Conflicts of Interest Policy

The Walker Crips Group and its subsidiary companies (the Group) provides diversified financial services to a broad range of clients from a number of locations within the United Kingdom. These services include stockbroking, fund management, IFA services, custody and they are delivered to clients that include individuals, private companies, and trusts. Across the group, these services are provided by employees, account executives, agents and affiliates. Given the range of services and the circumstances in which they are delivered, the aims and interests of our clients and the parties within the Group may create the possibility of conflicts of interests that cannot be avoided.

However, our employees and Account Executives are required to comply with a policy of independence and disregard any such interest when making recommendations to you.

Examples of conflicts that may arise between the Group, our affiliates and agents, and our clients and counterparties or between our clients are:

  • Conflicts between the firms' own proprietary position and those of our clients
  • Remuneration based upon dealing volumes and/or portfolio performance
  • Dealing in the shares of an issuer to whom we provided corporate finance services in the previous twelve months
  • Dealing in the shares of a collective investment scheme e.g. a unit trust, to which we are an adviser or manager

We take all reasonable steps to identify conflicts of interest between you and WCG and its representatives and with any other client, in the course of providing services to you. Our conflicts of interest policy defines the steps that we take to identify, prevent, manage and/or disclose conflicts of interest when providing various investment and other services. These actions include the following:

  • Training our employees
  • Notifying the Compliance Department of employees dealing in securities who are potentially exposed to conflicts of interest
  • Imposing restrictions on dealing in securities of a company for whom we are providing Corporate Finance advice
  • Reviewing transactions in securities where we have access to sensitive information
  • Requiring the disclosure to Compliance of any gifts or other inducements received by employees and Account Executives We also assess our internal conflicts of interest policy on a regular basis to ensure that all new conflicts are identified and our policies updated to address any new instances of conflicts arising across WCG.

Order Execution Policy

1. Overview

The purpose of this document is to provide clients of Walker Crips Investment Management (“WCIM” or “we” or “us”) with information about our Order Execution Policy and to seek your consent for this policy. Please note that you provide your consent when you sign or agree to the declaration in the Account Opening Form.

For most orders, it will primarily be a case of achieving the best price, although other features of the order, like cost, size, shape, liquidity, speed of execution and other matters, will be considered where relevant. For most orders, the choice of execution venue will involve no extra charges, but if there are extra charges, the best overall outcome for you will be the priority.

2. Client Classification

WCIM clients will be classified as either Retail or Professional, but regardless of classification we will treat all clients as Retail for the purposes of achieving Best Execution, or getting the best possible result for you when carrying out trades. We always aim to achieve Best Execution on a consistent basis as outlined in the Order Execution Policy.

3. Specific Client Instructions

If you provide us with a specific instruction to deal for you, it may prevent us from following some or all of the steps outlined in our Order Execution Policy, which is designed to obtain the best possible results for you on a consistent basis. When you give us a specific instruction we will take all reasonable steps to get the best results for you, but there is a risk we cannot achieve best execution, in respect of that aspect covered by your specific instruction.

4. Execution Factors

When dealing for you we will consider the following:

a) Your characteristics, including your regulatory client classification as noted in section 2;
b) The characteristics of the financial instrument concerned and of your order; and
c) Where such orders can be carried out (i.e. the ‘execution venues’).

When dealing in a financial instrument on your behalf we will exercise our discretion in assessing the criteria that we need to take into account 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 clients, in the absence of any specific instructions, we generally give precedence to the factors that allow us to deliver the best possible result in terms of value to the client. For further information on the relative importance of the execution factors, please see below.


For most liquid instruments, market price will be the overriding factor in attaining best execution. Other factors, such as costs remaining equal, our execution arrangements will drive WCIM to find the most advantageous (best) price available. This will be the case for the vast majority of orders for clients where the size of the order does not limit WCIM’s choice of venue. Certain instruments, such as collectives (Unit Trusts & Open-ended Investment Companies) will have only one price, and one venue. However, in some circumstances for some of our clients, orders, financial instruments or markets, other execution factors may become more important than price in obtaining the best possible execution result.


