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Omba is required to provide Best Execution to its clients as specified in Chapter 11.2A of the FCA’s Conduct of Business Sourcebook (COBS). This is to achieve, when executing orders, the best possible results for clients, considering the execution factors.

Introduction

Throughout this policy, the words “you”, “your”, and “yours” mean the client(s) (and any other individual who has authority over the client(s) account). The words “we”, “us” and “our” mean Omba Advisory & Investments Ltd.
The purpose of this document is to provide you with information about our Order Execution Policy. The Order Execution Policy outlines the arrangements we have put in place to ensure that we achieve ‘best execution’; i.e. obtaining the best possible results for our clients when carrying out transactions on their behalf.
This document sets out the process we utilise to meet our regulatory obligations.

The Obligation

Omba is required to provide Best Execution to its clients as specified in Chapter 11.2A of the FCA’s Conduct of Business Sourcebook (COBS). This is to achieve, when executing orders, the best possible results for clients, considering the execution factors.

This policy should be considered at the individual client level, as there are different obligations depending on the nature of the services provided to you and may vary depending on the broker/custodian. Omba evaluates the relationship with each client to determine the extent that the client is reliant on Omba for best execution. You and Omba are subject to the best execution policies of each relevant individual custodian/broker.

We maintain our own OEP to assist in the delivery of best execution, ensuring that this encompasses the different classes of investments, the entities where these orders are executed, and by whom (its brokers/custodians), and, as noted above, the suitability of its counterparts to ensure Omba delivers best execution for its clients.

Whenever there is a specific instruction from the client, we will execute the order following the specific instruction. This may, however, prevent Omba from taking the steps that it has designed and implemented in its execution policy to obtain the best possible result for the execution of those orders in respect of the elements covered by those instructions.

Execution Factors

Execution factors are any considerations relevant to the execution of the order and we will determine the relative importance of each of the factors in relation to each trade. As mentioned above, the factors are:
• price;
• transaction costs, including fees and commissions;
• speed of execution;
• likelihood of execution and settlement;
• size of order;
• nature of order; and
• other considerations relevant to the order.
Price will usually merit a high relative importance in obtaining the best possible result for professional clients*.
Where a firm executes an order on behalf of a retail client, the best possible result must be determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution, which 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.

Execution Criteria

When executing a client order, we will consider the following criteria to determine the relative importance of the execution factors:
• the characteristics of the client, including the categorisation of the client as retail or professional client;
• the characteristics of the client order, including whether the order involves a securities financing transaction;
• the characteristics of the financial instruments that are the subject of that order; and
• the characteristics of the execution venues to which that order can be directed.
These criteria should be carefully applied to each instance to determine the priority of each execution factor.

Typically, price will be the key factor when executing orders. When receiving quotes from multiple counterparties, the best price will always be chosen unless other factors sufficiently dictate otherwise – in which case these will be documented.
Price will be considered in conjunction with total costs, the speed of executing trades and the likelihood of execution. These can be important considerations when on-exchange volume of ETFs (Exchange Traded Funds), or other instruments, is low and executing the entire trade with no partials may be beneficial. We will use our discretion when executing trades, and additional considerations such as, the underlying liquidity of ETFs (time of day, use of hedging instruments) and liquidity providers vs authorised participants.
This OEP applies to each client order with a view to obtaining the best possible result for the client in accordance with this OEP. In addition, post trade analysis is performed, and an assessment is documented on a monthly basis for all trades executed on the Tradeweb MTF.

Selecting Execution Venues

We use our discretion to select the most appropriate execution venue for the relevant product. Please refer to Appendix I. These venues may be:
• Regulated Markets (for example, the London Stock Exchange);
• Multilateral Trading Facilities (for example, Tradeweb);
• Systematic Internalisers (Sis).

