Order Execution Policy

1. Purpose

The purpose of this information sheet is to provide clients with information on Verso Investment Management LLP’s Order Execution Policy.

Verso Investment Management LLP is required to put in place an Order Execution Policy and to take all sufficient steps to obtain the best possible result for our clients when placing orders that result from our decisions to deal in financial instruments on behalf of our client portfolios when providing the service of the discretionary portfolio management or for execution on behalf of a client. Verso Investment Management LLP is also required to provide appropriate information to clients on its MiFID Order Execution Policy.

2. The Scope

The Order Execution Policy for Verso Investment Management LLP applies to both Professional and Retail clients and to financial instruments where Verso Investment Management LLP:

• Places orders for execution that result from our decisions to deal in financial instruments on behalf of our client portfolios when providing the service of discretionary portfolio management
• Receives and transmits client orders

3. Placing Orders on a client’s Behalf

Verso Investment Management LLP will be placing orders ‘on a client’s behalf’ where such clients legitimately rely on Verso Investment Management LLP to protect their interests in relation to the pricing or other aspects of the transaction that may be affected by how and where the order is placed by Verso Investment Management LLP. This will be the case when Verso Investment Management LLP places orders when dealing as an agent.

4. Obtaining the Best Possible Result

Subject to any special instructions that may be given by clients, when placing orders for execution on their behalf, we will take all sufficient steps to obtain the best possible result, in terms of total consideration, by taking into account the execution factors.

The relative importance of the execution factors will be determined using our commercial judgement and experience in the light of market information available and taking into account the execution criteria.

The execution factors that will be taken into account will be price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.

Ordinarily, price will merit a high relative importance in obtaining the best possible result. For certain orders, for certain clients, under certain circumstances, for certain markets or for certain financial instruments, we may appropriately determine that other execution factors weigh more heavily than price in obtaining the best possible overall result.

5. Execution Criteria

The execution criteria that will be taken into account are the combined characteristics of the client, the order to be placed, the financial instruments that are the subject of that order, and the 3rd party entities, brokers and market makers, to which the placement of that order can be directed.

6. Placing an Order

The list of brokers and market makers we use for each class of financial instruments is attached to this document. This list comprises those 3rd party entities with whom Verso Investment Management LLP has entered into an agreement for handling its orders and on whom we place significant reliance. We reserve the right to add to or remove any of the brokers or market makers on the list at any time.

This list is regularly assessed, for all financial instruments we trade, to identify those that will enable us on a consistent basis to obtain the best possible result when placing orders on behalf of our clients. The list will be updated where necessary, from time to time, though we will not notify you separately of such changes. A current list will always be available on request or via our website at www.versoim.com

We do not structure or charge our commissions in a way that unfairly discriminates between any 3rd party entities. We may deal outside a Regulated Market or Multilateral Trading Facility.

7. Selecting a Broker or Market Maker

Subject to any specific instructions that may be provided by a client, Verso Investment Management LLP will always select the broker or market maker Verso Investment Management LLP considers to be the most appropriate given the execution criteria and execution factors prevailing at the time. However, price will always be the predominant factor.

8. Specific client Instructions

Subject to any specific instructions that may be provided by a client, we may transmit an order received to one of our selected brokers for execution. In doing so, we will always act in each client’s best interests and also comply with sections 4 and 5 above.

You need to be aware that the execution of your specific instructions may limit or prevent Verso Investment Management LLP from implementing the steps we have taken in our Order Execution Policy to obtain the best possible result for you in respect of the elements covered by those instructions.9.

9. Monitoring and Review

We will monitor compliance with our Order Execution Policy annually, and regularly review its arrangements, effectiveness, and accuracy. We will also review the list whenever a material change occurs that affects our ability to deliver the best possible result for our clients.

You will be notified of any material change to our execution arrangements and our Order Execution Policy, and this will be posted on our website along with any change, from time to time, in our list of selected brokers and market makers. You will not be notified separately of minor changes. Please refer to the website for the current arrangements and policy from time to time.