Order Execution Policy

I. THE POLICY

1. Purpose

   The purpose of the Order Execution Policy (“the Policy”) is to set out the strategy adopted by Fundsmith LLP (“Fundsmith” or “the Firm”) to obtain the best possible result for each Fund when orders are placed with other entities for execution.

2. Introduction

   Fundsmith LLP (“Fundsmith” or “the Firm”) is authorised in the UK by the Financial Conduct Authority (“FCA”) as a Collective Portfolio Management Firm. Fundsmith is:

   • The authorised corporate director of two open-ended collective investment schemes which are authorised under UK UCITS;
   • Authorised under UK AIFMD as a full scope alternative investment fund manager in respect of a closed-ended investment trust listed on the London Stock Exchange, which is considered a UK alternative investment fund (“AIF”).
   • Appointed as the investment manager to three US domiciled limited partnerships, which are considered non-UK AIFs.
   
   

   The above funds are collectively referred to as “Funds”, and each a “Fund”.

   The Funds, invest in listed equities on a global basis, employing a buy-and-hold investment strategy that seeks to achieve long-term growth in value. The Firm’s approach is to be a long-term investor in its investee companies and it does not adopt short-term trading strategies.

   Fundsmith has delegated the management of trade execution for its Funds to its affiliate, Fundsmith Investment Services Limited (“FISL”). Fundsmith and FISL are related entities by virtue of common ownership. FISL is also the investment manager of the Fundsmith SICAV and a number of segregated mandates. FISL is responsible for the implementation of the Policy in respect of all clients of both firms.

   FISL has engaged Northern Trust Securities LLP (“NTS”) to provide broker and trade execution services for the Funds on an agency or matched principal basis. NTS is a leading provider of execution services with in-depth expertise of trade execution across global equity markets. NTS was selected to undertake this function following detailed due diligence of its execution capabilities.

   See section four for information on NTS’ selection of execution venues.

   See section six for information on Fundsmith’s oversight of FISL and NTS.

3. Execution factors

   In its role as management company to the Funds, Fundsmith ensures that all sufficient steps are taken to obtain the best possible result for each Fund that it manages when orders are placed on behalf of the Funds with other entities, taking into account:

   • price;
   • costs;
   • speed;
   • likelihood of execution;
   • likelihood of settlement;
   • order size and nature;
   • and any other consideration relevant to the execution of the decision to deal,
   
   

   (collectively, the “Execution Factors”).

   When determining the relative importance of the Execution Factors, the following criteria are taken into account:

   • the objective, investment policy and risks specific to the Fund, as indicated in its prospectus or its constituting instrument;
   • the characteristics of the order;
   • the characteristics of the financial instruments that are the subject of the order;
   • the characteristics of the execution venues to which the order can be directed.
   
   

   The relative importance of the Execution Factors will vary considerably between orders. In executing trades, NTS will use their expertise and commercial judgement to evaluate the available market information to achieve the optimal balance across a range of potentially conflicting Execution Factors. Notwithstanding that, in certain situations, the Execution Factors will generally be prioritised as follows:

   For orders in equities that are highly liquid, price and costs will usually be the most important Execution Factors. For orders where there is less liquidity, the price, size of order and likelihood of execution tend to be prioritised. Furthermore, given order sizes can be significant, market impact is an important factor and the preference, where possible, will be to trade in blocks.

   In responding to significant subscriptions and redemptions, program trades are undertaken, which typically involve single trades in multiple equities. In these circumstances, speed, price and likelihood of execution and settlement tend to be the most important Execution Factors.

4. Execution venues

   NTS use their expertise and judgement to obtain prices from execution venues including: regulated markets; multilateral trading facilities; organised trading facilities; systematic internalisers; market makers and other liquidity providers; as well as non-UK / non-EU entities performing similar functions to the foregoing.

   NTS conduct ongoing monitoring on its chosen execution venues, which includes, but is not limited to, consideration of creditworthiness and financial stability and review of the performance of the execution venue.

   See Appendix I for a list of execution venues on which NTS places significant reliance in meeting its obligation to take all reasonable steps to obtain the best possible result for the execution of orders on a consistent basis.

5. Execution outside of a trading venue

   NTS may execute an order on behalf of the Funds which takes place outside of a trading venue, being a regulated market, a multilateral trading facility or an organised trading facility. Orders executed outside a trading venue may give rise to counterparty risk. Additional information about the consequences of this can be provided on request.

6. Oversight

   Fundsmith monitors the implementation of the Policy and the effectiveness of the order execution arrangements on a regular basis to identify any deficiencies and correct them where appropriate.

