policies
ORDER HANDLING

Sidekick must take sufficient steps to obtain the best possible results for our customers when handling orders on their behalf. The primary factors to be taken into account are: price; costs; speed; likelihood of execution/settlement; size and nature.

This policy outlines Sidekick’s approach to meeting our ‘best execution’ obligations and consistentlyachieving good outcomes for our customers.

Regulatory Landscape

The Financial Conduct Authority (FCA) has a Conduct of Business Sourcebook (COBS) which requiresSidekick to document, maintain and publish a policy which explains how we take sufficient steps to achieve best execution. Chapter 11 within COBS covers these rules in detail and is referred to throughout this policy. Best execution is also a core obligation within MiFID2.

Order Characteristics

Sidekick takes decisions to trade on behalf of our clients in line with our discretionary mandate. This will typically mean that our orders are:

Who?

• Executed on behalf of retail clients.
• Sidekick is not able to trade on its own account.

What?
In the following types of financial instruments:

• Fractional or whole listed shares - primarily US, UK or EU with periodic trading on other recognised public global exchanges as required by the investment strategy in place;
• Exchange traded funds (ETFs);
• American Depository Receipts (ADRs) or Global Depositary Receipts (GDRs); and
• UCITS funds.

In the event that Sidekick invests in any other type of financial instrument which has materially different characteristics to those listed here, we shall re-visit this policy and any other relevant processes or procedures.

Where?
Executed via arrangements we have made with carefully selected partners in the UK and the US. We are satisfied that we have created an environment in which we can meet our ‘best execution’ responsibilities.

• Sidekick has a very robust selection process in place to ensure that our partners enable us to meet our best execution responsibilities. The equivalent policies of our partners will be made available on our website.
• Our partners were selected on the basis that they: are authorised by the FCA or an equivalent national body; provide cost effective access to the asset universe required for our investment strategy; are well regarded within the wider industry; are able to support fractional trading; and satisfy all of our other due diligence requirements.
• Partner performance in terms of best execution is under constant re-evaluation. Sidekick reserves the right to contract with another broker or entity if we determine that good customer outcomes are not being obtained.

Some of our trading is likely to take place over-the-counter (OTC) although the companies in which we are investing will always be listed on a major global public exchange. Trading OTC can generally be riskier than trading on a public exchange; Sidekick takes active measures to robustly and expertly manage these risks on our customer’s behalf.

When?
Sidekick’s Investment Team operates under a discretionary mandate. As a result, we will trade on behalf of our customers when the market conditions are considered most favourable to the investment strategy. We do not intend to trade on a frequent basis.

How?
We will use the following order types:

• ‘Market Day’ – this is an instruction to trade at the best available price which is valid for the remainder of the trading day;
• ‘Fill or Kill’ – this is an instruction to trade at the best available price as quickly as possible. These are fulfilled immediately or cancelled; or
• ‘Limit orders’ – this is an instruction to trade where we set the maximum/minimum price at which we are willing to trade. These will be used depending on market conditions, mainly when there is increased price volatility.

The main exception to this will be when a customer withdraws assets from their portfolio (in full or in part). Whilst we would still take all reasonable steps to ensure the best possible result, the sell trade(s) would be prioritised by speed rather than the combination of any other factors. We define this as a ‘specific client instruction’. We do not otherwise accept self-directed client orders to trade.

In the event that any of these characteristics are no longer present (because of a change to our product range or business model), we will review and/or amend this policy and any related procedures at the earliest possible opportunity. Otherwise, this will be carried out on at least an annual basis.

Trading Outcomes

Sidekick defines a good customer outcome for the purposes of our best execution responsibilities in terms of ‘Total Consideration’ which represents the price of the financial instrument being traded and the costs related to execution.

This must include all expenses incurred by the client which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. This also includes implicit transaction costs (such as market impact).