Where explicit costs (such as exchange fees or settlement/custody costs) would make the overall consideration of the execution prohibitive (e.g. the cost of many small executions on an order book) then this factor may become relatively the most important.

In some circumstances, for example overseas brokerage commissions, other costs may be the most important factor. WCIM may consider that the large size of an order potentially moving the market, or the fact that requesting an electronic quote that might not be accepted are grounds for considering cost as being of higher importance than other factors.

Speed of execution

Similarly, the speed of execution may be important for some types of order, or client. Speed will be a high priority for clients executing an order in a liquid equity in a fast market.

Likelihood of Execution and Settlement (Liquidity)

In some instances, WCIM’s ability to actually execute and settle the order (the Likelihood of Execution and settlement) will be the primary factor to be considered. Where the instrument is illiquid (i.e. rarely traded), the size of the order is prohibitive, or some other factor determines this, the policy will ensure that actually effecting the order takes precedence over other factors. Application of the “total consideration” (representing the price of the financial instrument and the cost related to execution for the purpose of achieving “Best Execution”) may determine that this factor is given precedence over the immediate apparent price of a financial instrument in so far as it will, in WCIM’s opinion, deliver a better overall result for the client.

Size and shape of the order

The best price in a market is usually represented by the opportunity to trade in a particular size (i.e. number of shares, units, contracts etc.), which may not match the size of the client’s order. Where the order is bigger than the typical quoted size, then the part of the order executed over and above the threshold may only be available at a less favourable price. There are various strategies for trading large orders and WCIM will exercise its discretion where there is no other instruction from the client. Large or illiquid orders will be executed on a manual basis using the skills of our in-house dealing team. In such cases our dealers will source the best available terms by comparing the prices offered by a variety of market participants (including other regulated firms and Multilateral Trading Facilities (MTF) and Organised Trading Facilities (OTF) with reference market data.

Nature of the Order

WCIM will take into account any other factor relevant to the order that it believes warrants consideration in terms of how the order should be executed. This could be simply whether it is a buy or sell order, or whether the security is dealt in another market.

5. Execution Venues (Competing Markets)

WCIM will select a set of execution venues, which include market counterparties on which it places significant reliance in enabling us to obtain, on a consistent basis, the best possible result for the execution of client orders.

The types of venues we use are as follows:

i) Markets having regulated market (“RM”) status under MiFID such the London Stock Exchange, NEX Exchange, Plus Markets and its member firms;
ii) Multilateral Trading Facilities and Organised Trading Facilities;
iii) Retail Service Provider (RSP) network which is automated using market counterparties that have access to RMs and MTFs;
iv) Systematic Internalisers;
v) CoFunds Plc. and individual Unit Trust Managers;
vi) Other venues we are using now, or in the future, including Euronext.liffe and its member Firms, BOAT and Chi-X

There will be instances when WCIM passes an order to a counterparty (i.e. a broker) for execution. Typically, this will occur when WCIM is not a member of the RM, but may also occur in order to access alternative liquidity sources. In these circumstances, WCIM remains under an obligation to monitor the counterparty’s performance and does not remove WCIM’s obligation to obtain the best possible result for WCIM’s client.

We consider a number of factors to determine the appropriate venue or market counterparty for each asset class and instrument type. The factors include the asset coverage and liquidity provided by these venues/market counterparties in addition to the various costs, exchange fees and any other ancillary charges.

We regularly assess the execution venues available and may add or delete venues in accordance with our obligation to provide you with the best possible execution result on a consistent basis. We will notify you of material changes, which would impact our Order Execution Policy.

As noted above, we may deem it appropriate or advantageous to execute your order outside a RM, MTF or OTF, even where the investment (“financial instrument”) concerned is trading on a RM, MTF or OTF. WCIM is required to obtain your consent before executing orders outside an RM, OTF or an OTF. By agreeing to the Order Execution Policy and our terms and conditions, you are giving your express consent to this requirement.

