Best Execution Policy

Ravenscroft (CI) Limited ("RL-CI")

OVERVIEW

At Ravenscroft, our clients come first. This policy documents the ways in which Ravenscroft seeks to ensure it provides best execution to its clients.

As a regulated investment firm, there are a number of principles that must be adhered to. Those of most relevance are included in the ‘Jurisdictional Requirements’ section below.

OBJECTIVE

To ensure that Ravenscroft adheres to regulatory requirements in relation to timely and best execution, which means obtaining the best possible results for its clients when carrying out transactions on their behalf.

JURISDICTIONAL REQUIREMENTS

Guernsey

RL-CI adheres to the Guernsey Financial Services Commission’s (‘GFSC’) Licensees (Conduct of Business) Rules and Guidance 2021.

The most relevant principles in relation to this policy are that RL-CI:

• must observe high standards of integrity and fair dealing in the conduct of its business;
• should act with due skill, care and diligence toward its customers and counterparties; and
• should observe high standards of market conduct.

Jersey

RL-CI in Jersey adheres to the Jersey Financial Services Commission’s (‘JFSC’) Code of Practice for Investment Business.

The most relevant principles in relation to this policy are that RL-CI must:

• conduct its business with integrity; and
• have the highest regard for the interests of its clients.

CLIENT CATEGORISATION / CLASSIFICATION

Ravenscroft’s Best Execution Policy applies to all client types in Guernsey and Jersey, bar the following exception:

• In Guernsey, the GFSC’s requirements under The Licensees (Conduct of Business) Rules and Guidance do not oblige Ravenscroft to apply the following in respect of eligible counterparties:
  • client order priority;
  • timely execution;
  • best execution;
  • timely and fair allocation;
  • price at which allocations are to be effected; and
  • series of transactions treated as one.

CLIENT ORDER PRIORITY

Ravenscroft will deal with client orders and its own orders fairly and in due turn.

TIMELY EXECUTION

Once Ravenscroft has decided in its discretion or agreed to place a client order, it will effect or arrange the execution of the order as soon as reasonably practicable in the circumstances.

Ravenscroft can postpone execution of an order if it believes it is in the client’s best interests to do so.

BEST EXECUTION

Ravenscroft seeks to provide best execution, unless a specific instruction has been received from the client in writing.

As a member firm, Ravenscroft executes trades directly through the London Stock Exchange (LSE) or The International Stock Exchange. It also uses the services of market makers and other counterparties when executing orders in the UK and internationally, predominantly relying on:

• Member firms of the LSE
• Member firms of overseas stock exchanges
• Managers and administrators of collective investment schemes and other investments

Ravenscroft only utilises the services of execution venues/market makers/counterparties which it believes accord with its Best Execution Policy. As part of its approach to achieving the best possible result for clients, Ravenscroft may execute transactions in investments outside of a regulated market or multi-lateral trading facility where it thinks fit.

Best execution is achieved if Ravenscroft:

• takes reasonable care to ascertain the price which is the best available in the relevant market at the time for transactions of the kind and size concerned; and
• deals at a price which is not less advantageous to its client, unless required to do so in their interests.

In applying best execution, Ravenscroft has regard to the:

• best price;
• likelihood of execution and settlement at that price;
• costs of execution; and
• nature of the order.

Speed of execution, likelihood of execution and settlement, size and nature of the order, market impact and any other implicit transaction costs will only be given precedence over the immediate price consideration insofar as they are instrumental in delivering the best possible result for our clients.

TIMELY AND FAIR ALLOCATION

Ravenscroft will ensure that any transactions it executes are promptly allocated.

Where Ravenscroft has aggregated an order for a client transaction with an order for its own account or with another client order, then in the subsequent allocation:

• Ravenscroft will not give preference to itself or to any of those for whom it dealt;
• if Ravenscroft cannot satisfy itself that all orders can be achieved, it will give priority to satisfying client orders unless it believes that, without its own participation, it would not have been able to effect those orders; and
• it will allocate the order back to the client within 24 hours.

MONITORING AND REVIEWING

Ravenscroft monitors compliance with and the effectiveness of its Best Execution Policy.

Trade analysis is undertaken by the Trading team, with additional oversight and challenge provided by both the Compliance team and senior management.