Fundsmith Equity Fund
692.28p T Class Acc, 23 Jul 24

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An ISA (Individual Savings Account) is a savings account available to UK residents on which the return is tax-free and which need not be declared on the investor’s tax return. All income (dividends and interest) and all capital gains within the account are free of tax. For the current year, 6 April 2024 to 5 April 2025 the overall investment limit is £20,000 (excluding the British ISA which has a separate £5,000 limit).

 

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.