1. BEST EXECUTION
Best execution refers to the duty of an investment services firm executing orders on behalf of customers to ensure the best execution possible for their customers' orders.
2. BEST EXECUTION POLICY
This policy provides an overview of how Signet Investments and Securities Limited (Signet) executes orders on behalf of clients, the factors that can affect the timing of execution and the way in which market volatility plays a part in handling orders when buying or selling a financial instrument. The policy applies to Signet's execution of orders on behalf of retail clients. Upon acceptance of a client order and when there is no specific client instruction regarding the execution method, Signet will execute an order in accordance with this policy.
3. FINANCIAL INSTRUMENTS TO WHICH THIS POLICY APPLIES
This policy applies to the following financial instruments and products, namely, Stocks and Bonds.
4. SIGNET'S APPROACH TO BEST EXECUTION
4.1 When executing orders Signet will take all reasonable steps to obtain the best possible result under the circumstances for the client taking into account price, costs, speed, likely-hood of execution and settlement, size, nature or any other consideration relevant to the execution of the order ("Best Execution").
When considering the best executing factors, Signet takes into account:
- the characteristics of the client order;
- the characteristics of the financial instruments that are subject to that order.
A specific instruction from a client may prevent Signet from taking the steps that it has described in this policy to obtain the best possible result for the execution of orders. Trading rules for specific markets may prevent Signet from following certain of the client's instructions.
To the extent that a client instruction is not complete, Signet will determine any non-specified components of the execution in accordance with this policy.
5. ELEMENTS OF BEST EXECUTION
The procedure for routing determinations is mainly based on four criteria and is regularly reviewed by Signet Hence to determine the best way to execute an order for a client Signet takes into consideration:
5.1 Speed and Likelihood of the Execution
Due to the levels of volatility affecting both price and volume, Signet seeks to pro-vide client orders with the fastest execution reasonably possible although delays may occur.
5.2 Price Improvement and Overall Consideration of Costs
Orders are routed to market makers and/or market centers where opportunities for price improvement exist.
The criteria to be used by other market-makers and/or market centers include:
- automatically matching incoming market and limit orders to pending limit orders
- crossing transactions where price improvement can be offered to one or both sides of the trade.
5.2 Size Improvement
In routing orders, Signet seeks markets that provide the greatest liquidity and thus potential for execution of large orders.
5.3 Overall Execution Quality
When determining how and where to route or execute an order, Signet's traders draw on extensive day-to-day experience with various markets and market makers, focusing on prompt and reliable execution.
6. EXECUTION OF CLIENT ORDERS
Signet uses automated systems to route and execute client orders. When a client order is received by Signet, it may be kept in house for products which trades against its own proprietary desk.
7. EFFECTS ON ORDER EXECUTION
7.1 Clients should be aware of the following risks associated with volatile markets, especially at or near the open or close of the trading session:
- execution at a substantially different price from the quoted bid or offer or the last re-ported sale price at the time of order entry, as well as partial executions or execution of large orders in several transactions at different prices.
- opening prices that may differ substantially from the previous day's close.
- locked (the bid equals the offer) and crossed (the bid is higher than the offer) markets, which prevent the execution of client trades.
- price volatility is one factor that can affect order execution. When clients place a high volume of orders with brokers,
order imbalances and back logs can occur.
This implies that more time is needed to execute the pending orders. Such delays are usually caused by the occurrence of different factors: (i) the number and size of orders to be processed, (ii) the speed at which current quotations (or last-sale information) are provided to Signet.
8. TYPES OF ORDERS
8.1 Given the risks that arise when trading in the volatile market, the client may want to consider using different
types of orders to limit risk and manage investment strategies.
(It should be noted that the following descriptions of order types may apply only to some and not all types of
8.2 Market order: With a market order the client instructs a financial institution or trading counterparty to execute a trade of a certain size as promptly as possible at the prevailing market price. Brokers are required to execute market orders without regard to price changes. Therefore, if the market price moves significantly during the time it takes to fill a client's order, the order will most likely be exposed to the risk of execution at a price substantially different from the price when the order was entered.
8.3 Limit order: With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future.
8.4 Stop order: Different from a limit order, a stop order allows selling below the current market price or buying above the current market price if the stop price is reached or breached. A stop order is therefore a "sleeping" order until the stop price is reached or breached.
8.4.1 Trailing stop order: The trailing stop order is a stop order as described in Section 8.4 but the trailing stop price moves according to parameters set by the client. This way the trailing stop can be used to sell if the price drops more than a specified distance from the highest price traded or to buy if the price trades above a set level from the lowest traded price.
8.4.2 Stop Limit Order: A stop limit order is a variation of a stop order as described in Section 8.4 with a lower (higher) limit price to suspend trading if the price falls (rises) too far before the order is filled restricting trading to a predefined price range.
8.4.3 Spread Filters: In order to ensure that the client's Stop Orders is not filled at unreliable prices during short termed periods with abnormally wide bid/ask spreads caused by for instance release of key economic figures Signet has implemented spread filters preventing order execution when spreads exceeds certain levels. Having the spread filters in place will in general benefit the client, but can in rare instances be in the disfavor of the client.
Algorithmic order: An Algorithmic Order is an order executed by an automated strategy according to specific parameters or conditions. Algorithmic Orders are intended to minimize the market impact created from placing larger orders or achieving a recognized trading benchmark such as VWAP etc. The orders can also be used to follow a volume participation or in general to achieve a better overall execution.
9. REGULAR REVIEW OF EXECUTION QUALITY AND OF EXECUTION VENUES
9.1 Signet will review this policy annually and whenever a material change occurs that affects Signet's
ability to obtain the best possible result for the execution of client orders.
9.2 Signet regularly reviews the overall quality of its order executions and its order routing practices, including its order routing vendors and the available exchanges. Signet will amend this policy on the basis of such reviews if it considers it to be necessary. Any new policy will be made available on Signet's websites and will be in force as from publication.
Oladipo A. Aina
- Managing Director/Chief Executive