Best Execution Policy

1. Introduction and Purpose

It is in the best interests of our clients and Söderberg & Partners Financial Planning (“SPFP”, “we”, “us” and “our”) that, when arranging transactions on behalf of clients, we take all sufficient steps to obtain the best possible result.

When we arrange transactions with third parties (such as investment platforms, product providers or fund managers), we are required under the FCA’s Conduct of Business Sourcebook (COBS) to comply with the best execution requirements.

This policy sets out the arrangements we have in place to comply with those obligations. It applies where we arrange transactions in investments, such as collective investment funds and other securities, and should be read alongside the client agreement.

2. Scope

This policy applies to all situations where SPFP arranges or transmits orders on behalf of clients for execution by third parties.

SPFP does not execute client orders directly. Instead, all transactions are arranged through appropriately selected third parties depending on the nature of the investment.

3. Regulatory Context

When arranging transactions for clients, SPFP is required to take all sufficient steps to obtain the best possible result for its clients in accordance with the FCA’s Conduct of Business Sourcebook (COBS).

Best execution requirements apply when we arrange transactions with third parties, including investment platforms, product providers and fund managers.

4. Execution Venues and Third Parties 

An execution venue is any entity or arrangement that executes client transactions, such as a trading venue or product provider.

SPFP does not execute client orders itself. Orders are arranged and transmitted to third parties selected based on the investment involved.

4.1 Investments held on a platform

Where investments are held on one of SPFPs preferred investment platforms (online investment administration services), client orders are placed with the relevant platform.

The platforms currently used are:

• Söderberg & Partners Platform
• Transact

In these cases, the platform is responsible for transmitting client orders to the product provider. For collective investments, the execution price is determined by the fund manager in accordance with the fund’s dealing basis rather than by the platform.

4.2 Investments not held on a platform

Where investments are held directly with a product provider or fund manager, client orders are placed directly with that provider.

4.3 Other investments

For other types of investment, orders are arranged with an appropriate third party relevant to the specific investment.

SPFP regularly assesses the third parties available to ensure that, on a consistent basis, they enable the firm to obtain the best possible result for clients. Third parties may be updated following such assessments.

The third parties to whom orders are transmitted have their own obligations in relation to best execution and order handling. SPFP undertakes periodic monitoring to assess the quality of execution provided.

5. Execution Factors

When arranging and transmitting orders for execution, SPFP considers the following execution factors:

• Price
• Costs
• Speed
• Likelihood of execution and settlement
• Size of order
• Nature of the order
• Any other consideration relevant to the execution of the order

For retail clients, the best possible result is normally determined in terms of total consideration, representing the price of the financial instrument and the costs related to execution.

Accordingly, price and costs will usually be the most important factors when assessing best execution, unless the characteristics of the transaction indicate that another factor is more significant.

6. Client Specific Instructions

All transactions arranged by SPFP are undertaken following the provision of advice. SPFP therefore determines the execution approach and the third parties used to arrange transactions.

SPFP does not accept insistent clients and does not undertake execution‑only business. As a result, client‑specific instructions in relation to execution venues or third parties will not normally be accepted.

In the limited circumstances where SPFP agrees to follow a specific instruction, clients should be aware that this may prevent SPFP from taking the steps it would otherwise have taken to obtain the best possible result in respect of the elements covered by that instruction.

7. Governance and Oversight

SPFP’s commission and charging structures do not influence the selection of third parties or the way in which client orders are arranged or transmitted.

Third parties are selected based on their ability to deliver best execution and an appropriate standard of service.

SPFP does not receive inducements or incentives that would conflict with its obligation to act in clients’ best interests.

8. Identifying and Addressing Poor Outcomes

SPFP regularly monitors the effectiveness of this Best Execution Policy and the arrangements supporting it, to identify and, where appropriate, correct any deficiencies.

This includes reviewing the quality of execution provided by the third parties to whom client orders are transmitted.

This policy is formally reviewed at least annually, and also whenever a material change occurs that could affect our ability to obtain the best possible result for clients

9. Staff Awareness

All relevant staff are made aware of this policy and receive appropriate training to ensure they understand the importance of best execution and their responsibilities when arranging transactions on behalf of clients.