Best Execution Policy

• This is a summary of our best execution and order handling policy which we follow when executing orders on your behalf.
• By giving us orders to trade after receiving this policy summary, you will be consenting to having your orders handled by FinnCap Limited in accordance with its best execution policy.
• If you would like further information about our best execution policy, please contact us.

What is best execution and order handling?

• When we execute orders on your behalf, we may owe you a duty of best execution. This means that we are obliged to take all reasonable steps to obtain the best possible result for you when executing your orders.
• This does not mean achieving the best price for every client order, but rather the best possible result that we can reasonably be expected to achieve with the resources available to us.
• We also have an obligation to implement procedures which provide for the prompt, fair and expeditious execution of client orders in relation to other client orders or our own trading interests.

When does best execution apply?

• When we have an order in respect of a financial instrument and:
• we are executing orders on behalf of clients, either dealing as principal or as agent; or
• we are arranging transactions (for example, placing an order through a broker, known as “receiving and transmitting orders”).
• Please note: if you provide us with specific instructions this may prevent us from taking the steps set out in our policy to obtain the best possible result for the execution of your order in respect of the elements covered by those instructions. Executing your order in accordance with your instructions satisfies our obligation to take reasonable steps to obtain the best possible result for the execution of your order.

How do we satisfy the best execution obligation?

• We have to take all reasonable steps to obtain the best possible results for our clients.
• In practical terms, this means selecting execution venues which consistently deliver best execution taking into account the execution factors listed below.

What are the execution factors?

• The execution factors are:
• price
• costs of transactions (i.e. the fees charged for executing an order on a particular venue) which are passed on to you, directly or indirectly
• speed
• likelihood of execution (how liquid is the market in the particular product?)
• likelihood of settlement
• size of order
  
  and we must take into account:
• any other relevant considerations
• whether you have given us specific instructions (as execution according to those instructions will satisfy the best execution obligation)
• The importance of these factors has been weighted according to product.
• Any limit order that you give us, which we cannot immediately execute, we are required to publish to a regulated market or Multilateral Trading Facility – a system that brings together multiple parties that are interested in buying and selling financial instruments and enables them to do so – unless you agree that when you place a limit order with us that is not immediately executable, we may exercise our discretion not to publish such an order to a regulated market or MTF.
• We must obtain your consent to execute any orders submitted by you outside of either a regulated market or an MTF.

Order Handling

• We must execute client orders promptly and execute comparable client orders promptly and sequentially unless the characteristics of the order or prevailing market conditions make this impossible, or the interests of the client require otherwise.
• We also do not have to treat client orders sequentially if the orders are received by different media and it would not be practicable to do so.
• If your order is to be aggregated with other client orders and/or with our own orders, the effect of aggregation may work to your disadvantage in relation to a particular order.

Fair Allocation

• We will allocate all orders fairly and will not give preference to one client over another.
• If we have aggregated client orders with our own orders and we cannot complete the total order we will fill the client orders first unless we can show that without our participation the order could not have been filled on such favourable terms or at all.

Review

• We will review our best execution and order handling policy regularly and whenever a material change occurs that affects our ability to obtain the best possible result for you when executing your orders.
• We will notify you of any material changes to our best execution and order handling policy by posting an updated version of the document on our website, www.jmfinncapitalmarkets.com.

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