What is your Order Execution Policy?
Updated 13 July 2017
1.1 This article explains how we arrange for the execution of your instructions to buy or sell investments available through our Retiready offering (the “Order”). It explains the steps we take to obtain the best possible outcome when receiving and transmitting orders for execution using Retiready.
1.2 This policy applies to all investors and users of Retiready and should be read together with your terms and conditions, which are available by contacting the Customer Services team using the details provided at the bottom of this page.
1.3 Some of the information below will only apply to Retiready ISA funds.
2.0 Order Execution Policy
2.1 When we arrange the execution of an Order on your behalf, we’ll take all reasonable steps to obtain the best possible results for you in accordance with the following policy.
2.2 This Order Execution Policy is applicable to you where you’ve given us an Order through a Retiready account for retail funds (funds that are structured so that each investor owns a share of the fund).
3.0 Our approach to order handling – best execution
3.1 Best execution is at the core of regulation within financial services and aims to protect investors, ensure integrity in trading activity and promote competition.
3.2 We consider the price of the investment to be the most important factor for obtaining the best possible outcome for our customers. However, there may be circumstances which will cause other factors to be given a higher priority.
3.3 We’ll look to obtain the best possible outcome based on the price of the investment and the total costs that will be incurred – the ‘best price’.
3.4 There are certain circumstances where best price and therefore the execution policy may be limited – this would include trading directly with the product issuer or fund manager.
3.5 Regardless of the type of account you have with us, when we arrange the execution of an Order on your behalf, we consider a number of factors including, but not limited to:
- Speed – the efficiency of transmission and execution (including method of transaction)
- Certainty of execution and settlement – for example, the likelihood that an Order will complete
- Size of the deal
- Costs (including dilution levy, execution venue fees, clearing and settlement fees)
- Any other relevant considerations
3.6 Aegon reserves the right to act in a deal as agent for more than one client collectively.
4.0 Currency of transaction
4.1 All transactions placed through Retiready are accepted and executed in pounds sterling (GBP).
5.0 All dealing for retail funds
5.1 Retail funds are structured so that each investor owns a share of the fund. We deal directly with the fund manager for each fund available within Retiready. This will be Aegon for Retiready pension funds and BlackRock for Retiready ISA.
5.2 The transmission and execution of orders for investments in collective funds follow the same process as insured fund trading. Trades are always made directly with the respective Authorised Fund Manager (AFM) or Authorised Corporate Director (ACD) of that fund.
5.3 Your Order will be routed to the appropriate fund manager for execution at our next available Valuation Point (the point at which we combine all buy or sell Orders for a particular fund).
5.4 Any deal placed by us, will typically be made to the fund manager within the next two valuation points. Once the fund manager has received this order they’ll then apply their next available valuation point.
5.5 As trades are placed directly with the fund manager, best execution is limited. However, as the fund manager they are best placed to consistently provide a competitive market price and the level of units needed to complete these orders.
5.6 In order to provide best execution, we continually monitor the funds to be sure they’re suitably placed to give the best outcome.
5.7 We operate an aggregated dealing process for all orders, which means similar orders will be grouped together and executed as a single transaction adhering to the rules set by the FCA on aggregated trading.
5.8 Some funds cannot be routed electronically and the Order will be manually placed with the fund manager.
5.9 When we receive the completed trade from the fund manager, we’ll disaggregate the transactions and allocate the appropriate units or cash to investors, in line with their orders.
5.10 Disaggregation may result in the instruction being different by a very small amount, due to rounding.
5.11 We‘ll oversee the full trading process to make sure transactions aren’t delayed, are executed successfully, and receive the price within the timescales set out within the terms and conditions.
5.12 We keep records of transactions to make sure we can allocate all completed instructions fairly and in the order in which they were placed.
6.0 Your instructions to us
6.1 Due to the way we conduct our business, dealing instructions should only be placed via the online system. If the online system is preventing an instruction from being executed, contact the Customer Services team for guidance.
6.2 Where possible, order instructions are placed ‘at best’ – the best price available.
6.3 When you ask us to execute an Order on your behalf, you instruct us to execute that Order consistent with the Terms and Conditions of your Retiready Account and this current Order Execution Policy.
6.4 Acceptance of the terms and conditions on providing a dealing instruction will be deemed also to be consent to orders being executed in accordance with this policy.
6.5 If, for any reason, we consider it necessary and, in your best interest, to execute a dealing instruction outside of a regulated market or a multi-lateral trading facility, we’ll ask for consent before we complete this instruction.
6.6 Aegon reserves the right to vary any aspect of the policy without notice.
7.0 Dilution levy or exit charge
7.1 Aggregation of orders can lead to a large transaction in a particular asset. Such aggregation therefore runs the risk of a fund manager applying a dilution levy to the transaction. A dilution levy is an extra charge placed on a transaction by a fund manager to offset any significant movement in the price of a fund that may be generated by a large order.
7.2 If a dilution levy is applied to a bulked order, the levy is apportioned to the individual orders making up the bulked order in proportion to the units bought or sold on that order. A dilution levy is shown clearly on the contract note for that transaction.
7.3 Exit charges may be applied on orders by fund managers when a sell transaction is executed. They are normally set in advance as described in the terms and conditions of a fund. You are advised to check your fund literature carefully before purchase for any exit charges you may be liable to pay when you sell. The amount of any exit charge should be shown on your contract note.
8.1 We reserve the right to cancel a transaction without notice where we believe there is sufficient justification. This may include, but is not limited to, circumstances where we are requested to do so by our counterparty or where we believe you have submitted duplicate or repeated instructions to take advantage of any market limitations or restrictions.
8.2 We will not be liable for any loss or expense you incur as a result of the cancellation of a transaction in such circumstances.
8.3 If multiple trades are processed we will apply charges separately to each deal.
9.0 Order Execution Policy review
9.1 We’ll review this policy annually or at any other time when there’s a material change to the arrangements or procedures covered by this policy.
9.2 We’ll evaluate the overall quality of executed Orders and our Order Execution Policy to make sure that it allows us to obtain the best overall outcome for our customers.
9.3 If, as a result of a review, we make any material changes to our policy we’ll let you know by publishing an updated version on our website or by providing an updated version of this policy to you on request.
10.1 For more information about this policy, Retiready investment opportunities or any other queries, please contact us:
Call us on: 03456 100 072 (Monday – Friday, 8:30am to 5:30pm)
Send us an email: https://retiready.co.uk/public/contact-us.html
Speak to one of our agents on live chat: https://retiready.co.uk/public/support.html
10.2 We might record and monitor calls for security reasons and to help improve our service.