6. Execution Methodology

Having assessed the relevant criteria and any specific instructions provided by you, we will select the most appropriate venue(s) from those available and execute your order accordingly.

7. Publishing Limit Orders

Limit orders are orders, which you give us with specific parameters, for example orders with a specific price or specific size, which cannot be immediately executed. Limit orders placed on the LSE order book will be automatically executed if the limit price, which you have set can be achieved. Limit orders, which cannot be accepted on the LSE order book will only 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. If you give us an investment instruction at a specified price limit or better and for a specified size, then it may not always be possible to execute that order under the prevailing market conditions.

We would be required to make your order public (i.e. show the order to the market) in such a case unless you agree that we need not do so. We believe it is in your best interests if we exercise our discretion as to whether or not we make your order public. By agreeing to the Order Execution Policy, you agree that we will not make your order public unless we consider this to be in your best interest to do so.

8. General Dealing Arrangements

UK Equities

In normal market conditions and for orders concerning liquid (i.e. frequently traded) UK equities, WCIM will use its order management system to identify the best available terms by polling a variety of execution venues including the RSP network. Large or illiquid orders will be executed on a manual basis using the skills of our in-house dealing team. In such cases our dealers will source the best available terms by comparing the prices offered by a variety of market participants (including other regulated firms and MTFs) with reference to market data.

Overseas/International Equities

Overseas/International Equity orders will normally be executed on the following basis:

a) For CREST deliverable securities, WCIM will use its order management system to identify the best available terms by polling available execution venues. Larger orders will be executed on a manual basis as per the arrangements for UK equity orders and through our network of market counterparties.

b) For overseas delivery securities (traded locally in the relevant domestic market), WCIM will use its order management system to identify the best available terms by polling available execution venues (including other regulated firms). Large or illiquid orders will be executed on a manual basis using our network of local market participants (including MTFs) to source the best available terms. Execution of these international equity orders may also occur through our network of market counterparties.

Collective Investment Schemes / UCITS

WCIM executes orders in collective investment schemes / UCITS either directly with the fund manager or through a third party for execution. Orders are executed on negotiated terms, not generally available to individual clients.

Debt Securities

For smaller debt security orders WCIM will use its order management system to source the best available terms from a variety of bond market participants. For larger orders and less liquid bond markets, WCIM will utilise its network to source the best available terms. UK Government Bond orders (gilts) may be executed via our order management system or on a negotiated basis via our network of market counterparties.

Exchange Traded Funds (ETFs)

In normal market conditions and for liquid ETF orders, WCIM will use its order management system to identify the best available terms by polling available execution venues. Larger or less liquid orders will be executed on a manual basis as per the arrangements for UK equity orders.

Structured products

Structured products are executed with the product provider concerned. In such cases the Product Provider is the sole execution venue for that product. WCIM follows an established internal process to analyse and compare market data, ensuring a fair price is obtained for WCIM’s clients.

9. Order Aggregation

We may combine (or ‘aggregate’) an order for our clients with orders of other clients. We will only aggregate a client order if we reasonably believe that doing so is likely to work to the overall advantage of our clients. However, the effect of aggregation may on some occasions work to our client’s disadvantage and may on occasions result in our clients obtaining a worse price than if their order was executed separately.

Where we combine client orders with our own orders or those of persons connected to us and the aggregated order is partially executed, we will allocate fully the related trades to clients in priority to our own orders.

10. Monitoring and Review

WCIM will actively monitor compliance with its Order Execution Policy. To assist with the comprehensive review of WCIM’s best execution arrangements, WCIM has put in place a set of tools and processes aimed to satisfy our monitoring obligations and provide clients with the best possible execution, including but not limited to:

- Order Execution Review Team – A team is established to report to the Compliance Committee to review the adequacy of and ensure compliance with the firms’ Order Execution Policy.