We will always use our best endeavours to obtain the best possible price for our customers when we trade, we consider this to be the most important factor and will adopt this as the default priority.

The principle of best execution does not guarantee that the best price possible will be achieved for every single trade. In certain circumstances we may conclude that factors other than price (see below) are more important in achieving the best possible result. The relative importance of each of the factors will differ depending on the nature of the trade.

• Speed;
• Likelihood of execution/settlement;
• The past performance of the partners we use under similar market conditions;
• Market impact;
• Size & nature of the trade; and
• Any other relevant considerations which may arise.

We will use our reasonable commercial judgement together with our understanding of the appropriate execution criteria when we trade on behalf of our clients.

In practice, we will predominantly route US and UK trades (where the company is listed and in which currency they trade) to our respective partners in those jurisdictions. Costs are not ordinarily a customer factor as transactional fees are already accounted for within our AUM structure. For the avoidance of doubt, we do not separately charge fees for foreign exchange.

Speed of execution is broadly similar between our partners - the main determining factor for our trading activity will be availability of our preferred asset classes. All trading activity will be closely analysed to ensure that we are able to identify any instances which would represent a material difference in customer outcome solely because of the role of the executing partner we have used.

When we are trading on the US market, there is a potential ‘gap’ risk which could occur if the underlying stock price moves in an unfavourable direction outside of Sidekick’s core UK business hours. The liquid nature of the assets in our client portfolios means that this is unlikely to result in a material loss - in any event, we will continually evaluate whether our operational processes are not in adherence with our best execution obligations.

Aggregation

Client orders will typically be combined and executed via our partners within a bulk trading arrangement. This helps Sidekick to manage the operational risks associated with the processing of multiple simultaneous client orders and reduces our overall costs.

It is extremely unlikely that the aggregation of orders will disadvantage our customers. Although individual trades within the bulk order will be executed at different prices, these are averaged out across the consolidated order and all clients will receive the same price per share/fractional share when the end portfolio positions are allocated.

In the event that an entire order cannot be filled, the customers within our bulk trading instruction will receive their allocation on a ‘pro rata’ basis. This represents a fair outcome to all customers. Typically, when trading in fractional shares, there will be very small remaining fractions(representing up to 8 decimal places of a whole share in some cases) which cannot be allocated exactly. Internally, we have determined a hierarchy of allocation which ensures that this is accounted for and no customers are disadvantaged.

No client order is given preference - meaning that the customer orders are not prioritised, but fulfilled at the same time (when bulk trading) or as the instructions (new deposits or withdrawals)are received.

Partner Arrangements

Our chosen partners will execute Sidekick’s trades via multiple broker-dealers and other venues; inline with their own ‘best execution’ and other regulatory responsibilities.

Additional information is contained within the equivalent policies of partners which are available on our website.

Sidekick does not receive “any remuneration, discount or non-monetary benefit for routing client orders to a particular trading venue or execution venue “ which would be considered a conflict of interest. Our client’s best interests are the primary factor influencing our trading decisions and any ancillary arrangements we have put in place.

Oversight

Sidekick has put in place internal controls to monitor, on an ongoing basis, the effectiveness of the arrangements described within this policy.

We have implemented a transaction cost analysis solution3 which analyses our trading activity against a range of reference points, offering standardised metrics for internal assessments and comparisons against numerous industry-recognised benchmarks. This allows us to gain a comprehensive insight into the relative performance of our post-trade executions. This compares our execution price to the VWAP or “volume weighted average price” which represents the average price a given security has traded at throughout the day, based on both volume and price.

We have a regular standing agenda throughout our Governance structure to digest the results of our trade analysis and assess the results achieved for our clients compared to the pricing levels available in the wider market.

As part of the standard onboarding process, our customers provide their consent to our order handling policy (and those of our partners) via the Investment Management Agreement (IMA).

In addition, our partners have their own policies and internal control mechanisms in place which cover equivalent regulatory obligations.