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Gemini Wealth Group

Best Execution Policy

Overview

Gemini Wealth Group Ltd (GWG) is comprised of the following Financial Conduct Authority (FCA) regulated businesses to which this policy applies:

  • Gemini Wealth Management Ltd (GWM) – a financial advisory and wealth management firm
  • Gemini Asset Management Ltd (GAM) – a discretionary investment management firm

Both firms are wholly owned by GWG, a non-trading, non-regulated holding company, controlled by common ownership and directors, and share common staff operating across both firms.

As such, both firms apply common standards in terms of the systems and controls applied to the mitigation of financial crime, and consequently this financial crime policy and risk assessment applies to both firms.

Where there are identified differences in the obligations, policies, procedures or treatment of risks between the firms, these will be clearly detailed within this document.

References to “we” in the remainder of this document mean Gemini Wealth Group and the above subsidiaries unless indicated otherwise.

Purpose of the document

It is in the interests of our clients and our firms that we obtain the best possible result when placing orders for execution on behalf of our clients with third parties such as platforms and fund managers.

We are required to take all sufficient steps to provide best execution when carrying out such transactions and, on your request to provide you with a copy of the policy we have adopted to achieve that objective.

This best execution policy applies to orders in investments such as funds and other securities. You should read this policy in conjunction with your client agreement.

Execution venues and third parties

An execution venue is effectively a trading venue such as a regulated stock market where investment transactions are executed. Neither GWM or GAM executes orders or deals directly with execution venues. Instead, orders will be placed on behalf of our clients with appropriate third parties as explained below:

  • Investments on a platform: For investments recommended by GWM to be held on GWM’s preferred platform(s) (an online investment administration service), client orders will be placed directly with the relevant platform. These are Quilter (formerly Old Mutual Wealth), Standard Life, Transact and 7IM.
  • Investments not on a platform: For investments recommended by GWM to be held directly with individual fund managers, client orders will be placed directly with the relevant manager for each particular investment.
  • Stocks and shares: GWM and GAM do not place orders with stockbrokers in relation to stocks and shares.
  • Gemini Asset Management investments: For GAM investments recommended by GWM, client orders will be placed directly with the Quilter platform.

We regularly assess the third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging the execution of your orders. The above list will be updated, where necessary, following such assessment.

The third parties have responsibilities in relation to best execution and client order handling themselves. We’ll also undertake periodic monitoring to ensure that they’re meeting the relevant requirements.

Execution factors

When transmitting orders to a third party, we’ll make every effort to ensure the best possible result for our clients taking into account the following factors:

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

For retail clients, the price and cost of execution of the order will normally be the most important aspect in obtaining the best possible result. We will therefore assume that this is the most important outcome for your transaction unless you tell us otherwise.

Client specific instructions

If you have given instructions that price is not the most important factor in executing your instructions, we will make every effort to comply with your instructions but cannot guarantee this. This may be due to either the nature of the order, or the type of investment you wish to trade in.

We will make all decisions as to where the orders are placed and won’t accept specific instructions from clients regarding which third parties to use.

Charges

It is our policy that commission and charging structures won’t influence either the selection of third parties with which we place client orders, or the order flow that follows as a result of the execution process. We will therefore not discriminate between the third parties used to arrange execution of your orders.

Monitoring and review of our execution policy

We will regularly monitor the effectiveness of our best execution policy to identify and, where appropriate, correct any deficiencies. In particular, this will cover the third parties to which both GWM and GAM transmit client orders in terms of their quality of execution.

This review will be carried out regularly (on at least an annual basis) or whenever a material change occurs that affects our ability to continue to obtain the best possible result for our clients.

Staff understanding

All relevant staff are made aware of this policy to highlight and emphasise the importance of best execution.