Order and Best Execution Policy

Contents

Version Control

2. About this policy

3. Details

1. Version Control

Date Version Name

1st February 2021 1.0 Original

15th June 2021 2.0 Updated the monitoring and review, and contact details

16th November 3.0 Amended monitoring and added allocation

Annual review

Next Review Date: January 2025

Director: Abdulaziz Alnaim,

Responsible Officer: Stefan Dawidowski

2 About this policy

This document (“the Policy”) sets out the approach taken by Mayar Capital Ltd. (“the Firm”) in ensuring that the best outcome its obtained for its clients on consistent basis when transmitting orders to third parties for execution. The Firm manages portfolios of investments on a discretionary basis for investment funds and managed account clients (together, "clients"). Mayar Capital Ltd. is authorised and regulated by the Financial Conduct Authority ("FCA").

This Policy has been updated to take into account new rules arising as a result of the implementation of the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”) that came into force on 3 January 2018. Other FCA Rules and Guidance have been taken into account in designing this Policy, as have other EU regulations and ESMA Guidance where appropriate.

This Policy applies only to the execution or transmission of client orders in Financial Instruments, as defined in MiFID II, except where noted otherwise. It also reflects the fact that the Firm deals with professional clients only.

3 Best Execution Commitment

When managing investments, The Firm operates policies and procedures to ensure it acts at all times in the interests of its clients. When executing orders, The Firm takes all reasonable steps to obtain the best possible results on a consistent basis.

Whether executing orders directly or placing orders with third parties, The Firm takes into account certain execution factors, as set out below. Based on its execution factors, The Firm chooses execution venues and entities most likely to deliver the best possible results. This applies whether The Firm executes orders directly or passes orders to a third party for execution. Where orders are passed to third parties, The Firm has procedures in place to ensure such entities also deliver best execution.

The Firm will assess, on a regular basis, the quality of execution provided by the execution venues and entities used and, if necessary, change its execution arrangements to ensure best execution is achieved on an ongoing basis.

Our policy is to exercise the same standards and processes across all markets and financial instruments wherever possible. However, due to the different nature of such markets and instruments, different factors may be taken into account when applying our execution policy.

4 Execution factors

When placing orders for execution, The Firm’s primary considerations are: price; liquidity; cost; speed of execution; likelihood of execution; size of order; settlement and any other factors relevant to the efficient execution of your order. The Firm determines the relative importance of the execution factors by using its commercial judgement and experience in light of market information available.

The relative importance of such considerations will be determined by reference to the relevant portfolio’s investment objectives, the order attributes, the financial instrument to which the order relates and the available execution venues. In the absence of specific reasons total consideration is likely to be the main consideration behind the choice of venue or execution entity. Price, however, is not always the final determinant and execution of orders at a price other than the best price available at the prevailing time will not necessarily constitute a breach of this policy.).

5 Execution venues

The Firm may use one or more of the following venue types when executing an order: Regulated Markets; Multilateral Trading Facilities; Systematic Internalisers; Market Makers and other providers of liquidity. We will select execution venues that meet our criteria for delivering best execution to you, which may include executing outside of a Regulated Market or a Multilateral Trading Facility where we believe best execution can be achieved.

The Firm is not a member of any exchanges, however, uses the Direct Market Access mechanism of a third party investment bank for some orders thereby maintaining control over the execution.

Orders may be passed to third party brokers, including brokers outside of the EEA who are not regulated by the Markets in Financial Instruments Directive. When selecting entities to execute orders on our behalf, we ensure such entities have execution arrangements in place that enable us to still comply with our best execution obligations. The Firm may aggregate orders with those for other clients provided no client is disadvantaged.

Where the use of one of our usual execution venues or entities would not, in a particular situation, result in the best possible result on your order, we will consider other execution venues and entities where available. Where there is only one appropriate venue or broker available for execution of your order, we will only use that single venue or entity to fill the order.

6 Exceptions

Our execution policy does not apply at a time of severe market turbulence, during abnormal or illiquid market conditions and/or internal or external system failure. Instead the ability to execute orders on a timely basis, or at all, will become the primary factor. In the event of a system failure we may not be able to access all of our chosen execution venues.

In certain situations, a client’s chosen broker and custodian account may limit our ability to fully adhere to our execution policy such as when it does not accommodate “trading away” with other institutions, has limited or no ability to receive orders electronically from of the electronic systems that we use, or other restrictions and limitations that may make the full application of our execution policy not possible. In those situations we set execution limits for the broker in question on the asset to be executed and set reasonable limits on the order at placement time and date and exchange price, making best efforts to send orders around the same time. Where a price is not available, the limit is set at a best-efforts basis by the fund manager.

7 Allocation

7.1 Mayar Capital Ltd. will operate in such a manner as to ensure that none of the funds or separately managed accounts (“SMA”) that it manages are favoured over another fund or SMA. In general orders will be placed simultaneously for all funds following the same strategy managed by Mayar Capital Ltd. Where possible, trades will be pooled and then allocated at the time of execution based on an average price “fill” and as such will ensure that all funds and SMAs share the same execution price.

The only exception to this will be:

Where a fund or client has restricted broker selection due to the choice of custodian or broker (see point 6), orders for these funds will be placed at the same time and date, making best efforts to send orders around the same time.

8 Monitoring and Review

We monitor the effectiveness of our order execution arrangements and order execution policy in order to identify and, where appropriate, correct any deficiencies. The execution venues and entities we use will be assessed annually and whenever there is a material change to ensure that they are providing the best possible result on a consistent basis. We will notify you of any material changes to our execution arrangements or policy as summarised above via our website unless you request this in writing.

9 Updating the policy

9.1 How often will we update the Policy?

We will update the Policy periodically as and when appropriate.

9.2 How can you obtain the most recent version of the Policy?

We expect to post the most recent version of the Policy on our website. If you would like to receive a copy of the most recent Policy, however, please contact us in the manner described in section VII below.

10 Contact Details

10.1 How do you contact Mayar Capital Ltd. in connection with this Policy?

If you have queries about the Policy, please contact Stefan Dawidowski (Mayar Capital Ltd.)