Selecting a Broker/Counterparty

Transactions of behalf of our clients will be executed only with, or through, approved brokers and counterparties. Omba has a process to evaluate and approve the brokers and counterparties we use to execute client orders. Our evaluation process includes a thorough review of the broker /counterparties Terms of Business / best execution policies and may specifically include the below areas of focus:
• Are appropriately regulated
• Their consistency in providing best price;
• Sufficient capital to complete all executed trades;
• Ability to source liquidity to accommodate trading in different market conditions;
• Are charging competitive rates for execution;
• Timely and accurate trade reporting, if applicable;
• Speed and reliability of trading systems and venue.
Not all custodians/brokers may be used for a given trade to manage information leakage amongst other factors.

Dealing Arrangements

COMMISSION RATES; We will not receive any remuneration, discount or non-monetary benefit for routing client orders.
INDUCEMENTS; We do not receive any third-party payments or inducements from execution venues or counterparts.
EVIDENCE OF BEST EXECUTION; If requested by a client or the FCA, we will demonstrate that we have executed transactions in line with our OEP.

Monitoring and review of Execution Arrangements and Policy

To ensure that the OEP and execution arrangements remain appropriate for the firm and its clients, this policy will be reviewed by the governing body of the firm on, at least, an annual basis. If there is any material change to the firm’s ability to continue to obtain best execution then this policy will be reviewed and, where required, updated.
We will notify clients if there are material changes to this policy. A material change is a significant event which could impact the parameters of best execution, such as: cost, price, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.
The firm must monitor the effectiveness of its order execution arrangements and OEP to identify, and where appropriate, correct any deficiencies

Order Allocation Policy

COBS 11.3.7A requires the Firm to have an order allocation policy (“OAP”) to ensure the fair allocation of aggregated orders between clients.
The Firm is not authorised to deal on its own account. It may only place deals on behalf of its clients and in accordance with its OEP.
When the Firm has aggregated two or more client orders, the executed trades will be allocated in accordance with the Firm’s allocation procedure. This procedure requires trades to be allocated pro rata based on the pre-trade allocation for each client that was determined before the placing of the trade.
When necessary, the different agreed strategies in each underlying account are considered and a recording should be made for any deviations from the pro rata allocation. However, situations may arise where it is not possible to allocate across all relevant accounts, either for reasons of liquidity or practicality in which case each variation shall be documented and reviewed.
These procedures are designed to ensure that, when the Firm aggregates a client order with another client’s order and subsequently allocates the executions, it does so consistently and in accordance with the FCA rules covering:
• Timely allocation: Allocation will be made promptly between each account;
• Fair allocation: All clients should receive the same executed price or a volume weighted average where there is a series of executions;
• Re-allocation: Any errors in allocation will be promptly corrected so as to not benefit any one client over another; and
• Record keeping: Full documentation is available for all allocations, particularly in situations where the Firm’s usual policy was not followed. These records are retained for a period of at least five years from the date of the transaction.

Client Consent

We must obtain prior consent from our clients to our Order Execution Policy. Consent is provided by signing the Investment Management Agreement (IMA).
We may arrange for orders to be executed outside of a trading venue and by providing your consent, you have given your express permission to such transactions. Trading outside of a trading venue may have certain consequences including counterparty risk.
Upon client request, we will provide additional information about the consequences of this means of execution.
If a client does not provide consent, we will be unable to provide services to them.

Annex I – Broker / Counterparty and Execution Venue Details

We provide a list of the execution venues on which we place significant reliance in meeting our obligation to take all reasonable steps to obtain, on a consistent basis, the best possible result for the execution of client orders and specifying which execution venues are used for each class of financial instruments. There is no further distinction for retail client orders, professional client orders and SFTs.
We also provide, for each class of financial instrument, the entities with which the orders are placed or to which the investment firm transmits orders for execution.

CLASS OF FINANCIAL INSTRUMENT	KEY EXECUTION VENUES AND COUNTERPARTIES
ETPs (Exchange Traded Products)	Tradeweb MTF, London Stock Exchange, Xetra, Nasdaq, NYSE, Euronext Amsterdam, SIX Swiss Exchange, DRW, Flow Traders, Jane Street, Societe Generale, Susquehanna, Virtu.
Fixed Income	Tradeweb MTF, Citi, Barclays.
Equities	Citi, Barclays, London Stock Exchange, Nasdaq.