Legal, Disclaimers & Policies


Cavendish Capital Markets Limited is committed to the prevention, deterrence and detection of (a) criminal tax evasion and (b) criminal facilitation of tax evasion.  Accordingly, the Company has adopted a policy for preventing the criminal facilitation of tax evasion (the “Policy”).  Details of the Policy relevant to external Associates of the Company are available on request.

Best Execution Policy

This is a summary of our best execution and order handling policy which we follow when executing orders on your behalf. By giving us orders to trade after receiving this policy summary, you will be consenting to having your orders handled by Cavendish Capital Markets Limited in accordance with its best execution policy. If you would like further information about our best execution policy, please contact us.

What is best execution and order handling?

How do we satisfy the best execution obligation?

  • price
  • costs of transactions (i.e. the fees charged for executing an order on a particular venue) which are passed on to you, directly or indirectly
  • speed
  • likelihood of execution (how liquid is the market in the particular product?)
  • likelihood of settlement
  • size of order

and we must take into account:

The importance of these factors has been weighted according to product.

Order Handling

  • We will allocate all orders fairly and will not give preference to one client over another.
  • If we have aggregated client orders with our own orders and we cannot complete the total order we will fill the client orders first unless we can show that without our participation the order could not have been filled on such favourable terms or at all.

Conflicting interests or duties may arise because:

  • procedures to prevent or control the exchange of information e.g. between staff responsible for advising corporate clients of Cavendish Capital Markets and staff providing investment advisory or management services to investment clients;
  • separate supervision of staff whose principal functions involve carrying out activities for or providing services to clients whose interests may conflict;
  • avoiding direct links between the remuneration of staff principally engaged in one activity and the remuneration of different relevant persons engaged in another activity, where a conflict of interest may arise;
  • avoiding remuneration arrangements that reward behaviour that disadvantages the interests of clients in favour of the firm or other clients;
  • procedures to prevent or limit any person from exercising inappropriate influence;
  • procedures to prevent or control the simultaneous or sequential involvement of a member of staff in separate services where such involvement may impair the proper management of conflicts of interest;
  • allocation policies in relation to orders placed for more than one client;
  • staff personal account dealing policies;
  • policies which require staff not to solicit or accept inducements that could conflict with our obligations to our clients, nor offer or give inducements which could conflict with the recipient’s obligations to clients;
  • detailed policies and procedures in place on the giving and receiving of gifts and hospitality;  
  • disclosure to the client – where all other reasonable steps to manage a particular conflict of interest have failed.

The firm’s Compliance department is responsible for monitoring Cavendish Capital Markets policies and procedures for identifying and managing conflicts of interest, and for ensuring that any significant issues identified as a result of this monitoring are reported to senior management and handled appropriately.

Specific disclosures

In all the cases set out below, the firm has arrangements in place to ensure that the payments do not impair compliance with the firm’s duty to act in the best interests of the client.

Commission to intermediaries who introduce clients to the firm

Cavendish Capital Markets may pay a share of the dealing commission and fees charged to the client to the intermediary who introduced the client to the firm. Information about any commission and fee sharing arrangement relating to their business are provided to the relevant clients, and further details will be provided on request.

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