Order Execution Policy – August 2012

Introduction

VSA Capital Limited (“VSA”) will endeavour to provide transaction execution of the highest quality with regard to efficiency and cost effectiveness. The primary objective of its Order Execution Policy is to provide clients with the best possible result on a consistent basis.

VSA Capital will take all reasonable steps, based on the resources available to it, to satisfy itself that it has adequate processes in place to deliver the best possible results for transactions executed on behalf of its clients. Disclosure of its Order Execution Policy does not override or affect any other fiduciary responsibilities it owes you arising from its regulatory obligations or as may be otherwise contracted between you and VSA Capital.

 

Execution Venues

For each trade VSA executes on behalf of clients, its policy on an ongoing basis is to consider the variety of trading venues or sources of liquidity available from time to time. This enables it to obtain on a consistent basis the best possible result for the execution of transactions. In satisfying this policy, it may consider the use of one or more of the following venue types:

  • Regulated markets;
  • Multilateral trading facilities;
  • Systematic internalisers;
  • Third-party investment firms and/or affiliates acting as Market Maker or other liquidity providers; and or
  • Non-EU entities performing similar functions.

Where VSA believes that best execution can be achieved on a client’s behalf outside Regulated Markets or Multilateral Trading Facilities it is its policy to do so. However, your consent is required for this.

In certain financial instruments there may only be one execution venue. In executing a trade in such circumstances VSA will presume that it has provided the best possible result in this respect for such an instrument.

Execution Factors

VSA will consider the following factors, in relation to each instrument type, to determine the counterparts it may choose, the manner in which it instructs them or whether it directly executes your orders in the market place:

  • Price;
  • Costs;
  • Speed;
  • Settlement quality;
  • Size of order;
  • Investment objectives of the portfolio; and
  • Any other matters we consider relevant to the efficiency and cost effectiveness of the order.

VSA Capital will determine the relative importance of each factor using the following criteria:

  • Your characteristics (including your Regulatory Client categorisation);
  • The characteristics and nature of your order, including whether any specific instructions are given in relation to any individual or series of transactions;
  • The characteristics of the financial instruments that are the subject of your order;
  • The characteristics of the execution venues to which your order can be directed.

Ordinarily price will merit a high relative importance in obtaining best execution. In our experience the next most important characteristic is typically liquidity of the market. However, in certain circumstances, for some instructions, instrument types or markets, VSA Capital at its absolute discretion may decide that other factors may be more important in ensuring the best execution result.

 

Order Handling

VSA is committed to prompt and fair treatment of all Client orders. VSA will exercise its discretion in publicly displaying uncompleted limit orders to achieve Best Execution, unless Clients expressly instruct otherwise.

 

Monitoring

VSA Capital will actively monitor compliance with its Order Execution Policy.