Holbein Partners LLP

Best Execution Policy

Overview

The purpose of this document is to provide clients of Holbein Partners LLP (‘we’, ‘our’, ‘Holbein’) with information regarding our Best Execution Policy.

Holbein is required by the Markets in Financial Instruments Directive (‘MiFID II’) and the Financial Conduct Authority (‘FCA’), to implement a Best Execution Policy and to make this publicly available on our website.

The Best Execution Policy outlines all of the reasonable steps that Holbein must take to ensure that we achieve ‘best execution’ in obtaining the best possible results for our clients when carrying out transactions on their behalf.

Specific Client Instructions

Holbein places all orders with approved counterparties or the client’s custodian bank, and are thus considered passive orders. We do not place orders directly with trading venues and do not accept instructions from clients to direct orders to a trading venues and do not therefore undertake Directed orders.

Order Aggregation

Holbein provides services to Professional and Retail clients. In executing orders on behalf of clients no distinction is made between client types and all therefore all clients are treated equally. We may combine or aggregate an order for our clients with orders of other clients.

Execution Venues

We are regulated by the FCA to manage client assets, but we do not hold them. Client assets are held by appointed third-party custodians. Therefore, our best execution obligations to the client are met as we have no discretion to influence the execution outcome. However, as the custodians that our clients use are subject to MiFID, they will be required to comply with their own best execution obligations.

Trade Execution Dealing Arrangements

Equities - We do not execute equity trades for our clients directly with the market. These types of trades will be placed with the client’s appointed custodian who is responsible for execution. Clients should refer to their custody terms for further information.

Collective Investment Schemes - We do not execute collective investment scheme trades for our clients directly with the market. These types of trades will be placed with the client’s appointed custodian who is responsible for execution. Clients should refer to their custody terms for further information.

Debt Securities - We do not execute debt security trades for our clients directly with the market. These types of trades will be placed with the client’s appointed custodian who is responsible for execution. Clients should refer to their custody terms for further information.

ETFs - We do not execute ETF trades for our clients directly with the market. These types of trades will be placed with the client’s appointed custodian who is responsible for execution. Clients should refer to their custody terms for further information.

Foreign Exchange - We do not execute FX trades for our clients directly with the market. These types of trades will be placed with the client’s appointed custodian who is responsible for execution. Clients should refer to their custody terms for further information.

Structured Products - We do not execute structured product trades for our clients directly with the market. These types of trades will be placed with the client’s appointed custodian who is responsible for execution. Clients should refer to their custody terms for further information.

Derivatives - We do not execute derivative product trades for our clients directly with the market. These types of trades will be placed with the client’s appointed custodian who is responsible for execution. Clients should refer to their custody terms for further information.

Commodities & Precious Metals - We do not execute commodities and precious metal trades for our clients directly with the market. These types of trades will be placed with the client’s appointed custodian who is responsible for execution. Clients should refer to their custody terms for further information.

Limited Liability Partnerships (‘LLPs’) - LLP arrangements are classified as unregulated collective investment schemes. These are illiquid investments and cannot be sold by the investor except on a matched basis as the execution for LLPs is usually the operator of the LLP. Therefore, it will not be possible to take into account the execution factors that would apply to a market listed security and clients will therefore be subject to the price determined by the operator or its agent.

Investments in Private Companies - It will not be possible to take into account the execution factors that would apply to a market listed security when transacting in securities in private companies and clients will execute at a price and on terms agreed with the private company or their appointed agent.

Monitoring

To assist with the review of our Best Execution arrangements, Holbein has put in place processes to monitor our obligations and provide clients with the best possible execution.

Recommending a Custodian: When deciding which custodian to recommend to a client, the best execution arrangements of the custodian will be a primary consideration in addition to several other factors.

Monitoring: Both the effectiveness of our execution policy and the execution procedure of our counterparties, is monitored by us on a regular basis.

Payments

Holbein does not receive any payments, discount, rebates, or non-monetary benefits as a result of trading relationships, and does not trade with any affiliates.

Review

This policy is subject to an annual review or when there is a material change that occurs that affects our ability to continue to obtain the best possible result for our clients.

Holbein Partners LLP