Latest (3rd October 2022)

Touch by AJ Bell Order Execution Policy

The Financial Conduct Authority requires us to implement an ‘Order Execution Policy’, which explains how we achieve the best possible outcome when trading for you.

This policy applies to all trading instructions we receive from you or your adviser and it should be read in combination with our terms and conditions, as you are agreeing to this policy when using our services.


Dealing process and combined client trades

We only trade in funds such as Unit Trusts & OEICs (Open Ended Investment Companies) which are typically priced at a set time daily by the fund managers. This is called a ‘valuation point’ and the frequency and time of the valuation point varies between fund managers.

We place all fund trades for all clients once per day

Where possible we’ll aggregate (“combine”) client trades; this means that trading for all clients in the same fund and same trade type (either a buy or a sell) are aggregated and placed as a single trade. Doing so typically reduces the cost of trading as costs are shared. Our aggregation windows are defined on a fund by fund basis, with cut-off typically set to an hour before the funds valuation point each working day. Trade orders approved within an aggregation window will be placed no later than the working day following the aggregation window closing.

Aggregation often enables us to obtain terms that are generally not available to you as a retail client. However, this may also increase the likelihood of orders being oversized, and the Fund Managers may impose a dilution levy (this is where there are unusually high levels or buying and/or selling which increases the funds dealing costs and affects its value and will be apportioned across all clients included in the trade).

We’ll produce a contract note when your trade is contracted, which will show you the date and time of the trade.

We provide online only dealing services and trading instructions can only be approved through the app. Any error with the app may cause delays to investment instructions. We do not guarantee the continuous and faultless operation of services which may be temporarily suspended due to errors or repairs.

Execution Factors

We’ve considered a range of factors to ensure that you receive the best possible results, and these include price, costs, speed, likelihood of execution and settlement, size, and nature. However, these factors have no impact on fund dealing, and therefore we will execute all orders in line with the instructions provided by you or your adviser.

Fund suspensions

If a fund is temporarily suspended, we’ll be unable to buy or sell the affected fund. This means your investments may be temporarily out of line with the target weightings that your Adviser has recommended for you.

Specific instructions

Trading instructions will be accepted through your adviser. We cannot accept specific trading instructions directly from you, unless it’s in connection with a withdrawal you have requested.

Execution Venues

Trades can only be placed through EMX (our messaging service provider) or directly with the fund manager. Any errors with EMX or any break in the upload process could cause delays to the trade placement.

We’ll regularly review our messaging service provider against this execution policy to ensure we are satisfied with their performance.

Monitoring of this policy

Trades which are executed at a worse price than available, will have not been executed in compliance with this execution policy and will be corrected to put you in the position that you should have been in.

Policy review

This policy is reviewed annually or where there is any material change to our arrangements. We’ll notify you of any material changes to this execution policy by providing an updated version by email or by publishing it on our website and/or app.

Further information

Any further reasonable request for information about this execution policy can be made to the Touch by AJ Bell Support Team via email to support@ajbelltouch.co.uk. We will give you a clear response within a reasonable time.