This Best Execution Policy is an explanation of how we handle your investment instructions when adding to, or withdrawing money from, your investment, or if you’re making changes to your selected investment portfolio.
It explains how we meet the requirements set out by the Financial Conduct Authority (FCA) by taking sufficient steps to obtain the best possible result for you. This is achieved by taking into account the factors outlined in this policy and ensuring all instructions are handled in a consistent manner with controls and safeguards in place.
By agreeing to our terms and conditions you’re agreeing to this policy.
Scope
This policy covers all instructions you give to us which lead to an investment order being generated, which will be executed by Hubwise. (Hubwise is the ISA manager and SIPP Trustee and operator).
Example instructions within scope include:
- contributions (regular or ad hoc)
- withdrawals (regular or ad hoc)
- changes to your selected investment portfolio.
Execution factors
We act as a ‘receiver and transmitter of client investment orders’, passing them on to Hubwise for onward transmission or execution with a relevant trading venue.
We always trade as an ‘agent’, and we’re responsible for the speed of execution. For liquid securities, prices are sensitive to market fluctuations. Therefore, it’s crucial that we transmit your order to Hubwise promptly, without delay.
Because Hubwise does not perform the trading role of executing investment orders, we cannot influence the following execution factors:
- Price: We have no control over securing the best price when executing your instructions.
- Transaction costs: We cannot influence the impact of customer charges when selecting an execution venue, and any charges that may be passed on to you.
- Likelihood of execution and/or settlement: This involves considering the likelihood of a trade being executed and/or settled into your investment account. This process can be affected by trading in markets or venues with low or high liquidity.
- Nature, size, and complexity of the Order: The prices shown by execution venues are for specific order sizes. If your order is large compared to the usual market size or involves less liquid securities, the final price might differ from the initial one displayed.
- Other: We may also need to consider factors such as the quality and efficiency of the settlement process after the trade, the financial stability and reliability of the counterparty, and the overall market impact of the transaction.
All of these factors will be dealt with by Hubwise in line with their order execution policy available to download here: SSC-Hubwise-Order-Execution-Policy-October-2024.pdf
We will receive and transmit customer instructions which will generate investment orders for collective investment schemes (Funds), ETFs or investment trusts as appropriate.
Order management and handling
Once you have given us your instruction we’ll input the detail into the Hubwise system. We’ll create instruction investment orders which Hubwise will execute. Hubwise states in its order execution policy that it handles orders promptly and in a fair and expeditious manner. They accurately record and allocate the trades we send them and execute them sequentially in order of receipt, unless the order characteristics or prevailing market conditions require otherwise.
Please refer to their order execution policy shown above for further details.
Monitoring and review of this policy
We monitor best execution through reports provided by Hubwise.
As per FCA rules, we review this execution policy annually.
Glossary
- Agent: A person or entity authorised to act on behalf of another, for this service this will be HUB Financial Solutions Limited, acting for you, the customer.
- Best execution: The obligation to execute customer orders on the most favourable terms.
- Collective investment schemes: Investment funds that pool money from multiple investors to invest in securities.
- Liquidity: The ease with which an asset can be bought or sold in the market without affecting its price.
- Exchange Traded Funds (ETFs): Investment funds traded on stock exchanges, similar to shares.
- Investment Trusts: Closed-end funds that are publicly traded and invest in a diversified portfolio of assets.