Best Execution Policy

1.   Overview

It is in the interests of our clients and our firm that we obtain the best possible result when placing orders for execution on behalf of our clients, with third parties, such as platforms, fund managers or stockbrokers. We’re required to take all sufficient steps to provide best execution when carrying out such transactions and, on your 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.

2.   Financial instruments that we trade in

The financial instruments that we may trade in include:

• Shares in British and foreign companies (including unlisted or unquoted shares), debenture stock, monies, currencies and loan stock, bonds, notes, certificates of deposit, commercial paper or other debt instruments including government, public agency, municipal and corporate issues, Eurobonds, fixed interest, and other securities denominated in any currency, Treasury Bills and other money market instruments (referred to collectively as ‘core investments’)
• Depository receipts or other types of instruments relating to core investments and warrants
• Structured products
• Collective investment schemes (CIS), including unit trusts, open ended investment companies, closed ended investment trusts, mutual funds, and CIS in the UK and elsewhere, including non-mainstream pooled investments (NMPI) which include unregulated collective investment schemes
• Exchange traded products (ETPs), including ETFs, ETCs and exchanged traded notes
• Precious metals, commodities, bullion, and gold coin

3.   Execution venues and third parties

An execution venue is effectively a trading venue such as a regulated stock market where investment transactions are executed. Our firm doesn’t execute orders or deals 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 the platform(s) that have been selected by your financial adviser (an online investment administration service), client orders will be placed directly with the relevant platform.
• Holdings within the Magnus funds: For holdings within the Magnus funds that are traded by Magnus, orders will be placed directly with Vestima for collective investment schemes (“funds”) and Tradeweb for exchanged traded funds (ETF). See Appendix 1 for a list of the approved brokers that we use.
• Exchange Traded Funds (ETFs): For Exchange Traded Funds (ETFs), orders are transmitted via the Tradeweb platform through a Request for Quote (RFQ) process. Quotes are requested from Magnus’ approved market makers and liquidity providers, with orders typically executed against the most favourable available quote received at the time of trading. This process supports Magnus in achieving best execution for clients through competitive price discovery, efficient execution and access to multiple sources of liquidity.

Most funds are priced once a day. The funds will have a cut-off time before orders need to have been placed with the fund house, so any order placed after this time will be dealt at the next valuation point. Investors will receive the same outcome provided all deals are executed at the same time.

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 your orders. 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’ll also undertake periodic monitoring to ensure that they are meeting the relevant requirements.

4.   Execution factors

When transmitting orders to a third party, we’ll make every effort to ensure the best possible result for our clients considering the following factors:

• Price
• Cost
• Speed
• Likelihood of execution and settlement
• Size
• Nature of the order
• Any other considerations relevant to the execution of the order

For retail clients, the price and cost of execution of the order will normally be the most important aspect in obtaining the best possible result. We will therefore assume that this is the most important outcome for your transaction unless you tell us otherwise.

In relation to Exchange Traded Funds (ETFs), Magnus may also consider factors including market liquidity, bid-offer spreads, underlying market conditions and the quality of quotes received from approved market makers and liquidity providers when seeking the best possible outcome for clients.

5.   Client specific instructions

If you have given instructions that price is not the most important factor in executing your instructions, we’ll 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.

6.   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 will therefore not discriminate between the third parties used to arrange execution of your orders.

7.   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.

For ETF transactions, Magnus may periodically review execution outcomes using available execution reports, market data and other relevant information to assess whether best execution obligation continue to be met.

8.   Staff understanding

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

Appendix 1 – External brokers

In respect of the Magnus OEIC, we currently place orders via the Tradeweb platform when trading in ETFs.

Magnus has agreements in place with the following approved market makers and liquidity providers for ETF trading. Orders are placed through the Tradeweb platform using a Request for Quote (RFQ) process, which facilitates competitive pricing and execution across approved liquidity providers:

• DRW
• Optiver
• Jane Street