ORDER EXECUTION POLICY (OEP)

“We shall take all reasonable steps to obtain the best possible result on behalf of our clients when executing client orders or receiving and transmitting orders for execution.”

The paragraphs below set out in detail how we seek to achieve this result for you.

Overview:

• Under this OEP, we consider the characteristics of the financial instrument, nature of the order, execution venues, liquidity, client category (retail or professional) and any other relevant criteria, and then route the order accordingly.
• For most orders, it will primarily be a case of achieving the best price, although other features of the order, like cost, size, shape, liquidity, speed of execution and other matters, will be considered where relevant.
• For most orders, the choice of execution venue will involve no extra charges, but if there are extra charges, the best overall outcome for you will be the priority.

Client Categories:

• This OEP applies to Retail and Professional Clients, as defined in the FSA Handbook.

Execution Venues:

• We use sophisticated dealing systems with links to Regulated Markets, such as the London Stock Exchange (LSE) and Plus Markets (PLUS) and their Member Firms, which include Market Makers and the Retail Service Provider Network (RSP). The use of these systems by our Dealers and Account Executives means that, for the majority of orders, we are able to achieve best execution extremely quickly and at no additional cost.
• For the more complex transactions or securities, in addition to systems, we also have direct telephone communications with counterparties with whom we can execute your orders.
• For non-UK equities, we will use the most efficient venue which, to the best of our knowledge, will provide you with the best overall outcome.
• The Execution Venues we use are:
  • The London Stock Exchange and its Member Firms
  • Plus Markets and its Member Firms
  • Other Recognised Investment Exchanges (Regulated Markets) and their Member Firms
  • Systematic Internalisers
  • CoFunds plc and individual Unit Trust Managers
  • Other venues we are using now, or may in the future, include Euronext.liffe and its Member Firms, BOAT and Chi-X.
• We regularly assess the execution venues available and may add or remove venues in accordance with our obligation to provide you with the best possible execution result on a consistent basis.
• The FSA rules require you to give express consent before we can execute your order outside a Regulated Market or Multilateral Trading Facility (MTF), i.e. dealing offexchange. We believe that it is in your best interest that we are able to deal in as many markets and use as many Execution Venues as possible, in order that we may give you the best possible outcome.
• By consenting to this OEP, you are expressly consenting to Walker Crips Stockbrokers Limited using Execution Venues which are outside a Regulated Market or MTF.
• Where your express consent is denied, or not received, you may be limiting our ability to provide you with the best possible outcome for your orders.

Limit Orders:

• Limit Orders are orders which you give to us with specific parameters, for example, orders with a specific price or specific size which cannot be immediately executed.
• Limit Orders placed on the LSE Order Book will be automatically executed if the limit price which you have set can be achieved. Limit Orders which cannot be placed on the LSE Order Book will only be accepted for execution on a best endeavours basis. Limit Orders will expire at the end of the business day and must be renewed if required on the following day.
• The FSA rules require your unexecuted Limit Orders to be made public unless you expressly instruct us not to make it public. We believe that it is in your best interest that we do not make your Limit Orders public and by consenting to this OEP, you are expressly instructing Walker Crips Stockbrokers Limited not to make such orders public, unless we feel that it is in your best interest to do so.
• Where your express consent is denied, or not received, we will attempt to make your Limit Order details known to the market and if there are additional costs in doing so, we will notify you and this cost will have to be passed on to you.