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Best Execution Policy

This best execution policy forms part of the agreement between you and Lakeview Capital Market Services GmbH. References in this best execution policy to "we", "us", or "our" are references to Huddlestock Limited and Huddlestock Group of Companies (Huddlestock Limited and Huddlestock Capital AS) together, except where the context requires otherwise.

This best execution policy summarises how we obtain the best possible execution result for you across all the asset classes in which you may invest. These procedures will vary depending on what type of client we categorise you as, and what type of financial instrument is being sold or traded. This best execution policy sets out the factors we take into account when looking to obtain the best possible execution result, as well as the relative importance we place on each of those factors.

By using our service, you agree we may act in accordance with this policy.

  1. 1. Factors we take into account when arranging for your deals to be placed

    1. 1.1.

      When your investments are bought and sold, we take into account a number of factors to determine the best way to place your order. These factors include:

      1. 1.1.1.

        the total price you pay for the investment, including any costs;

      2. 1.1.2.

        the speed at which we can complete the deal on your behalf;

      3. 1.1.3.

        the likelihood of executing your order;

      4. 1.1.4.

        the size of your order;

      5. 1.1.5.

        the nature of your order; and

      6. 1.1.6.

        any other consideration relevant to order execution.

    2. 1.2.

      When executing your order, we will take into account the following criteria for determining the relative importance of the factors referred to above:

      1. 1.2.1.

        your categorisation as either a retail or professional client;

      2. 1.2.2.

        the characteristics of your order;

      3. 1.2.3.

        the characteristics of financial instruments that are the subject of your order; and

      4. 1.2.4.

        the characteristics of the execution venues to which that order can be directed.

    3. 1.3.

      If you have been categorised as a retail client (please see our terms and conditions for more information on your categorisation), then the most important factor we take into account when handling your orders is the total price (including any costs) you will incur or receive for the order. There may be circumstances where we give other factors more importance in order to deliver you the best possible result.

    4. 1.4.

      If you are a professional client, then we may consider other execution factors to be more important than price to make sure that we obtain for you the best possible execution result. Price will, however, always merit a high relative importance when we take into account all execution factors.

    5. 1.5.

      For all our clients, the relative importance that we give to the execution factors above is designed to obtain the best possible execution of you orders.

    6. 1.6.

      The Investment Ideas that we produce and distribute to you may cover a whole range of asset classes, from equities to government bonds. Therefore our best execution procedures will also take into account the different circumstances associated with the execution of orders related to a particular asset class.

    7. 1.7.

      Please see Appendix 1 for the execution processes and procedures in place to deliver you the best possible execution result for each available asset class to you as an investor.

  2. 2. Places where your deals are executed

    1. 2.1.

      A critical part of ensuring that we provide you with the best possible execution result is the selection of execution venues where your investments are bought and sold. This service will be provided by third-party brokers who will place your orders with execution venues appropriate for the relevant asset class and underlying financial instrument.

    2. 2.2.

      We have chosen third-party brokers who we think are able to deliver you the best execution result possible on a consistent basis. These third-party brokers are able to provide us with access to execution venues and trading platforms that we might not have access to ourselves, ensuring that the correct and appropriate execution venue is used to provide a high quality execution service.

    3. 2.3.

      Since the third-party brokers we select are able to access a whole range of execution venues to satisfy an order, we do not have control over a third-party broker’s choice of execution venue, and we do not control the implementation of a third-party broker’s order execution arrangements or duplicate its own monitoring efforts it uses to execute orders. We have in place effective third-party broker monitoring, ensuring a consistent scrutiny of our third-party brokers, which allows us to assess whether the third-party brokers consistently obtain best execution results for you.

    4. 2.4.

      Please see Appendix 2 for a list of the third-party brokers that we use for execution.

  3. 3. Specific instructions

    If you give us a specific dealing instruction, we will execute your order according to your instruction. This may limit the degree to which we can obtain best execution for you. In any event, we will try to deliver the best possible execution result in respect of that order, in accordance with this best execution policy.

  4. 4. Aggregation of client orders

    1. 4.1.

      In order to obtain and deliver the best possible execution result for your order, it may be necessary that we aggregate your order with that of another client, for example where the aggregated orders relate to the buying or selling of a certain underlying financial instrument.

    2. 4.2.

      Where we aggregate orders, this may work to the disadvantage of a particular individual trade; however, we will only aggregate orders where we believe that it is unlikely that the overall effect of the order aggregation will not work to the disadvantage of any client whose order is to be aggregated.

    3. 4.3.

      In addition, where an aggregated order is only partially executed, we will ensure that the related trades are re-allocated in a fair and consistent way in accordance with our order allocation policy, and where possible, on a pro-rata basis relating to the size of each client’s order and the overall size of the aggregated order.

  5. 5. Annual review and monitoring

    1. 5.1.

      We monitor the effectiveness of our order execution arrangements and this policy so that we can identify and, where appropriate, correct any deficiencies to ensure we are obtaining the best possible results for you. Our third-party broker monitoring assesses on a regular basis whether our third-party brokers (as listed in Appendix 2) are able to provide for the best possible result for you and your investments.

    2. 5.2.

      We will review this policy annually, and we will let you know if we make material changes to this policy. Our website contains the most up-to-date version of our execution policy.

Last Updated: 3rd January 2017

Appendices

1. FINANCIAL INSTRUMENTS

The processes and procedures we implement to obtain the best possible execution result for our clients will vary depending on market structures and the structure of the underlying financial instrument of the investment. Below is a list of asset classes in which you will be able to invest, and the procedure involved in executing orders for each asset class:

  1. 1. Equities
  2. 2. Exchange traded funds and exchange traded commodities
  3. 3. Bonds and loans
  4. 4. Derivatives
  5. 5. Collective investments
  6. 6. Foreign exchange

In all cases:

Our primary consideration is total price net of costs, we will then seek to execute as much of each order as possible without breaching order-specific market impact criteria.

When selecting a broker we primarily take into account the track record for each of their execution algorithms, then their exchange memberships and finally geographic and product coverage.

At this point, we only intend to trade spot FX for hedging purposes. We will aim to neutralise every account to significant FX exposures that may adversely affect their value.

2. APPROVED BROKERS LIST

When selecting third-party brokers to provide you with the best possible results for your trades, we take into account the track record for each of their execution algorithms, their exchange memberships and their geographic and product coverage.

Please see below a list of approved third-party brokers on which we place significant reliance in meeting our obligation to take all reasonable steps to obtain on a consistent basis the best possible result for the execution of your orders:

  1. 1. Saxo Capital Markets UK Limited
  2. 2. Vertem Asset Management / Sapia Partners LLP

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