   Fundsmith maintains a supplier management framework, the purpose of which is to ensure that suppliers remain appropriate to provide the relevant service. The execution arrangements of FISL and NTS are subject to ongoing oversight to ensure they continue to allow Fundsmith to obtain the best possible results for the Funds on a consistent basis.

   The execution quality of NTS is reviewed through second line compliance monitoring that considers third party total cost analysis.

APPENDIX I – NTS' EXECUTION VENUES

A J Bell Securities Limited	First Equity Limited	ODDO BHF SCA
Abbey Nat. Treasury Serv Plc	First Sentinel Corporate Finance	Old Mission
Abg Sundal Collier Asa	Fiske plc	Oppenheimer
Abn Amro Bank N.V	Flow Traders	Optiver V.O.F.
Academy Securities	Forte Securities Limited	ORA Traders B.V.
Acg Advisors (Uk) Llp	Freetrade Limited	Otkritie Capital Intl Ltd
Adm Investor Services Intl Ltd	Gca Altium Limited	Panmure Gordon (Uk) Limited
Alexander David Securities Ltd	GFI Securities Limited	Pareto Securities
Alfa Cap Holdings (Cyprus) Ltd	GHC Capital Markets Limited	Pavilion Global Markets Ltd
Algoengineering Europe Limited	Gibraltar Asset Management Ltd	Peel Hunt Llp
Algorithmic Trading Group Bv	Global Investment Strategy UK Limited	Pershing
Alize Trading Sas	Global Liquidity	Peterhouse Capital Limited
All Options International B.V.	Goldenberg Hehmeyer LLP	Pictet Global Markets (UK) Limited
Allenby Capital Limited	Goldman Sachs	Pilling & Co Stockbrokers Ltd
Alliance Trust Savings Limited	Goodbody Stockbrokers Uc	Piper Sandler
Anglo-Suisse Capital Limited	GPIM Limited	Platform Securities LLP
Arbuthnot Latham & Co. Limited	GTS	Pragma
Arctic Securities As	GüX ADR	QCM Cayman Ltd
Armira Capital Limited	Haitong International (UK) Limited	Quilter Cheviot Ltd
Arnold Stansby & Co Limited	Halifax Share Dealing Limited	R.J. O'Brien Limited
Arqaam Capital Limited	Hargreaves Lansdown Asset Mgnt	Radix Trading Europe B.V.
Atonline Limited	Hauck & Aufhaeuser Privatbankiers Ag	Ravenscroft (CI) Limited
Aurel BGC	Hedley & Company Stockbrokers Ltd	Raymond James
Autonomous Research Llp	Hobart Capital Markets Llp	RBC
Avalon Capital Partners Limited	HSBC	Redburn Atlantic
Avior Capital Markets Int Limited	Huatai Financial Holdings	Redmayne-Bentley LLP
Axis Capital Markets Limited	Hubwise Securities Limited	Renaissance Capital Limited
Baader Bank	Hudson River Trading Europe Ltd	Riverfort Global Capital
Baird	Hybridan LLP	Rosenblatt
BAML	IBKR Financial Services AG	Rowan Dartington & Co Limited
Banca Imi S.P.A.	ICAP	RW Baird
Banco Santander S.A.	ICBC Standard Bank Plc	S P Angel Corporate Finc Llp
Bank Julius Baer & Co. Ag	iDealing.com Limited	Samsung
Bank of Nova Scotia (London Branch)	IG Markets Limited	Sanford Bernstein
Barclays	IIFL Securities Limited (India Only)	Sanlam Securities UK Limited
Barratt & Cooke	IMC Trading B.V.	Sapia Partners LLP
Barrenjoey Markets Pty Ltd	Instinet Europe & APAC Limited	Sberbank CIB (UK) Ltd
Bcs Prime Brokerage Limited	Interactive Brokers	Sbg Securities Pty Limited
Beaufort Securities Ltd	Intermonte Sim S.P.A	Scotia
Berenberg	Intesa Sanpaolo S.p.A.	Seaport Group Securities
Bell Potter Securities Limited	Investec Bank Plc	SEB
BestEx	Investment Funds Direct Limited	Seven Investment Management LLP
BGC Brokers L.P.	ISI US HT	SG Option Europe S.A.
BGL BNP Paribas	ITAU BBA Securities	Shard Capital Partners Llp
BIDS Trading	ITI Capital Limited	Shore Capital Stockbrokers Ltd
Blankstone Sington Limited	J & E Davy	Sigma Broking Limited
BlockCross	J.M. Finn & Co.Ltd	Skandinaviska Enskilda
