Best Execution Disclosure Statement
Introduction
When executing your orders, CEL will take all
reasonable steps to obtain the best possible result
for you. This does not mean that we will obtain
the best possible result for each order; rather we
will apply our execution policy to each order
with a view to obtaining the best possible result.
This is known as “best execution”. The purpose of
this document is to provide you with appropriate
information about our execution policy.
Our commitment to provide you with best
execution does not mean that we owe you any
fiduciary responsibilities over and above the
specific regulatory obligations placed upon us or
as may be otherwise contracted between us.
Services & Products
CEL offers to provide the following services to its
clients:
Executing orders; and Receiving and transmitting
orders.
The arrangements for achieving the best possible
result, whether in terms of price or otherwise,
differ according to the capacity in which the
Company is acting. Further information on how
we will provide best execution in relation to each
service is provided below.
CEL offers the above services in relation to shares
admitted to trading on AIM. AIM is not a
regulated market (as defined by the FSA).
The Execution Factors
When executing orders or receiving and
transmitting orders on your behalf, CEL will have
regard to the following criteria (known as ‘execution
factors’):
- 1. Price;
- 2. Costs;
- 3. Speed;
- 4. Likelihood of execution and settlement;
- 5. Size;
- 6. Nature; or
- 7. Any other consideration relevant to the
execution of an order
The best possible result for your orders will be
determined by reference to the total consideration
involved in the execution of the order. This means
that CEL will have regard to both the price at
which the security is traded as well as any costs
related to execution.
CEL will only place other considerations, such as
market impact and likelihood of execution, over
price where we believe that it is necessary to do
so in order to deliver the best result for you.
Execution Arrangements
CEL may either execute your orders itself or
it may transmit the order to a third party for
execution. The arrangements for achieving the
best possible result, whether in terms of price
or otherwise, differ according to the capacity in
which the Company is acting. The capacity in
which CEL is acting will be made clear to you at
the time of trading.
Executing Orders
Where CEL executes your orders it will always do
so by trading with you as principal.
This means that CEL will sell securities to you
from its own account (and vice versa).
CEL does not offer access to any other execution
venues when executing your orders.
Transmitting Orders
CEL may transmit your orders to a third party for
execution. Where it does so CEL will act as agent
for you. CEL has selected the parties to which it
will transmit your orders based on the following
considerations:
The entities are themselves subject to the
obligation to provide best execution;
Each entity is a member of the LSE and has
access to market makers for AIM listed
securities; and
The costs associated with each entity are
reasonable having regard to the market as a
whole.
When transmitting a client order to a third party
broker, CEL will have regard to the Execution
Factors as set out above (i.e. that price is the
determining factor).
Orders Above Standard Market Size
For orders which are above the standard market
size, other factors may become instrumental in
delivering the best possible result for you. Market
impact and likelihood of execution may outweigh
price considerations, particularly if there is
limited liquidity in a security.