Order Execution Policy

Jarvis Investment Management Ltd (“Jarvis”) is required to establish and implement an order execution policy and to provide appropriate information on its order execution policy to its clients. This information about Jarvis’s order execution policy is applicable to all retail clients of Jarvis.

1. General Principles

When executing or routing orders in relation to financial instruments on your behalf, we will take all reasonable steps to achieve what is called ‘best execution’. This means that our policy and procedures are designed to obtain the best possible execution result, subject to and taking into account your characteristics, client classification (categorisation as a retail client) and the characteristics of the order, the financial instruments that are the subject of that order and the Execution Venues to which that order can be directed.

Our commitment to provide our clients with best execution does not mean that we have any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or as may be otherwise contracted to.

2. Order Execution Policy

Subject to any specific instructions from you, when executing orders on you behalf or transmitting them to another entity for execution, we shall take all reasonable steps to achieve the best possible execution result for you order taking into account the execution factors listed below.

Execution Factors

The execution factors that will be taken into account are:

  • price;
  • costs of the transaction;
  • speed of execution;
  • likelihood of execution and/or settlement;
  • size and complexity of the order; and
  • characteristics and nature of the order.

Ordinarily price and overall costs for transacting the deal will merit a high importance in obtaining the best execution result for the order. However, in some circumstances we may determine that other factors listed above may be more important in determining the best execution result for the order. We will exercise our own discretion in determining these factors.

Execution Venues

Jarvis will execute deals through:

  • Regulated markets - a large proportion of the orders we execute is traded on the London Stock Exchange
  • Multilateral Trading Facilities
  • Systematic internalisers
  • Market makers for their own account
  • Other liquidity providers
  • Non-EU entities performing similar functions

For certain transactions, such as those where the security is traded by a limited number of entities, Jarvis may use alternatives where we consider it is in your best interests to do so.

Where we consider it preferable, we may execute you order outside a Regulated Market or Multilateral Trading Facility even where that order could be executed through one of these.

3. Delivering Best Execution

Having given consideration to the Execution Factors and General Principles referred to above, we will select the most appropriate venue(s) from those available and execute your order accordingly.

If you give a specific instruction with regard to order execution, you should be aware that this may mean that you will not achieve the best outcome on that trade. Jarvis will carry out the order in accordance with your specific instruction and will be deemed to have complied with the best execution requirement to the extent of that instruction.

4. Review and Monitoring

Jarvis will monitor execution quality and compliance with our Execution Policy on an on-going basis and will at least once a year make a formal assessment of its dealing policies. You will be notified of any material changes to the Execution Policy.

5. Limit Orders

In the case of client limit orders in respect of shares admitted to trading on a regulated market which are not immediately executed under prevailing market conditions, unless you expressly instruct otherwise, we are required to take measures to facilitate the earliest possible execution of that order by making public immediately your limit order in a manner which is easily accessible to other market participants. Such publication may not always be in your interest so unless you give explicit instructions to publish at the time that you place the order with us, we shall deem that you have instructed us not to publish.

The circumstances when which we can publish your Limit Order(s) are:

  • The Limit Order must be placed by telephone during normal market hours;
  • The order size must be within the normal market size dictated by the market upon which the stock is listed, i.e. London Stock Exchange (LSE);
  • The stock must be an “order driven stock”, i.e. a stock that can be published on the LSE order book;
  • You may only choose a settlement period of T+2; and
  • The limit order is ‘Good for The Day’ i.e. your order will be published until the market closes on the same day.

X-O.co.uk is a brand name of Jarvis Investment Management Ltd (Jarvis), which is authorised and regulated by the Financial Conduct Authority. Jarvis is a member of the London Stock Exchange and NEX Exchange, and is an HM Revenue & Customs Approved ISA Manager. Registered office: 78 Mount Ephraim, Tunbridge Wells, Kent, TN4 8BS. Registered in England number 1844601. VAT registration number 680 0400 74