Background
This Order Handling and Best Interests Policy is provided by Shares App Ltd ("we" or "the Firm") and provides you with important information about how we will treat Orders submitted by you via the Shares App.
Purpose
The purpose of this Order Handling Policy (the “Policy”) is to describe how the orders you submit to us are handled and how you receive best execution. Providing best execution is a regulatory obligation; it takes into account the nature of a particular order, the prices available, the execution venues available, and a reasonable assessment of relevant execution factors.
Order handling
The Firm does not execute any orders itself; rather, the Firm will transmit customer orders to Alpaca Securities LLC (“Alpaca”), a US-based third-party executing broker and custodian, for execution. Under no circumstances will we act in any other capacity. A transaction will arise between the customer and Alpaca in all instances for the purposes of the execution of your Order.
The Firm does not receive any benefit (monetary or otherwise) from any trade execution venues (such as Alpaca) in return for sending the Firm’s customers’ orders to them.
Our primary obligation is to ensure that your Orders are transmitted to our Third Party Broker, Alpaca, promptly and fairly. Unless instructed otherwise by you or where prevailing market conditions prevent us from doing so, Orders will be transmitted to the Third Party Broker sequentially and promptly.
If you place an Order with us after Market Hours, we will place your order for execution on the next day and will seek to execute it once that market opens again, at which point the price of the relevant Instrument may have moved (but we will continue to execute your Order despite those movements).
You will be able to request to cancel your Order instructed outside of Market Hours at any time before the opening of the relevant exchange. However, we cannot guarantee that we will be able to action your request for cancellation once submitted. Please cancel your Order with plenty of time before the relevant market opens in order to avoid any risks associated with cancelling your Order or price volatility once the market opens.
We will not be liable for any losses you suffer as a result of fluctuations in price whilst submitting an Order outside of Market Hours.
Execution services
We receive and transmit Orders via our app. These Orders are transmitted onwards and then executed as follows:
Execution via Third Party Broker (Alpaca Securities LLC) – We will primarily transmit an Order to be executed by the Third Party Broker unless instructed otherwise or where prevailing market conditions prevent us from doing so.
We are required to get your express consent to send orders for execution to a trading venue outside of the UK. By agreeing to this Order Handling Policy you are acknowledging that you have provided such consent to send your orders to the Third Party Broker.
We shall not act in any other capacity and the transaction which arises shall be between you and the relevant third party broker to execute your Order.
Specific instructions
In extreme circumstances where a Customer provides specific instructions to us, we will transmit an Order in accordance with those instructions. These specific instructions may prevent us from acting in accordance with our best execution Policy, which is designed to ensure Orders are handled and executed in a Customer’s best interests.
Where we received specific instructions, those instructions shall be deemed to constitute best execution (to the extent best execution is applicable). Where those instructions only relate to some aspects of an Order, we will comply with this Policy in relation to the other aspects.
Best execution
We have a regulatory obligation to provide best execution when transmitting Orders for execution. This means that we will aim to ensure best execution, taking into account the nature of a particular order, the prices available and a reasonable assessment of the relevant execution factors (see below).
Transmitting Orders to the Third Party Broker
We have chosen to primarily transmit Orders to the Third Party Broker as it has been able to demonstrate that it can consistently achieve the best execution results for Customers. In particular, we have confirmed the Third Party Broker has the necessary expertise in relation to the Instruments to deliver outcomes at least as good as can be obtained by transmitting Orders to other third party brokers. As part of our terms and conditions, you will have accepted the terms of the Third Party Broker.
Securities brokerage services are provided by Alpaca Securities LLC , member FINRA/SIPC, a wholly-owned subsidiary of AlpacaDB, Inc. The Third Party Broker is therefore also under an obligation of best execution and is required to publish information on its execution practices and venues which it selects for executing transactions.
The Third Party Broker maintains a system in order to provide fractional share trading and listed securities arrangements that ensures that it shall provide best execution for Customers and / or provide benefits with respect to price in circumstances where the Third Party Broker acts both as agent and principal to fill an Order.
Further details of the best execution policy for the Third Party Broker may be obtained directly from the Third Party Broker or supplied by us upon request.
For the avoidance of doubt, we are deemed to have provided best execution where it is receiving and transmitting an Order for execution pursuant to a specific instruction provided by a Customer (see Section 4 above for details).
Policy review
The policy will be reviewed annually to ensure it is fit for purpose.
Reporting
We will publish annually data relating to the Third Party Broker, the quality of execution and any other relevant FCA Rules.
The report on the quality of execution shall be available on our website.
Inducements
We shall not structure or charge our commissions in such a way as to discriminate unfairly between third party broker(s). We shall not receive any third-party payments that do not comply with MiFID II and shall inform Customers about the inducements that the firm may receive from execution venues in accordance with applicable law.
For further details, please see the Conflicts of Interest policy.
Consent
Customers are deemed to consent to this Policy when they agree to the Terms of Business of the Firm.
Responsibilities
Where applicable, our duty to provide the Customer with best execution does not imply that we owe the Customer any fiduciary responsibilities over and above the specific regulatory obligations placed upon it or as may be otherwise contracted between the Firm and the Customer. The Customer remains responsible for its investment decisions and we will not be responsible for any market trading loss the Customer may suffer as a result of those decisions.
Further questions
Should you have any further questions about our order handling or best execution, you can contact us:
