Arjent Limited
Advisory Broking

Order Execution Policy ("OEP")

Introduction
Arjent Limited ("the Firm") is authorised and regulated by the Financial Services Authority ("FSA"). The Firm undertakes advisory broking for a range of clients, with a mixture of strategies and its Scope of Permissions enable it to; advise on investments, arrange deals in investments, deal in investments as agent and to make arrangements with a view to transactions in investments.

As an advisory broker, Arjent recieves instructions from its clients to deal and then transmits these decisions on behalf of its clients to other Brokers for Execution. This method of achieving execution will be explored later.

The Firm is an investment firm and as a result of the above services and activities undertaken, it falls under the Market in Financial Instruments Directive ("MiFID") that came into effect on 1 November 2007. Under MiFID, investment firms are required to ensure that they take all reasonable steps to deliver the best possible result when orders are executed on behalf of clients, taking into account the Execution Factors (known as "the Best Execution Obligation"). The Best Execution Obligation requirements are set out in the FSA Handbook under COBS 11.2.

When providing the service of advisory broking, the Firm will always act in the best interests of its clients when placing orders with other entities for execution. Those orders result from decisions by the Firm's clients for the Firm to deal in financial instruments on behalf of its clients.

Best Execution relates to all types of financial instruments, however, due to the differing obligations that arise as a result of utilising differing instruments, the transmission of orders will be applied in a manner that takes into account the different circumstances associated with the execution of orders related to particular types of financial instruments. Best Execution will apply to each client order transmitted to the Broker for execution.
Purpose
As required by FSA regulations, the Firm has developed this Order Execution Policy ("OEP") setting out the arrangements that the Firm has in place to comply with the Best Execution Obligation. The auxiliary purpose of setting out our OEP is in order that we are able to communicate our policy to clients as appropriate and to obtain their consent.
Obligation
All employees of the Firm with the authority and/or responsibility to place orders must ensure that, in placing orders, they always act in the best interests of each client. This is to be by following the approach set out in this OEP except where we can clearly demonstrate that a better outcome for that client in that transaction can be achieved by an alternative approach. In the event of employing such an alternative approach, the individual responsible must record and report the circumstances to the Compliance Officer, who will consider whether amendments to this policy are required.

Insofar as we receive specific instructions from a client in relation to a transaction, those instructions supersede our OEP. Execution of such an order must comply with the client instructions and, otherwise, where it does not conflict with these instructions, in accordance, with this OEP.

The Firm will be involved in the transmission of orders in certain types of financial instruments, according to the trading strategies followed. The decision is taken with reference to the 'Execution Factors' and the 'Execution Criteria'.
Execution Factors
The Execution Factors are the issues that the Firm must consider when undertaking to deliver Best Execution. They constitute the differing considerations that can be given precedence in the trading process, dependent on the individual situation. The Firm's OEP aims to set out the process for determining the relative importance of each of the Execution Factors in relation to each trade. The factors to be considered are:
1. Price;
2. Broker's relevant expertise related to specific instruments traded;
3. Speed of execution;
4. Transaction costs, including fees and commissions;
5. Likelihood of execution and settlement;
6. Size of the order;
7. Nature of the order (sale or purchase etc);
8. Market impact; and
9. Other considerations relevant to the order.
The relative importance to the client of each of the above will help to establish Best Execution. Typically, our priority will be the likelihood of successful execution and settlement, followed by price and cost
Execution Criteria
When transmitting an order to a Broker for execution of a client order, the Firm must take into account the following criteria for determining the relative importance of the execution factors:
1. The characteristics of the client;
2. The characteristics of the client order;
3. The characteristics of the financial instruments that are the subject of that order; and
4. The characteristics of the execution venues to which that order can be directed.
Through the careful application of these Execution Criteria, in each instance the priority of each Execution Factor will be determined. This is set out in further detail below.
Use of Broker
The Firm's policy is to use RBC Correspondent Services ("the Broker") as the sole broker. The Firm has considered, and will keep under review, the appropriateness of the Broker. The Firm will endeavour to ensure the Broker is able to obtain results for clients at least as good as the results that it reasonable could expect from using alternative entities.
1. Selecting the Broker
  The Firm will apply the Execution Factors as follows: our priority will be the likelihood of successful execution and settlement, followed by price and cost. Consequently our use of RBC Correspondent Services is intended to enhance the overall quality of execution in terms of all these factors.
2. Considerations relating to broker/counterparty expertise and illiquid instruments.
  The Firm only deals in financial instruments that are readily available and are highly unlikely to become illiquid. In the event an instrument in question presents obstacles to successful execution due to obscurity, under-researched markets, illiquidity or small capitalisation, the Firm may engage a broker/counterparty with relevant market knowledge and experience for such a transaction. In selecting the appropriate broker/counterparty the priority factor will be their expertise in relation to the instrument in question on the grounds that this will result in the best overall execution in terms of achievement of execution and price. Under these circumstances, the transaction cost - particularly the broker's commission - may not be the most competitive, and as such would be given a lesser overall priority.
3. Considerations relating to commission rates
  The Firm's policy on commission rates is quite simply to select the broker/counterparty with the most competitive rates bearing in mind the Execution Factors and Execution Criteria (given that the Financial Instruments are US securities exclusively traded on US Markets). However, as is made clear elsewhere in this policy, cost of transaction is usually not the highest priority and in some circumstances will be a lowly rated factor, but where there is a direct choice of broker with other factors being equal, the lower commission rated broker will be employed.
  
  By direct extension, where commission can appropriately, without client disadvantage, be avoided altogether, it is our policy to deal in that way.
4. Considerations relating to large transactions
  Where a transaction is large in comparison to the normal market size for that instrument, the Firm may use a broker to manage the execution of the transaction, exercising his discretion and expertise. In these circumstances, our priority factor will normally be either the broker's ability to complete the transaction successfully, or to achieve the best practicable market price in relation to the size of the order. Consequently, the costs of transaction in terms of the broker's commission will be attributed a relatively low priority, reflecting the importance of selection of a broker known to be expert at achieving execution in these circumstances.
5. Considerations relating to speed of transactions
  When the price of the contemplated instrument is moving quickly, either as a result of news relating specifically to the underlying economic factors that may have an impact on that instrument or because of wider market movement, speed of execution will usually be the priority factor. The achievement of speedy execution is achieved either through an appropriate broker /counterparty known to be capable of achieving fast execution in the circumstances and in the instrument in question. Second to speed, will be successful transmission, followed by the question of cost. In these circumstances the price factor is inevitably given a lesser overall priority.
6. Considerations relating to speed of settlement
  In the comparatively unusual situation that the speed of settlement is of material importance, this factor will be prioritised above costs of transaction and price, although this does not imply that cost and price are irrelevant - merely lower priority. As a means of procuring speedy settlement, it will be necessary to negotiate with a broker/counterparty for special settlement terms. Usually this latter will result in the selection of a substantial and well capitalised broker/counterparty capable of providing such a service, not withstanding that they might not be the most cost competitive. In exceptional circumstances settlement may be delayed and this will be agreed between the Firm and the relevant broker/counterparty at the time of transmission. In these circumstances the speed of settlement is inevitably given a lesser overall priority.
7. Considerations relating to geographical location
  In the selection of broker/counterparty, geographical location will sometimes be a material consideration. Where appropriate, in order to minimise the cost of transaction, it is the Firm's policy to use a broker/counterparty to which it has access. In practical terms this will usually only apply in geographical locations where well developed markets exist. Where the proposed transaction concerns an instrument of some obscurity, the use of a broker/counterparty with known expertise in relation to that instrument and wherever geographically it is traded will usually be the preferred means to ensure successful execution and best price but recognising that the broker/counterparty may not be competitive on cost.
8. Details of brokers/counterparties
  As set out above, the selection of brokers/counterparties will result from the prioritisation of the execution factors as appropriate for the individual transaction. Currently our Broker is RBC Correspondent Services. This appointment will be updated from time to time to reflect new brokers/counterparties. It is acceptable in some circumstances, as explained above, for price and/or cost not to be the highest factors. However where the decision is taken that other factors have higher priority in the context of an individual transaction, a record is to be made, as part of the transaction record, of that decision and the rationale for it. Usually price and cost will be the highest priorities, subject of course to the fundamental capacity of that venue/broker to facilitate the transaction.
  Any amendment to the broker/counterparty details set out in the appendices are to be notified to the Compliance Officer.
Client consent
We are required by the regulations to obtain the consent of each client to our execution policy. Unless the client advises us to the contrary, we will deem that consent to have been provided following their receipt of the notification contained within the summary of this OEP.
Changes to this OEP
Although the Firm as a transmitter of client orders (not an executor) is not obliged to inform clients of alterations to this OEP the Firm will do so. In the event that we amend this OEP in such a way as to bring about a material change (for example select another or replacement Broker), it is the responsibility of the Compliance Officer to ensure that we notify our clients of that change. A material change is one where its disclosure is necessary to enable you to make a properly informed decision about whether to continue utilising our services. Immaterial changes will not be the subject of a notification.
Client instructions
As set out above, in the event that specific instructions are received from a client in respect of the execution of a transaction, the Firm is deemed to have complied with its best execution obligations by following those specific instructions. Clients may not be induced to give specific instructions in order to remove the need for the provision of Best Execution.
Evidence of Best Execution
We are obliged by the FSA rules to be able to demonstrate to our clients, at their request, that we have transmitted orders in accordance with this OEP. It is therefore essential the Firm will maintain adequate details for this purpose.
Monitoring and review of execution arrangements and policy
To ensure that this OEP remains appropriate and in line with the requirements, the Compliance Officer will ensure that it is reviewed at least annually by the Board. A review will also take place in the event of any change of circumstances which may affect the Firm's ability to achieve best execution.

This will include a review of available Brokers to ensure the Broker continues to be appropriate in achieving best overall results on execution of orders.

It will also be a review of access providers to determine whether they continue to provide access on appropriate terms. The Broker is assessed and if falling below the necessary standard is required to improve their performance or cease to be used by the Firm.

The dates and details of any changes to the Order Execution Policy, or Brokers will be documented by the Compliance Officer.

The Firm will undertake quarterly compliance monitoring to determine whether the transactions have been conducted in accordance with the Order Execution Policy.