Walker Crips Investment Management Limited ("Walker Crips") is required under the Financial Conduct Authority ("FCA") rules to take all sufficient steps to obtain the best possible results for its customers when executing orders or receiving and transmitting orders in financial instruments on their behalf.

Customers are provided with the full Order Execution policy ("OEP") at the establishment of the relationship and it forms part of our Terms of Service and Business ("ToB"). By agreeing to the ToB, you are agreeing to the OEP.

The following disclosure provides a summary of Walker Crips’ OEP and our approach to achieving the best possible result for you.

Customers and client categorisation
The policy applies when we execute orders on behalf of Professional and Retail customers.

Execution factors and criteria of order execution
When we undertake a transaction on your behalf, subject to any specific instructions that may be given by you, we will take all sufficient steps to obtain the best overall outcome for you, taking into account the following factors:

• the characteristics of the financial instrument, nature of the order, execution venues, liquidity, your characteristics;
• client categorisation (whether you are Retail or Professional);
• execution factors (price of the financial instrument; costs related to the order execution; speed of executing the order; likelihood of execution and settlement; size of the order; nature of the order) and any other relevant criteria.

When dealing in a financial instrument on your behalf we will exercise our discretion in assessing the criteria needed to achieve best execution. The relative importance of these criteria will be judged on an order-by-order basis, in line with our commercial experience and with reference to market conditions. In executing orders for customers, in the absence of any specific instructions, we generally give precedence to the factors that allow us to deliver the best possible result to the customer. For most orders, it will primarily be a case of achieving the best price, although other features of the order may be considered, where relevant.

For most orders, the choice of execution venue will involve no additional charges, but where additional charges are incurred, achieving the best overall outcome for you will be the priority. The UK’s standard settlement for most purchases and sales is trade date plus 2 (T+2). If a trade is instructed for settlement outside the standard settlement, there may be extra costs reflected in the share price. Extended settlement does not fall within the policy and must be requested for, and agreed by your Account Executive.

Specific customer instructions
There may be instances where you instruct us to place an order with specific criteria. When you give us a specific instruction as to the execution of an order, we will execute the order in accordance with those specific instructions. You should note that any specific instructions may prevent us from following some or all of the steps outlined in the OEP and there is always a risk that we may not be able to achieve best execution.

We reserve the right to refuse specific instructions to us in relation to the execution of a particular order where, in our opinion, such instructions are not practicable, or may be contrary to your best interests.

Execution venues
We maintain a significant network of market counterparties and execution venues, on which we place reliance in enabling us to obtain, on a consistent basis, the best possible result for the execution of customer orders. We use dealing systems with links to regulated markets and their Member Firms, which include the Market Makers’ Retail Service Provider Network (RSP).

For more complex transactions or securities, or non-standard settlement trades, in addition to systems, we also have direct telephone communications with counterparties with whom we can execute your orders. For non-UK equities, we will use the venues which, to the best of our knowledge, will provide you with the best overall outcome.

The Execution Venues and counterparties are subject to periodic review and may be added or removed in accordance with our obligation to provide you with the best possible execution result.

Limit orders
Limit Orders are orders given to us to buy or sell with specific parameters, for example orders with a specific number of shares in a stock at a specific price or better. In such circumstances, it may not always be possible to execute that order under the market conditions at that time.

Limit Orders placed on a Regulated Market ("RM") order book will be automatically executed if the limit price, which you have set, can be achieved.

Limit Orders which cannot be placed on the RM order book will be accepted for execution on a best endeavours basis. Limit Orders will expire at the end of the business day and must be renewed, if required, the following day. Limit Orders instructed over longer periods, will be accepted on a best endeavours basis.

Whilst best endeavours will be made to execute a purchase or sale at a specified dealing price, we are unable to accept responsibility for any loss arising from a limit price being missed. Walker Crips is unable to accept stop loss instructions.

Consents
OEP - We believe that it is in your best interest that we can deal in as many markets and use as many execution venues as possible, including dark pools, in order that we may give you the best possible outcome.

Before we can execute your order outside a regulated market, multilateral trading facility (MTF) or organised trading facility (OTF) (i.e. where we deal off-exchange), we are required to obtain your express consent. By signing the account opening documentation and agreeing to our ToB, you will be deemed to have provided such consent. If you withdraw your consent, please notify us in writing through your Account Executive. Using market counterparties may result in counterparty risk, where the counterparty to a transaction fails to honour its obligations by failing to pay for the transaction or deliver stock. In the event that a market counterparty defaults in its obligations or becomes insolvent, we will not be responsible to you for any loss suffered by you by reason of any cause beyond our control.

Limit Orders - We are required to make public your unexecuted Limit Orders unless you expressly consent to us not to make it public. We believe that it is in your best interest if we exercise our discretion as to whether or not we make your order public. By agreeing our OEP and ToB, and signing the account opening documentation, you are expressly instructing us not to make such orders public.

Customer order handling and allocation
Order Handling - When we execute orders on behalf of customers, we will ensure that orders are recorded and allocated as soon as reasonably possible. In the event that comparable orders are received from two or more customers, the orders will be executed immediately and sequentially unless market conditions make this impracticable.

Order Aggregation and Allocation - We may combine your order with that of another customer, or with our own orders, or with those of connected parties, where we reasonably believe that it is more likely that the aggregation will work to your advantage overall than if your order had been carried out separately. When we combine customer orders with our own orders or those of persons connected to us and the aggregated order is only partially executed, we will prioritise the customer, and fully allocate the customer before ourselves..

Monitoring
Compliance with our OEP will be regularly monitored.

Policy review and updates
Our order execution arrangements and policy are subject to periodic review. We will notify you of any material changes to the policy by providing you with an updated version of the document. We will notify you of any material changes to our best execution arrangements or whenever a material change occurs that affects our ability to continue to obtain the best possible result for our customers.