Ravenscroft (CI) Limited, Ravenscroft Investment Management Limited and Ravenscroft Cash Management Limited
• At Ravenscroft (‘the firm’) the clients comes first.
• This policy documents the ways in which the firm ensures that it provides a quality service 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.
To ensure that the firm adheres to Regulatory requirements in relation to timely and best execution.
If the firm is providing an execution only service this must be clearly documented in the application form which is signed by the client and the firm.1
• The client must be provided with adequate detail in relation to the terms on which the service is being provided. This is provided in the Terms of Business.
• When provided an execution only service to a client it is important that the firm does not provide advice to that client.
• The client categorisation / classification is important in relation to this policy because some client types do not benefit from certain protections and the firm must ensure the client is aware of this e.g. in Guernsey timely execution, best execution, client order priority and timely and fair allocation does not apply if the client is categorised as an eligible counterparty.
• RL-CI, RIML and RCML must adhere to the Guernsey Financial Services Commission’s (‘GFSC’) Licensees (Conduct of Business) Rules 2016 (‘COB Rules’).
• The most relevant principles in relation to this policy are that RL-CI and RIML :
o Must observe high standards of integrity and fair dealing in the conduct of its business; and
o Should act with due skill, care and diligence toward its customers and counterparties.
o Should observe high standards of market conduct.
• Ravenscroft (CI) Limited in Jersey must adhere to the Jersey Financial Services Commissions (‘JFSC’) Code of Practice for Investment Business.
• The most relevant principles in relation to this policy are that RL-CI in Jersey must:
o Conduct its business with integrity;
o Have the highest regard for the interests of its clients.
• The firm must deal with client order and its own orders fairly and in due turn.
• Once the firm has agreed to place a client order it must effect or arrange the execution of the order as soon as reasonably practicable.
• The firm can postpone execution if it believes that this is in the client’s best interests, however such a decision must be documented and must be easily retrievable.
• The firm must seek to provide best execution, unless a specific instruction has been received from the client in writing.
• The firm executes trades directly through the London Stock Exchange3 or the International Stock Exchange. It also uses the services of the brokers / market makers when trading on the London Stock Exchange where necessary. All others trades are placed through brokers. The firm only utilises the services of brokers that it believes will provide best execution 4.
• Best execution is achieved if:
o The firm takes reasonable care to ascertain the price which is the best available for the client in the relevant market at the time for transactions of that kind; and
o The firm deals at a price which is not less advantageous to the client, unless required to do so in the interests of the client.
o The firm 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 may only be given precedence over the immediate price consideration insofar as they are instrumental in delivering the best possible result to the retail client.
• The firm must ensure that any transactions it executes are promptly allocated.
• Where the firm 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:
o The firm must not give preference to itself or to any one for which it dealt;
o If the firm cannot satisfy itself that all orders can be achieved, it must 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
o Jersey : Where a registered person has aggregated a client order with its own or other clients orders it must allocate back to the client within 24 hours.
• The Compliance Department undertake a testing programme whereby they select a sample of orders to ensure they have been executed in accordance with this policy.
• Findings may be indicative of systemic issues, additional requirements etc.
• Issues identified will be remediated appropriately.
• Significant findings are reported to the relevant Board.
1 This requirement was stressed in the GFSC Thematic Review in Investment and Long Term Insurance Sales Practice which was published in September 2017.
2 The JFSC states that this excludes investments in units in collective investment schemes.
3 The JFSC states that best execution is met when the firm executes an order through the London Stock Exchange.
4 Ultimate responsibility for ensuring best execution rests with the firm and as such appropriate enquiries must be undertaken.