- Performance Monitoring – Regular monitoring measures to ensure the best possible result for the client orders involving a third-party vendor LiquidMetrix.

- Review of Market Counterparties – Where we use chosen market counterparties, we take reasonable steps to monitor their performance to ensure we obtain the best possible results for you on a consistent basis.

WCIM will regularly, and at least annually, review its Order Execution Policy and arrangements, and will notify you of any material changes as outlined in our terms of business with you.

You can view this policy on our website https://www.wcgplc.co.uk/.

WCIM is obliged to publish annually for each class of financial instruments the top five execution venues in terms of trading volumes where WCIM executed client orders in the preceding year and also publish information on the quality of execution obtained which includes detailed monitoring of the quality of execution obtained on the execution venues where it executed all client orders in the previous year. This promotes transparency for clients to better understand where their orders have been executed and the overall quality of order execution.

The publication will be done through WCIM website at https://www.wcgplc.co.uk/. The first annual report is required to be published by April 2018.

11. Client Declaration

WCIM operates on the basis that all clients would be legitimately relying on WCIM to deliver best execution for all transactions, regardless of how they arise.

By consenting to this Order Execution Policy, you are expressly consenting to WCIM using Execution Venues which are outside a RM, MTF or OTF as noted in section 5.

Please note that if you do not provide your consent to our Order Execution Policy you may be limiting our ability to execute your orders on the most advantageous terms for you. Accordingly, if you do not consent to this Order Execution Policy we may be unable to open an account for you.

Should you require further information or assistance in relation to the Order Execution Policy, or would like WCIM to demonstrate how best execution has been achieved on any order executed for you, please contact your Investment Manager, who will be able to assist you and answer any queries you may have.

Treating Customers Fairly Policy

Walker Crips Group is committed to act in the best interest of our customers at all times. "Giving Customers A Fair Deal" underlies the services we provide.

In our dealings with you, we endeavour to:

treat you fairly and assure you that fair treatment of our customers is embedded in our corporate culture place your interests first be open and transparent communicate clearly notify you of our charges in advance handle complaints promptly and fairly ensure our staff are adequately trained


Supporting Policies

These additional internal policies bolster our commitment to Treating Customers Fairly (TCF):

  • Order Execution: to obtain the best possible result on behalf of our clients when executing orders or receiving and transmitting orders for execution.
  • Conflicts of Interest: sets out our practices surrounding investment research.
  • Data Protection: the proper custody of sensitive client data.
  • Personal Account Dealing: the monitoring of personal dealing by Account Executives and staff to reduce the risk of conflict of interest with clients.
  • Gifts and Inducements: the observance of protocol on giving or accepting gifts, ensuring there is no conflict with duties owed by the Company.
  • Chinese Walls: adequate segregation of duties and functions between business units where segregation is required.
  • Client Complaints: responding and dealing with client complaints promptly and fairly.

Treating Customers Fairly Policy - Compliance Arrangements

Compliance Arrangements

  • Our Compliance Team is experienced and members are suitably qualified.
  • The Team manages a robust Compliance Monitoring Programme.
  • Checks are carried out regularly to ensure that all Policies, as listed above, are achieved and are being conformed to.
  • The Compliance function reports to the Board of Directors, and its findings and reports are submitted within the Board Management Information Pack.

Investors should be aware that past performance is not a reliable indicator of future results and that the price of shares and other investments, may fall as well as rise and the amount realised may be less than the original sum invested.

Walker Crips Group plc (Old Change House, 128 Queen Victoria Street, London EC4V 4BJ), registered in England, registered number 1432059, incorporates the following companies which are authorised and regulated by the Financial Conduct Authority: Walker Crips Investment Management Limited registered in England number 4774117 member of the London Stock Exchange, Walker Crips Wealth Management Limited registered in England number 3790291, Ebor Trustees Limited registered in England number 3514268, Barker Poland Asset Management LLP registered in England and Wales number OC341149.