Overview

Best execution policy

It is in the interests of Coloma and our clients that we obtain the best possible result when placing orders for execution on your behalf, with third parties, such as platforms, fund managers or stockbrokers. We are required to take all sufficient steps to provide best execution when carrying out such transactions and, on request, to provide you with a copy of the policy that we have adopted to achieve that objective.

This best execution policy applies to orders in investments such as funds and other securities. You should read this policy carefully.

Execution venues and third parties

An execution venue is effectively a trading venue such as a regulated stock market where investment transactions are executed. We do not execute orders or deal directly with execution venues. Instead, we will place orders on behalf of our clients with appropriate third parties as explained below:

• Investments on a platform: for investments held on our preferred platforms, (an online investment administration service), client orders will be placed directly with the relevant platform. These are:

 Transact, AJ Bell, Ascentric, Standard Life, 7IM, AVIVA

• Investments not on a platform: for investments held directly with individual fund managers, client orders will be placed directly with the relevant fund manager for the particular investment.
• Stocks and shares: we use Ascentric, Transact and AJ Bell
• Other investments: for EIS or VCT investments we will use providers such as Octopus,

  Downing, Longbow, or other regulated providers.

  We will regularly assess the third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging the execution of orders for our clients. The above list will then be updated, where necessary, following such assessment.

  The third parties have responsibilities in relation to best execution and client order handling themselves. We will also undertake periodic monitoring to ensure that they are meeting the relevant requirements.

  Execution factors

  When transmitting orders to a third party, we will make every effort to ensure the best possible result for our clients by taking the following factors into account:

• Price
• Cost
• Speed

  For retail clients, the price, speed and cost of executing the order will normally be the most important aspect in obtaining the best possible result. We will therefore assume that these are the most important outcomes for your transaction unless you tell us otherwise.

  Client specific instructions

  If you have given instructions that price is not the most important factor in executing your instructions, we will make every effort to comply with your instructions but cannot guarantee this. This may be due to either the nature of the order, or the type of investment you wish to trade in.

  We will make all decisions as to where the orders are placed and will not accept specific instructions from clients regarding which third parties to use.

Best execution policy

April 2020

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Charges

It is our policy that commission and charging structures will not influence either the selection of third parties to which we place client orders, or the order flow that follows as a result of the execution process. We do not discriminate between the third parties used to arrange execution of your orders.

Monitoring and review of our execution policy

We will regularly monitor the effectiveness of our best execution policy to identify and, where appropriate, correct any deficiencies. In particular, this will cover the third parties to which we transmit client orders in terms of their quality of execution.

This review will be carried out regularly (on at least an annual basis) or whenever a material change occurs that affects our ability to continue to obtain the best possible result for our clients.

Trading venues and volumes

We will place investment orders with one of our platform partners listed above. Each platform has a published best execution policy which outlines how they will place client orders to obtain the best possible outcome. Each platform publishes its top 5 entities to which client orders have been transmitted by volume and quality of execution.

A review will be carried out at least annually to ensure that we may continue to use venues that are efficient and provide a good quality of service.

Staff understanding

All relevant staff are made aware of this policy to highlight and emphasise the importance of best execution.