Execution Policy

Centile Partners Limited (“The Company”) executes orders in relation to financial instruments on behalf of its clients.  There are two methods that it can use to execute those orders that are distinguished for the purposes of FCA Rules.

First, The Company can execute the relevant transaction on behalf of the client directly on an exchange or other trading system.  The exchange or trading system with which The Company chooses to execute such a transaction is referred to in this policy as an “Execution Venue”.

Secondly, The Company can place an order as agent with a third party (e.g. another broker or bank).

The Company’s Core Best Execution Obligations

In accordance with FCA Rules, The Company is required  to take all sufficient steps to obtain the best possible result for its clients when executing orders for its clients. (i.e. to obtain best execution).   In seeking to obtain best execution, The Company is required:

To take all sufficient steps to obtain the best possible result for its clients, taking into account certain “execution factors” – price; costs; speed; likelihood of execution and settlement; size of the transaction; nature of the transaction; or any other consideration relevant to execution. Under The Company’s policy, such other considerations can include (without limitation) the overall cost of the transaction or any costs for executing the order on an execution venue); timely execution availability of price improvement; the potential impact of the transaction on price; importance of retaining commercial confidentiality in relation to trading activities or intentions; liquidity of the market (which may make it difficult to execute an order); order information leakage; trading conflict; market conduct; market impact; venue liquidity and counterparty risk.

In order to comply with the overarching best execution requirement (above), The Company will ensure that appropriate (execution) policies and/or arrangements are effectively implemented for the carrying out of all orders.

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

Best Execution Policy

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

Execution Factors

The decision of which venues 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 Company’s own fees and commissions.

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

In order to calculate the price The Company 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.

Execution Criteria

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

1. the characteristics of the client including the categorisation of the client as retail or professional;

2. the characteristics of the client order;

3. the characteristics of financial instruments that are the subject of that order;

4. the characteristics of the execution venues to which that order can be directed

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, we will choose where we believe we can trade to the best advantage for (or at no disadvantage to) you.

Specific Client Instructions

The Company can take specific instructions from a client which may override this policy however The Company may not induce any client to do so. If a client chooses to give specific instructions to The Company then The Company will attempt to provide best execution as far as is possible. However this may prevent The Company from taking the steps that it has designed and implemented in its execution policy to obtain the best possible result for the execution of those orders in respect of the elements covered by those instructions.

Execution Venues 

The Company may use one or more of the types of Execution Venue.  The Company may execute orders on behalf of clients directly on exchanges, multilateral trading facilities or organised trading facilities.

Placing Orders with Brokers / Banks

In choosing the Broker or Bank to place orders The Company has taken care to select those Brokers/Banks that, in The Company’s view, consistently provide a high quality execution service, taking account of the relevant execution factors for the relevant Instrument Class.

Where The Company places an order with a Broker/Bank for execution, The Company is not responsible for controlling or influencing the arrangements made by this third party relating to the execution of that order (e.g. The Company does not control the Broker’s choice of execution venues, such as exchanges, multilateral trading facilities or organised trading facilities). The Company is not required to duplicate the efforts of the Broker/Bank to whom an order is passed in ensuring the best possible result.

Direct Execution of Orders  

In choosing the Execution Venues The Company has taken care to select those Execution Venues that, in The Company’s view, enable it to obtain on a consistent basis the best possible results for its clients.

The selection process takes into account such factors as liquidity, integrity of marketplace and price formation.

Choosing Between Order Placement and Direct Execution 

The Company will determine whether to place an order with a Broker/Bank or to execute an order directly on an Execution Venue according to the nature of the order and the market in which the relevant order is to be executed. In determining whether to place an order with a Broker/Bank or to execute directly, The Company will have regard to the relative importance of the execution factors. In certain markets, it will only be possible to execute client orders by placing them with a Broker/Bank in the relevant market.

The factors affecting the choice of Execution Venue or Broker 

In relation to an order, an Execution Venue or Broker/Bank will be selected as is appropriate in view of the size and nature of the relevant order. The Company will select Execution Venues and Brokers/Banks based on their track records of achieving the best result in terms of the execution factors taking into account, in particular, the geographic and market coverage of the relevant Execution Venue or Broker/Bank.

Over-the counter trades 

When executing orders or using a Broker to deal in financial instruments over-the-counter, The Company will check that the price quoted is fair by taking into account market data, including comparing that price with similar instruments (where available). There may be counterparty risk when executing an order outside a trading venue. On request by the client, The Company can provide additional information about the potential impact on the execution of orders when executing over-the-counter.

Monitoring and Reviewing this Policy 

The Company has an obligation to monitor the effectiveness of its order execution arrangements and this policy. This obligation has been incorporated into The Company’s general compliance monitoring process and business procedures and policies.

The Company assesses, on a regular basis, whether the execution venues listed above provide the best possible result for clients or whether it needs to make changes to its execution arrangements. The assessment takes into account the information on execution quality published by execution venues and brokers in accordance with MiFID II.The Company also conducts regular reviews through random sampling of transactions to ascertain whether the best possible result was obtained in respect of those transactions.

Review of Policy

At least annually, The Company will review this policy and its execution arrangements. The review will focus on whether The Company would obtain better results for its clients if it was to:

1. include additional or different Execution Venues or Brokers/Banks;

2. assign a different relative importance to the execution factors; or

3. modify the process by which Execution Brokers/Banks and Venues are selected

4. modify any other aspects of this policy and/or its execution arrangements.

The Company will also review this policy and/or its execution arrangements whenever a material change occurs that could affect its ability to obtain the best possible result for the execution of its clients’ orders on a consistent basis, for example, a significant event that could impact the parameters of best execution such as the execution factors specified above.

Client Notification / Consent Requirements 

The Company has an obligation to provide its clients with appropriate information on this policy. Where The Company executes orders on behalf of a client, it will also have an obligation to obtain the client’s consent to this policy. By accepting our terms of business, you consent to your transactions being executed in accordance with this policy.

Annual Publication of Top 5 Execution Venues 

Each year The Company will publish data on the top five Execution Venues and the top five Brokers/Banks The Company has used during the previous year. The top five Execution Venues and Brokers/Banks will be based on trading volume [(i.e. the number of financial instruments traded times price for each transaction, cumulated for the year)] for each class of financial instrument for the preceding year.

The Company will also publish an annual report on The Company’s website providing a summary of the analysis and conclusions drawn from The Company’s monitoring of the quality of execution obtained on the Execution Venues.