Effective January 2024

Effective January 2024, RF Advisors Limited has established an Order Execution Policy in compliance with the Markets in Financial Instruments Directive II (MiFID II) and Chapter 11.2A of the Conduct of Business Sourcebook (COBS). This policy ensures that clients receive the best possible outcome when executing their orders with RF Advisors Limited.

Products in Scope

This policy applies to all financial instruments as defined by MiFID II, including shares, bonds, unit trusts, structured products, and derivatives, irrespective of their public listing status. Best execution obligations extend to all such instruments, regardless of their trading venues.

Application of Best Execution – Client Classifications

  • Retail Clients: RF Advisors Limited is committed to providing best execution to retail clients, who are presumed to rely on the firm to protect their interests. This obligation applies whenever RF Advisors Limited executes orders for retail clients, except when specific instructions are provided by the client (see “Specific Instructions” below).
  • Professional Clients: Best execution is provided to professional clients when they rely on RF Advisors Limited to protect their interests, assessed on a transaction-by transaction basis.
  • Eligible Counterparties: Best execution obligations do not apply to Eligible Counterparties, such as firms classified under this category by RF Advisors Limited.

Order Execution Factors

When executing orders, RF Advisors Limited considers several factors:

  • Client characteristics
  • Financial instruments involved
  • Execution venues

Additional considerations include price, order size, speed and likelihood of execution, likelihood and speed of settlement, costs, and any other relevant factors. The priority of these factors may vary depending on client classification and will be determined on a case-by-case basis.

Execution Factors Explained

  • Price and Size: For most liquid instruments, price is the primary factor for achieving best execution, especially for retail clients where the order size does not limit RF Advisors Limited’s choice of venue. However, in larger orders, the best market price may not always be available due to size. In such cases, RF Advisors Limited will use reasonable judgment to achieve the best execution possible.
  • Speed and Likelihood of Execution: In some situations, speed and likelihood of execution may take precedence over price, particularly if a client requires prompt execution. In other cases, a client may prefer a large trade to be staggered to minimize market impact. RF Advisors Limited will discuss the importance of price versus speed with the client to understand their preferences.
  • Likelihood of Settlement: As most of RF Advisors Limited’s business involves shares quoted on global exchanges with centralized clearing and settlement, the likelihood of settlement is not considered a critical factor in achieving best execution.
  • Costs: When explicit costs, such as exchange fees or settlement costs, could make the total consideration prohibitive, these may take precedence in determining the execution venue. In some cases, other factors may outweigh price considerations, such as for Unit Trusts which  have one price and venue.

Execution Venues

RF Advisors Limited selects from a set of execution venues, including:

  • Regulated markets (RMs) under MiFID II, such as the London Stock Exchange
  • Multilateral Trading Facilities (MTFs) and Organised Trading Facilities (OTFs)
  • Market makers, systematic internalisers, and other liquidity providers Third-party investment firms and brokers

RF Advisors Limited retains the obligation to ensure the best possible result for the client, even when passing an order to a counterparty (e.g., a broker) for execution. Venue selection criteria include historical performance, extent of services enabling us to meet client obligations, market reputation, and due diligence outcomes. Venues are regularly reviewed and adjusted to ensure compliance with best execution requirements. A current list of execution venues RF Advisors Limited relies on can be found on our website.

By agreeing to our Order Execution Policy and Terms of Business, you consent to RF Advisors Limited executing orders outside a Regulated Market (RM) or MTF when it is deemed appropriate.

Valuation of Unlisted Securities

For private, unlisted securities, pricing is typically based on prior transactions. Changes to this price will be based on subsequent fundraising or other relevant public information. For delisted stocks, a fair value price (FVP) will be determined by public information and reviewed quarterly to ensure accuracy.

Specific Instructions

If you provide specific instructions for an order, RF Advisors Limited may not follow all the steps in this policy, potentially limiting our ability to achieve best execution. While we will take sufficient steps to get the best results, there is a risk we may not achieve best execution in respect of the aspects covered by your specific instruction.

Publishing Limit Orders

If you provide a limit order, we may not always be able to execute it under prevailing market conditions. By agreeing to this policy, you consent that we will not publish your limit order unless it is in your best interest.

Dealing Arrangements

All orders are managed by a centralized dealing desk. Orders from portfolio managers are routed electronically to the trading desk, which is responsible for executing the orders according to this policy.

Aggregation and Allocation

RF Advisors Limited may aggregate orders when it believes it is in the client’s best interest. Aggregation may, on rare occasions, result in a worse price than if the order were executed separately. When allocating aggregated transactions, orders will be allocated pro rata to ensure fairness.

Monitoring and Reviewing

RF Advisors Limited’s compliance department regularly monitors order execution to ensure compliance with this policy. Any material changes will be communicated to clients, and the latest version of this policy will be available on our website.

Client Declaration

By agreeing to RF Advisors Limited’s Terms and Conditions and signing the account opening form