A.1 Introduction

The purpose of this document is to provide clients of Collidr Asset Management Limited (“Firm”) with information about the Firm’s best execution policy and to seek their consent to that policy.

The Firm currently has two business lines:

1. The management of funds; and
2. The discretionary management of model portfolios on investment platforms.

It is only in the management of funds that the Firm has a direct role in the execution of trades. Where financial products are traded within a model portfolio, all trades are undertaken by the investment platform or it sub -custodian(s) and their best execution policies and procedures will apply.

The Firm is required to take all sufficient steps to obtain the best possible results (“Best Execution”) on a consistent basis on behalf of its clients when executing orders taking into account the execution factors (“Strong Execution”).

The Firm is required to act in accordance with the best interests of its clients when transmitting or placing orders with other entities for execution that result from decisions to deal, and to take all sufficient steps to obtain the best possible result for the client taking into account the execution factors (“Indirect Execution”).

A.2 Order Execution

The Firm executes orders for all financial instruments it trades, other than OTC Products and open ended collective investment schemes, via direct market access (“DMA”) (i.e. electronic facilities that are designed allow the Firm to benefit from a better cost for financial securities the Firm may seek to buy or sell). DMA trades are undertaken using Bloomberg ESMX, via one of the Firm’s approved brokers;

Orders for OTC products (except units in open-ended collective investment schemes) are placed directly with one of the Firm’s approved brokers; and

Orders for units in open-ended collective investment schemes are placed directly by way of Clearstream and Neolink.

A.3 Execution Factors

When executing orders, the Firm will take all sufficient steps to achieve Best Execution, subject to and taking into account, any specific instructions from the client, the nature of such orders, the priorities its clients’ place upon it in filling those orders and the nature of the markets and products in question.

In order to deliver Best Execution, the Firm uses its knowledge, experience and judgement to execute trades on behalf of its clients taking into consideration a number of execution factors including:

• The price that the order can be executed at;
• The costs of execution of the transaction to the client;
• The speed of execution of the transaction;
• Market accessibility;
• The likelihood of achieving execution and settlement;
• The nature of the order; and
• Any other consideration relevant to the execution of the specific order (the “Execution Factors>”).

A.4 Execution Criteria

The Firm is required to determine the relative importance of the Execution Factors for its clients by taking into account the following criteria:

• The characteristics of the client, including the categorisation of the client;
• The characteristics and nature of the client order;
• The characteristics of the financial instruments that are the subject of that order; and
• The characteristics of the execution venues/brokers to which that order can be directed (the “Execution Criteria”).

In considering the Execution Criteria and the importance of the Execution Factors, the Firm also takes into account the client’s understanding and experience of the market in question, the client’s dealing profile, the nature of the dealing service the client requires and the specific and general instructions given to the Firm by the client which may prioritise how the Firm fills client orders.

A.5 Execution Venues And Brokers

The Firm will primarily select the execution venue or broker that in the Firm’s judgment is the most appropriate, taking into account the Execution Factors and Execution Criteria. The Firm will also consider the market coverage and market intelligence that the execution venue or broker can provide and other relevant qualitative factors.

The Firm has identified those venues on which it most regularly executes and which the Firm believes offer the best prospects for affording its clients Best Execution. These venues are separately disclosed within the Firm’s RTS28 disclosure.

In selecting the most appropriate venues for the purpose of executing client orders, the Firm will take into full account the Execution Factors and Execution Criteria relevant to the order, and the following:

• what the Firm reasonably assesses to be its clients’ best interests in terms of executing the orders; and
• such other factors as may be appropriate, including the ability of the venue to manage complex orders, the speed of execution, the creditworthiness of the venue and the quality of any related clearing and settlement facilities.

The diversity in the markets and instruments in which the Firm trades mean that different factors will have to be taken into account when the Firm assesses the nature of its Policy in the context of different instruments and different markets. In some markets, price volatility may mean that the timeliness of execution is a priority, whereas, in other markets that have low liquidity, the fact of execution may itself constitute Best Execution. In other cases, the Firm’s choice of venue may be limited (even to the fact that there may only be one platform/market upon which the Firm can execute client orders) because of the nature of the client order or of specific client requirements.

A.6 OTC Products

When executing orders in OTC products, the Firm assesses whether the price quoted is “fair” by undertaking systematic checks to undertake appropriate valuation and taking into account market data on comparable products where available.

A.7 Detailed Requirements For Each Financial Instrument Class Traded

A.8 Specific Instructions

To the extent that the Firm follows specific instructions from a client when placing an order with, or transmitting an order to, another entity for execution, such instructions supersede this Policy and the Firm will be deemed to have complied with its Best Execution obligations by following the clients’ specific instructions. Specific client instructions may prevent the Firm from taking the steps it has implemented in this Policy to obtain Best Execution. It is likely to be only in rare circumstances that the Firm would receive such specific instructions. In general the Firm will make all dealing decisions itself in its capacity as discretionary portfolio manager.

A.9 Monitoring And Review

The Firm actively monitors the effectiveness of its best execution arrangements and policy. The Firm’s processes are designed to ensure that monitoring assists the Firm in delivering Best Execution for its clients on a consistent basis.

The Firm’s senior management is responsible for ensuring that robust business practices are operating in all its trading activities to deliver Best Execution on a consistent basis and for promoting a culture that proactively identifies and manages conflicts of interest.

The Firm will regularly, and at a minimum annually, review its best execution policy and execution procedures and will notify its clients of any material changes to them.