Best Execution Policy Disclosure Statement

The Obligation

Investec Investment Bank and Securities (a division of Investec Bank plc) will take all reasonable steps to achieve Best Execution of your orders relating to financial instruments in the following circumstances;

a) where we act as agent on your behalf in executing a transaction and
b) where we act as principal but have a client relationship with you in relation to executing a transaction on your behalf.

We will not be executing an order for you, and therefore the best execution obligations will not apply, where we provide you with a quote for the purchase or sale of a financial instrument in response to a request from you.

Please note that specific instructions from you take precedence and will influence how we fill your orders; this may prevent us from taking the steps set out in this statement to obtain the best possible result for the execution of your orders.

Relevant arrangements

We have arrangements in place to enable us to achieve the best possible result taking into account a number of factors which include, amongst others, price, cost of transaction, speed of execution and the size and nature of the order. Price will ordinarily be a priority in this assessment but in some circumstances other factors may be given a higher priority in order to ensure the best possible execution result is achieved.

We usually execute orders in UK listed stocks on Regulated Markets or Exchanges of which we are members. The actual venue for execution may be selected by Smart Order Router which selects the venue for execution based on the price/volume available and the fungibility of the stock.

We also have access to a number of other liquidity pools and venues (both in the UK and overseas) which we may use from time to time, depending on the security or trade in question. These liquidity pools include multilateral trading facilities, systematic internalisers and third party investment firms. The priority for venue selection will always be to try and achieve the best possible result for the client.

We will undertake periodic monitoring to ensure the ongoing effectiveness of our arrangements in addition to a full annual review of our systems, the liquidity pools / venues we have access to and the prioritisation of the factors mentioned above. Material changes to the market or to our business model during the period will also trigger a review.

Retail Clients

Where we are executing an order on behalf of you, and you are classified as a Retail Client, then the best possible result will be determined in terms of the total consideration (i.e. the price of the financial instrument/costs related to execution) related to the execution.

Where we do not receive any specific instructions from you, we will consider all factors in delivering the best possible result. However other factors (e.g. speed, likelihood of execution and settlement) will only be given precedence over the immediate price and cost consideration only insofar as they are instrumental in delivering the best possible result in terms of total consideration for you as the client.

Your consent

We are required to obtain prior consent to our Best Execution policy; receipt of an order from you after 1 November 2007 will be deemed to be your provision of that consent.

Review 

We will notify you of any material changes to our execution arrangements or our Order Execution Policy by posting an updated version of this document on www.investec.com