Execution Policy

Objective

To put in place an Order Execution Policy to enable Fundamental Asset Management Limited (hereinafter referred to as ‘FAML’) when it is providing portfolio management services to clients to comply with the obligation in the Conduct of Business Sourcebook (‘COBS’) 11.2 of the Financial Conduct Authority. The obligation is to take all reasonable steps to obtain the best possible result for its clients (taking into account the execution factors) when placing orders with other entities for execution that result from decisions by FAML to deal in financial instruments on behalf of its clients.

Policy

Identify in respect of each class of instruments, the entities with which orders are placed and confirm that the entities identified have execution arrangements that enable the firm to comply with its best result obligation.

FAML uses a number of specialist execution brokers for all classes of instrument in which FAML deals, being principally shares listed on the Official List of the UK Listing Authority, shares quoted on other major overseas exchanges, AIM, corporate bonds and Contracts for Difference.

FAML considers that the execution services IG, ODL and Cenkos provide are keenly priced and efficiently provided both online and by telephone.

FAML has reviewed IG’s, ODL’s and Cenkos’ Best Execution Policy and is satisfied that the arrangements set out in it will enable FAML to comply with its best result obligation.

Monitoring of the Policy

Monitor on a regular basis the effectiveness of the policy and in particular the execution quality of the entities identified in that policy

FAML shall review the policy regularly and in any event at least annually.
FAML shall review the policy whenever a material change occurs that affects the firm’s ability to obtain the best possible result for its clients.

In conducting such reviews FAML shall explore the execution services that are available from other execution brokers.

April 2010