course of carrying our investment management business anywhere in the European Economic Area (‘EEA’).

This Policy applies to all execution provided to clients and professional advisers with a direct contractual relationship with Punter Southall Wealth. An order for the purposes of the Policy is an instruction to buy or sell a financial instrument, where Punter Southall Wealth is acting as the discretionary manager for a client or on an Execution Only basis as directed by a client.

Professional Advisers using Punter Southall Wealth’s model portfolios on behalf of their retail clients through a Platform Service Provider should be aware that Punter Southall Wealth will maintain the model portfolios through the service providers interface, the Platform Service Provider’s Order Execution Policy will determine the obligations to provide best execution to retail clients using the Punter Southall Wealth Model Portfolios on Platforms.

Punter Southall Wealth acts as agent to all client orders for the purposes of this Policy and Punter Southall Wealth does not trade for its own principle account.