The purpose of this document is to provide clients of Psigma Investment Management (“Psigma”) with information on our Order Execution Policy. This document forms part of the Psigma Investment Services Terms and Conditions, acceptance of which provides your consent to this Policy.

This order execution policy is designed to ensure that we take all sufficient steps to achieve the best possible result (best execution) for you when we buy or sell investments on your behalf or when receiving and transmitting orders or passing orders onto others for execution as part of discretionary investment management services. The Company must also be able to demonstrate upon request that orders have been executed in accordance with this policy.

The rules regarding Best execution are set out by the Financial Conduct Authority ‘’FCA’’ and are further enhanced under the EU Market in Financial Instruments Directive (“MiFID & MiFIDII”). The rules apply to professional and retail clients and relate to all financial instruments dealt in the course of carrying our investment management business anywhere in the European Economic Area ‘’EEA’’.

This policy applies to all execution provided to clients and professional advisers with a direct contractual relationship with the Company. An order for the purposes of the Policy is an instruction to buy or sell a financial instrument, where Psigma is acting as the discretionary manager for a client or as directed by a client.

Professional Advisers using Psigma’s model portfolios on behalf of their Retail Clients through a Platform Service Provider should be aware that Psigma will maintain the model portfolios through the service providers interface, the service providers Order Execution Policy will determine the obligations to provide best execution to retail clients using the Psigma Model Portfolios on Platforms.