Bmo Capital Markets Limited	J.P. Morgan	SMBC Nikko (Japan Only)
Bnp Paribas	James Brearley & Sons Limited	Smith & Williamson Investment
Bradesco	James Sharp & Co LLP	Societe Generale
Brandon Hill Capital Ltd	Jane Street Financial Limited	Sova Capital Limited
Brewin Dolphin Limited	Jarvis Investment Management Limited	Spark Capital Advisors (India) Private Limited
Britannia Global Markets Limited	Jarden	Speedroute
Bryan Garnier & Company Limited	Jefferies International Ltd	SSW Market Making GmbH
BTIG	Joh. Berenberg, Gossler & Co. Kg	Stephens
Cabrera	Jump Trading Europe B.V.	Stern Brothers
Caixabank	Kbc Securities N.V.	Stifel
Canaccord	KBW	Stockdale Securities Limited
Canadian Imperial Bank of Commerce	KCG (VIRTU)	StoneX
Cantor, Fitzgerald & Co., Inc.	Kempen & Co N.V.	SunTrust
CAPIS US	Kepler Chevreux	Susquehanna Intl Sec Ltd
Capital Plus Partners Limited	KeyBanc	Svenska Handelsbanken AB (publ.)
Cardale Asset Management Limited	Killik & Co LLP	Tavira Securities Limited
Carnegie Investment Bank Ab	King & Shaxson Limited	Telsey
Castlefield Investment Partners LLP	Kyte Broking Limited	TFS Derivatives Ltd
CastleOak Securities	Lakeshore Securities	The Link Asset and Securities Co Ltd
Cave & Sons Limited	LEK Securities UK Limited	The Share Centre Limited
Cavendish	LGT Vestra LLP	The Toronto-Dominion Bank
China International Capital Corporation	LHCM Ltd	Third Platform Services Limited
CICC	Liberum Capital Limited	Thomas Grant & Company Ltd
Citadel	Linear Investments Limited	Tigress
Citigroup Capital Markets	Liquid Capital Australia Pty Ltd	Tilney Investment Management
Clearpool Technology	Liquidnet	Tourmaline Europe LLP
CLSA	Lloyds Bank	Tower Research Capital Europe Limited
CODA	Logic Investments Ltd	Trium Capital Managers Ltd
Commerzbank Ag	Loop Capital Markets	Tullett Prebon
Cooperatieve Rabobank U.A.	Louis Capital Markets Uk Llp	Turner Pope Investments (TPI) Ltd
Cowen Execution Services Limited	Luminex	Two Sigma
Credit Agricole	LXM Finance LLP	UBS
Credit Industriel et Commercial	M D Barnard & Co Ltd	UG Europe AG
Credo Capital Limited	Macquarie	Unicredit Bank Ag
CWG Markets Ltd	Mainfirst Bank Ag	Utr8 BV
Daiwa Capital Markets	Marex Financial	Valbury Capital Limited
Danske Bank As	Mariana UFP LLP	Van Lanschot Kempen Wealth Mgnt
Dash Financial	Market Wizards B.V.	Vantage Capital Markets LLP
Deutsche Bank	Maxim Group LLC	Velocity Trade International
Dinosaur Financial	MCAP	Virtu
Dnb Bank Asa	Mediobanca - Banca di Credito	Vontobel
Dougall FIX Connection	Mirabaud Securities Limited	VTB Capital PLC
Dowgate Cap Stockbrokers Ltd	Mischler Financial Group, Inc.	W H Ireland Limited
DRW	Mizuho International Plc	Walker Crips Stockbrokers Ltd
EC Markets Group Ltd	MMX Trading B.V.	Webb Traders B.V.
Eclipse Futures (HK) Limited	Monecor (London) Limited	Wedbush Europe Limited
ED&F Man Capital	Morgan Stanley	Wells Fargo
EFG	Mufg Securities Emea Plc	Whitman Howard Limited
Embark Investment Services Limited	NAGA Markets Europe	William Blair
Emkay (India Only)	National Financial Services LLC (Fidelity)	Wilson Advisory (Australia Only)
Equiniti Financial Services Limited	Natixis	Winterflood Securities Ltd
Everbright Sun Hung Kai	Natwest Markets Plc	Wolverine
Execution Noble Ltd	Nomura International Plc	Wood And Company
Exotix Partners Llp	North South Capital	Xconnect Trading Limited
Farley & Thompson LLP	Novum Securities Limited	XTX Markets Limited
Fidante Partners Europe Ltd	Nplusü Singer Capital Mkts Ltd	Zeus Capital Limited
FinecoBank S.p.A.	Numis Securities Limited	Zurcher Kantonalbank
Finovesta GmbH	Nyenburgh Holding B.V.