Order Execution Policy

1. Overview

MiFID’s best execution regime requires Brandon Hill Capital Limited (“BHC”) to take all reasonable steps to obtain the best possible results for clients, taking into account: price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of an order.

In order to comply with the best execution requirement stated above, BHC will ensure that appropriate execution policies and/or arrangements are effectively implemented for carrying out all orders.

BHC however are under no obligation to obtain the best possible result for each individual order; rather, BHC will apply its execution policy to each order with a view to obtaining the best possible result in accordance with the execution policy.

The detailed policy for order execution contained below will be reviewed regularly and clients will be informed of any material changes to the policy.

2. Best Execution Policy

This policy is intended, in as clear a way as possible, to demonstrate how BHC operates and provides best execution.

3. Execution Venues

Generally, all orders will be executed on a Regulated Market or Multilateral Trading Facility (“MTF”). The execution venues and clearers (each an “Execution Venue”) that BHC uses are:

Direct as Members:London Stock Exchange


BATS Trading

Via other brokers:Toronto Stock Exchange

Australian Stock Exchange

New York Stock Exchange


BHC believes that the Execution Venues are appropriate to providing best execution to the client as these Execution Venues enable BHC to obtain, on a consistent basis, the best possible result for executing client orders. The charges passed down to the client are consistent with the cost to the firm of dealing with each execution venue/clearer so as not to unfairly discriminate against any one Execution Venue.

BHC will assess regularly the Execution Venues available in respect to any product that BHC trades in order they continue to be the most appropriate for our clients.

4. Execution Factors

The decision of which Execution Venue is used for any one trade will be reached based on: price, costs, speed likelihood of execution and settlement, size, nature, or any other consideration relevant to the execution of an order. This decision may be influenced by the Execution Venue’s own fees and commissions.

When executing an order, BHC will generally treat price as the highest priority for ensuring the best execution. Only under exceptional circumstances would this not be the case.

In order to calculate the price, BHC will pay due attention to the total consideration; this is represented by the price of the financial instrument and the costs related to execution, which must include all expenses incurred by the client which are directly related to the execution of the order, including Execution Venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.

5. Execution Criteria

When executing a client order, BHC will take into account the following criteria for determining the relative importance of the above noted factors:

  • The characteristics of the client including the categorisation of the client;
  • The characteristics of the client order;
  • The characteristics of the financial instruments that are the subject of that order;
  • The characteristics of the Execution Venues to which that order can be directed.

6. Selecting an Execution Venue

The following methodology will be used when selecting an execution venue for an order:

  • Subject to proper consideration of the execution criteria and execution factors referred to above, BHC will choose the Execution Venue  where it believes it can trade to the best advantage (or at no disadvantage) for the client;
  • When dealing on a Regulated Market or MTF, BHC will select the Execution Venue BHC considers the most appropriate.

7. Specific Client Instructions

BHC can accept specific instructions from a client which may override this policy; however, BHC may not induce any client to do so. If a client chooses to give specific instructions to BHC relating to an order, BHC will attempt to provide best execution as far as possible. However, a client’s specific instruction may prevent BHC from taking the steps that it has designed and implemented in its execution policy to obtain the best result for the execution of that order in respect of the elements covered by those instructions.

8. Limit Orders

FCA rules requires that client limit orders in respect of shares traded on a regulated market which cannot be immediately executed must be made public unless you expressly instruct us otherwise.  Unless you notify us in writing, you instruct us not to publish unfilled limited orders over normal market size unless we decide in our discretion to do so.

9. Execution Venue other than on a Regulated Market or Multilateral Trading Venue (“MTF”)

BHC do not intend to execute your orders outside a regulated market or multilateral trading facility (in other words, in the over-the-counter market).

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