Best Execution Policy Update

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The firm has an obligation to execute orders on behalf of its clients on terms that are the most favourable at the time the order is executed. We take into account execution factors such as price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of an order.

The firm does not act as principle to any trade. Therefore, when trades are negotiated with other market participants, the firm is acting as agent.

The firm currently uses two electronic dealing platforms, Pro-Quote and Thomson Financial. Once the firm’s trader requests a quote price for a particular stock the platforms choose from the current Retail Service Providers (RSP) (member firms of the London Stock Exchange) who offer quotes in that stock, the current best bid or offer price. The trader can hold that price for 20 seconds. Once a quote has been obtained the dealer will execute the order should that price be acceptable to you unless he is instructed to re-quote. That quote, if accepted is deemed to be the best possible price even if the price changes within the 20 seconds before actual execution of the trade. We assume that any price change within 20 seconds would not make the original quote manifestly out of date.

The firm uses two electronic trading platforms to assist with business continuation, however it is possible there maybe a very slight price difference between the RSP’s quoting on the two platforms, which ever platform the dealer uses will be deemed to be in line with the firm’s best execution policy.

Where electronic trading facilities do not exist the firm will telephone the RSP’s who are making the best quote in the chosen financial instrument to place the order at the best price possible taking into consideration the size of the order and the speed of execution.

Currently the firm executes trades on regulated markets such as the London Stock Exchange (LSE) and Multilateral Trading Facilities (MTF) such as Aim or Plus Markets. Before we would be able to execute a trade outside of these markets we  require your prior consent on a bargain by bargain basis, outside these markets could be over the counter (OTC) or agency cross by crossing your order with that of an opposing client.

Unit trust deals are traded directly with the individual managers at a fixed price on any given dealing day, these prices are usually available in financial sections of newspapers or on the managers own websites.

When dealing in a financial instrument we will exercise our discretion in assessing the criteria we need to take into account to ensure we provide best execution, this criteria for instance may be safe custody charges, execution venue fees or clearing and settlement fees. However our aim is to deliver the best possible result in line with this execution policy.

Orders will normally be executed in the same order as they are received except where there are special conditions such as price limits or limited liquidity.

Please note that any specific dealing instruction from you may prevent us from taking the steps within this policy to obtain the best possible result for you.

We will monitor the effectiveness of this policy and should a material change occur we will post an updated version of this document here on our website.

This policy came into force November 1
st 2007, clients dealing through us on or after that date will have been deemed to have accepted our policy.

Further details can be found on our terms and conditions page or by phoning 0161 832 6581.

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PILLING & CO.
INDEPENDENT STOCKBROKERS SINCE 1893
MEMBER OF THE LONDON STOCK EXCHANGE AND A.P.C.I.M.S.
Authorised and Regulated by the Financial Services Authority No. 141242

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