1. Preamble

1.1. This document is prepared and published in accordance with the Investment Services Act (the Act) and any subsidiary legislation or regulation enacted under the Act, and rules and regulations implemented by the Malta Financial Services Authority in implementing the Markets in Financial Instruments Directive and implementing Directives, and is not intended to create third party rights or duties or form part of any contractual agreement between the firm and any client or potential client. This policy may be reviewed and amended from time to time.

2. Purpose

2.1. This Policy applies to both Retail and Professional Clients of Jesmond Mizzi Financial Advisors Ltd. When executing an order, the company will ensure that the best possible result for its clients is obtained. In general, when dealing with Retail clients, the company will achieve the best economic value at the time of executing orders. This is completed by making sure that the price is the best one possible. On the other hand, when dealing with professional clients, other factors such as speed of executing the order and size of order might determine best execution for the client.

3. Aggregation of Orders

3.1. As a company policy, client orders are treated individually and are not aggregated. However, Jesmond Mizzi Financial Advisors Ltd will seek to aggregate orders where it seems that this will result advantageously for its clients.

3.2. Additionally, although the company may aggregate orders for different clients, the company will not aggregate client orders with the orders of the company itself. Separate orders will be affected separating the company’s own transaction and the transactions executed on behalf of its clients. However, if the company aggregates a client order with transactions for its own accounts, and the order is partially executed, the company shall allocate the related trade to the client in priority to itself. Nevertheless, if the company would be unable to execute a client’s order if the order was not aggregated with its own account transaction, the order will be allocated proportionally.

3.3. Nevertheless, in certain circumstances aggregation of orders may not work to the advantage of the clients. In circumstances where clients will be disadvantaged due to aggregation of client orders, the company will proceed with the transaction only after obtaining the individual’s client consent.

3.4. When orders are aggregated, these are usually allocated to clients on the trading date and an average price (if the order was executed in different portions using different prices) and costs are apportioned on a pro rata basis. Furthermore, when an aggregated order is partly executed, allocation to clients will be done in proportion to the initial amount ordered. .

3.5. Customer accounting records are retained for a period of ten years. Such record includes all purchases and sales of Customer’s Assets, receipts and payments of money belonging to customers (arising from transactions carried out by the company), assets and liabilities of the company’s customers, and records clearly showing the person who is holding such assets, the location of the assets, and their beneficial owner.

3.6. If an error is identified in an allocation, a re-allocation may be made for an aggregated order. In such cases, a record of the reason for and the basis of the re-allocation must be fully documented, and the re-allocation will be completed within one business day of the identification of the error.

3.7. Should the company suffer from system failures or other unavoidable circumstances, the company may need to diverge from method of execution explained in this policy. However, the company will make sure that the best terms of order execution are used at that point in time.

4. Policy Review

4.1 Jesmond Mizzi Financial Advisors Ltd will review the Order Allocation Policy at least annually, and whenever a material change occur which will affect the operations of the company as well as providing the best possible service for its clients. The clients of the company will be informed whenever an updated version of this policy is available.

Version: April 2019