Order Execution Policy

Introduction

This Policy is intended to provide clients with information relating to the execution arrangements Clim8 Invest has in place to comply with its obligations under the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”). In particular, it sets out how Clim8 Invest will provide clients with best execution, where relevant. 

 The Policy details the information that must be provided to clients regarding the execution criteria and factors that Clim8 Invest will need to consider when trying to obtain the best possible results for those clients. 

In carrying out the activities above we will act in the best interest of our clients and therefore will take all reasonable steps to achieve; 

• the best possible result for our clients on a consistent basis  when executing order. This will be subject to any specific instructions you may give, and any priorities you have identified to us
• comply with the obligation to act in accordance with the best interests of our clients when placing orders with other entities for execution that result from our decisions to deal in financial instruments on behalf of our clients , subject to and taking into account any specific instructions you may give.  

The policy also specifies when the obligation to provide best execution might not apply. 

Order Execution 

When executing client orders we take all sufficient steps to obtain the best possible result (‘best execution’) for our clients taking into account all relevant factors, including:

• costs (implicit and explicit);
• size;
• speed;
• likelihood of execution;
• likelihood of settlement;
• the nature of the order;
• the ability to retain anonymity in the market; and
• the prevention of information leakage.

When executing client orders, Clim8 Invest shall take into account the following criteria for determining the relative importance of the aforementioned Execution Factors:  

a) the characteristics of the client; 

b) the characteristics of the client order; 

c) the characteristics of financial instruments that are the subject of that order; 

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

Where you give us specific instructions, relating to an order or a particular aspect of an order, we will execute the order in accordance with those instructions. This will mean that, in the context of this order or aspect we will not follow our Best Execution Policy. This includes where we are given specific instructions on the use of a broker. Where any instruction relates to only part of the order, we will continue to apply our order execution policy to those aspects of the order not covered by the specific instruction. In any situation where our ability to provide best execution is limited, we will always apply the principle of best efforts to try and achieve the best outcome for clients.

Fees

When executing an order on behalf of a Client, Clim8 Invest may charge an additional fee, commission or mark-up for providing the execution. In determining whether or not Clim8 Invest have provided Best Execution to you on a transaction we will not consider any fees or charges which are charged by us for executing the transaction (e.g. commission or mark-up). Those fees and charges will not be considered to form part of the price for Best Execution purposes. Any fee, commission, or mark-up charged will however:

• be disclosed to you ahead of the placement of the Order, either on a transaction by transaction basis or by prior general disclosure of fee levels for categories of Orders for the Client; and 
• not be set in such a way that it inherently compromises the underlying process of obtaining Best Execution.

Clim8 Invest will not receive any incentives (remuneration, discount or non-monetary benefit) for routing client orders to a particular venue if they will result in Clim8 Invest failing to meet its best outcome obligations or result in contravening requirements on conflicts of interest or inducements

Third Party Execution Brokers

 Where Clim8 Invest owes clients Best Execution on a transaction we may use third party brokers to provide access to markets where we otherwise may not be able to execute or where we believe it to be in your best interests to do so e.g. to source liquidity. Where we owe Best Execution on a transaction and that transaction is passed to a third party broker that has discretion over the execution of any aspect of such transaction (either in whole or in part), we will be relying on that third party broker to execute the transaction in a way which enables us to meet our Best Execution obligation. Clim8 Invest will carry out due diligence on such third party to ensure that we are satisfied that they are enabling us to comply with our Best Execution obligations. 

We will have internal processes and procedures in place to review periodically our choice of third party brokers and dealers to determine that, taking into account all the factors specified above, the third party broker or dealer is providing the best results for your orders on a consistent basis. In making this determination we will have regard to: prices offered for the particular type of instrument over time; 

• average costs per trade charged for the type of trade over time;
• the best execution policy of, and any other guidance issued by, the relevant broker or dealer from time to time. 

Where orders are delegated to third party investment managers, the third party’s order execution policy will apply and they will be responsible for ensuring best execution. We will regularly review whether the execution venues, the brokers and dealers to whom we interact for execution orders continue to provide for the best execution result for you on a consistent basis. 

Execution Venues 

Where a transaction is subject to Best Execution, the selection of an execution venue will be relevant where the execution of the transaction is dependent on our ability to access liquidity (e.g. in the case of an order where we execute transactions as agent). Where the selection of an execution venue is relevant, Clim8 Invest will choose the execution venue (or venues) that we consider to be the most appropriate to meet our obligation to obtain the best possible results for our clients on a consistent basis.

Below is a list of venues that Clim8 Invest’s chosen Third Party use to obtain best execution for its customers. 

• AIM Alternative Investment Market) Trading Venue ETF’s and Funds
• Bloomberg MTF Trading Venue ETF’s and Funds
• CBOE Europe Trading Venue ETF’s and Funds
• Equiduct Trading Venue ETF’s and Funds
• Euronext Belgium Trading Venue ETF’s and Funds
• Euronext France Trading Venue ETF’s and Funds
• Euronext Netherlands Trading Venue ETF’s and Funds
• Euronext Portugal Trading Venue ETF’s and Funds
• London Stock Exchange Trading Venue ETF’s and Funds
• NASDAQ OMX Denmark Trading Venue ETF’s and Funds
• NASDAQ OMX Finland Trading Venue ETF’s and Funds
• NASDAQ OMX Sweden Trading Venue ETF’s and Funds
• NEX Exchange Trading Venue ETF’s and Funds
• The International Stock Exchange TISE Trading Venue ETF’s and Funds
• Turquoise Trading Venue ETF’s and Funds
• Winterflood Trading Venue ETF’s and Funds
• XETRA Frankfurt Trading Venue ETF’s and Funds
• XETRA Germany Trading Venue ETF’s and Funds
• XETRA Ireland Trading Venue ETF’s and Funds
• Order Execution Policy 8
• Execution Venue Venue or Broker Security Traded
• Banca IMI Broker ETF’s and Funds
• Barclays Capital Broker ETF’s and Funds
• Credit Suisse Broker ETF’s and Funds
• Instinet Europe Limited Broker ETF’s and Funds
• ITG Limited Broker ETF’s and Funds
• Morgan Stanley Broker ETF’s and Funds
• Susquehanna Broker ETF’s and Funds
• UBS Limited Broker ETF’s and Funds
• Virtu Financial Broker ETF’s and Funds

Review, Governance and Oversight 

Our Order Execution Policy is formally reviewed at least on an annual basis or promptly should there be any material change in the interim, as explained in more detail below. The purpose of the review is to carry out an overall assessment of Clim8 Invest’s execution arrangements to ensure they are reasonably designed to enable the firm to obtain the best possible result for the execution of its client orders.

The Policy will also be reviewed on the occurrence of a material change in our trading arrangements or a material change in our underlying regulatory obligations 

The Policy is a ‘living document’ and will be periodically updated based on client experience and as a result of our best execution oversight. 

Monitoring Adherence to this Policy 

We monitor our adherence to the Policy and our regulatory obligations in this area through the firm’s compliance risk assessment framework and monitoring programme, with oversight from the ManCo.

Useful Contacts

Additional regulatory information can be found under the FCA website www.fca.gov.uk and the ESMA website www.esma.europa.eu