Best execution and order handling policy
This page sets out Cushon's Best Execution and Order Handling Policy, explaining how we manage and execute orders on behalf of our customers, including how we seek to achieve the best possible outcome when transacting on your behalf and how we manage the associated transaction and trading costs.
This policy applies to you as a customer of Cushon Money Limited ("Cushon"), a subsidiary of Cushon Group Limited. It explains how we execute orders in Investment Funds on your behalf.
We are required under UK financial services regulations, including the rules of the Financial Conduct Authority ("FCA"), to establish an order execution policy and to take all reasonable steps to achieve the best possible outcome for you when handling your orders. Whilst we are committed to seeking the best execution on your behalf, we cannot guarantee this will be achieved in every instance. This commitment does not create any fiduciary duty beyond our specific regulatory obligations or any obligations otherwise agreed between us.
This policy covers the following Cushon savings products:
Stocks and Shares Individual Savings Account ("ISA"), including the Lifetime ISA ("LISA") and Junior ISA ("JISA")
General Investment Account ("GIA")
The following terms are used throughout this document:
Term
"Cushon", "we", "our", "us"
Definition
Cushon Money Limited, a subsidiary of Cushon Group Limited.
Term
"Customer", "you", "your"
Definition
A holder of a Cushon savings product.
Term
"Execution Only"
Definition
An order placed entirely by you, without any input, advice or guidance from Cushon.
Term
“Investment Funds”
Definition
UCITS-compliant investment funds and non-UCITS compliant retail funds
Term
"UCITS"
Definition
Undertakings for Collective Investment in Transferable Securities — a type of regulated investment fund that meets UK standards for retail investors.
Through the Cushon platform, you can buy and sell units in Investment Funds. Orders are placed on an Execution Only basis, meaning they are directed entirely by you.
Cushon does not deal directly in the market. Instead, all orders are transmitted to a third-party custodian of our choosing, who transacts on your behalf. Cushon deals only in Investment Funds and does not deal in any other types of investments.
Cushon's best execution obligation applies to the orders we transmit to our third-party custodian on your behalf. Whilst Cushon does not deal directly in the market, we are responsible for executing your orders with our custodian, who in turn transacts in the market on your behalf. We seek to ensure that this process delivers the best possible outcome for you, including minimising costs wherever possible.
As part of our best execution obligations, we periodically review our choice of third-party custodian to ensure they continue to deliver the best possible outcomes for our customers.
Cushon receives order instructions in a number of ways:
Direct instructions – where you direct Cushon to buy or sell Investment Funds on your behalf, either through the Cushon platform or via our customer services team.
Automatic investments – where money received from you or on your behalf is automatically invested in line with your standing investment instructions. This includes payroll contributions, one-off payments, and cash transfers of existing savings into your account.
Automated platform processes – such as collection of platform charges
All order instructions are categorised as either “buy” or “sell” depending on the nature of the request.
Cushon aggregates all orders twice daily, at 11am and 4pm. Orders received before each aggregation time are included in that aggregation run, subject to a cut-off time immediately prior. Any orders received after the cut-off will be carried forward to the next aggregation run.
Depending on the volume of orders being processed, aggregation may take up to 12 hours to complete in exceptional circumstances. Once aggregation is complete, your order will be dealt with our third-party custodian immediately. Please note that aggregation and dealing can occur outside of standard business hours.
Our third-party custodian operates trading cut-off times for each Investment Fund. Orders received by them from Cushon before their cut-off are placed at the corresponding Fund Manager Valuation Point for that day. Orders received after the cut-off will be placed at the following Valuation Point. Fund Managers set these Valuation Points regularly, and all orders received prior to a Valuation Point will be executed at that point.
To illustrate how this works in practice:
Order placed : 1pm
Aggregation time: 4pm
Aggregation completed: 7pm
Fund valuation point: 5pm/9pm
Execution: 5pm on following day/9pm on same day
Cushon commits to ensuring your order is executed in the market within 3 working days of your instruction being received. This commitment applies consistently across all order types, whether a buy or a sell.
Cushon does not charge you for the execution of orders. As part of our commitment to best execution, we seek to minimise the costs associated with order handling through our approach to aggregation and our third-party custodian relationships.
Investment Funds may incur their own costs and charges, which are set and managed independently by the relevant fund managers. These are outside of Cushon's control and remit, and you are encouraged to review the relevant fund documentation, including the Key Investor Information Document or fund factsheet, prior to placing any order.
Cushon reconciles all customer cash and assets on a daily basis. This process is designed and maintained to meet the FCA’s Client Assets and Client Money rules, which are in place to ensure your assets are appropriately safeguarded at all times.
In the event of any reconciliation discrepancy, Cushon has established procedures to investigate and resolve the matter promptly, including direct engagement with our third-party custodian where required.
If you have questions regarding this policy, please contact us:
Address: 51 Lime Street, London, EC3M 7DQ, UK
