Best Execution & Order Allocation Policy for Wise Assets UK Ltd.
Last updated: 23 May 2025
1. Overview of Best Execution
The FCA’s Conduct of Business Sourcebook (COBS), derived from the MiFID II Directive (2014/65/EU) and related regulations, requires Wise Assets UK Ltd (“Wise Assets”, or “firm”) to take all sufficient steps to obtain the best possible result for clients, taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of an order. The firm, at all times, strives to act in accordance with the best interests of its clients when transmitting client orders to other entities for execution.
In order to comply with the overarching best execution requirement (above), Wise Assets will ensure that appropriate execution policies and/or arrangements are effectively implemented for the carrying out of all orders.
Wise Assets will apply our execution policies to each order with a view to obtaining the best possible result in accordance with the execution policy.
The detailed policy for order execution contained below will be reviewed regularly and clients will be informed of any material changes to the policy.
This policy is intended, in as clear a way as possible, to demonstrate how Wise Assets operates and provides best execution as often as is possible. You may request information about Wise Assets’ policies or arrangements. The requests must be reasonable and proportionate and Wise Assets will answer clearly and within a reasonable time.
1.1 Order Placement
Due to the way Wise Assets’ service is provided, all orders are placed through the Wise App. Wise Assets is not able to take client orders via telephone or email.
2. Order Execution Factors
The decision as to which execution venue is used for any one trade will be reached based on the price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of an order. This decision may be influenced by the firm’s own fees and commissions. Where there is only one execution venue to place your order, Wise Assets will be required to use that venue irrespective of the above factors. This is usually the case when an order is placed within a collective investment scheme (i.e. Unit Trust or Open Ended Investment Company). This venue will be ‘Direct with Fund Manager’.
When executing an order, the firm will generally treat price and speed as the highest priority for ensuring best execution. Only under exceptional circumstances would this not be the case.
In order to calculate the price, the firm will pay due attention to the ‘total consideration’. This is represented by the price of the financial instrument and the costs related to execution, which must include all expenses incurred by you which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.
2.1 Execution Venues
An ‘execution venue’ includes a regulated market, a Multilateral Trading Facility (MTF), an Organised Trading Facility (OTF), a systematic internaliser, or a market maker or other liquidity provider or an entity that performs a similar function in a third country to the function performed by any of the foregoing.
The below table shows which instruments Wise Assets deals in and which execution venue is used for each instrument. Orders will be executed outside of a regulated market.
| Instruments | Execution Venues/Clearer |
|---|---|
| Units | Direct with the Fund Manager: Blackrock BlackRock (Luxembourg) S.A |
| Units | Direct with the Fund Manager: BlackRock Asset Management Ireland Limited |
Wise Assets believes that the execution venue above is appropriate to providing best execution to you as our service is offering a single venue product. This enables the firm to obtain on a consistent basis the best possible result for the execution of client orders. The charges passed down to you are consistent with the cost to the firm of dealing with the Fund Manager. As this is a single venue product, there is no discrimination against any one execution venue.
2.2 Execution Criteria
When executing your order, we will take into account the following criteria for determining the relative importance of the execution factors above:
- your characteristics including your categorisation as a retail client;
- the characteristics of your order;
- the characteristics of financial instruments that are the subject of that order;
- the characteristics of the execution venue to which that order can be directed.
As best execution obligations apply to all financial instruments, irrespective of whether they are traded on trading venues or OTC, the firm will gather relevant market data in order to check whether the OTC price offered to you is fair and delivers on the best execution obligation.
2.3 Selecting an Execution Venue
As we are only offering a single venue product, we have taken the decision to execute all orders directly with the Fund Manager, BlackRock Investment Management (UK) Limited. We assess each Fund Manager’s order placement and execution policy as part of our Fund Manager due diligence process to ensure that it aligns with our commitment to achieving the best overall execution of client orders, taking into account the order execution factors. A copy of BlackRock Investment Management (UK) Limited’ Global Execution and Order Placement Disclosure can be found here.
We believe that placing and executing your orders directly with the Fund Manager allows us to achieve the fastest trading times with the lowest cost to you. This is because WAUK is able to access reduced fee classes for each of the traded funds and obtain fee rebates from the Fund Manager which we, in turn, pass on to you through reduced Wise Assets fees.
Wise Assets executes orders outside a regulated trading venue. As such, you may be exposed to additional risks, including counterparty risk from trading outside a trading venue. Upon your request, Wise Assets will provide additional information about the consequences of this means of execution.
2.4 Conflict of Interests/Inducements
Wise Assets does not receive any financial or non-financial benefit for routing your orders to a particular trading venue which would constitute a conflict of interest.
Due to our agreement with the Fund Managers, Wise Assets may receive a fee rebate for the various funds offered which are, in turn, passed on to you through reduced Wise Assets fees.
Details of these rebates can be found on the Funds and Fees page.
2.5 Order Allocation
Wise Assets is required to ensure that all purchases and sales of Units should be allocated fairly across all clients unless there are reasons for acting differently. Subject to COBS 11.3.7A; Wise Assets may aggregate transactions for clients with those of other clients, and will allocate such transactions on a fair and reasonable basis. When Wise Assets aggregates your order with an order for another client it must do so in accordance with this Policy and ensure that it is consistently applied. Wise Assets will aggregate transactions only where it is unlikely that the aggregation of orders and transactions will work to the overall disadvantage of any client whose order is to be aggregated.
Wise Assets will ensure that the Policy is effectively implemented, providing for the fair allocation of aggregated orders and transactions. When aggregating your order, Wise Assets may execute the order in part if it does not prove possible to execute the order in full.
When Wise Assets aggregates your order with an order for another client, or an own account order, and part or all of the aggregated order has been filled, it must promptly allocate the designated investments concerned in accordance with the Policy.
If the aggregated order is partially executed, Wise Assets shall allocate the related trades to you in priority to any other account orders. Aggregation may delay the execution of a transaction, and it may operate to your disadvantage in relation to a particular order.
3. Order Aggregation and Position Netting Process
As part of Wise Assets’ execution model, Wise Assets will be routinely aggregating all client buy orders and all client sell orders. The order to the Fund Manager will be submitted in Wise Assets’ name and will always be a matched position to the aggregate of all of the clients orders.
Wise Assets may apply ‘position netting’ to client buy and client sell orders in relation to the same fund. Position netting will pair opposing orders for administrative reasons, which could result in a net position; either an ‘open buy order’ or an ‘open sell order’. Position netting will always occur after the trade cut-off time. Wise Assets will always maintain separate internal records of each aggregated buy and sell order.
Open buy order: if on any given trading day Wise Assets receives more client buy orders than client sell orders (i.e. for the same fund), Wise Assets may only submit one buy order to the Fund Manager.
Open sell order: if on any given trading day Wise Assets receives more client sell orders than client buy orders (i.e. for the same fund), Wise Assets may only submit one sell order to the Fund Manager. Wise Assets’ position in relation to its clients and its position in relation to the UCITS fund would always remain matched.
Our clients are very unlikely to ever be disadvantaged by the aggregation or position netting of orders as there is a single cut off time and single daily price for the UCITS Fund in which Wise Assets will be buying or selling Units. Therefore all clients buying or selling orders on any given trading day would receive the same valuation for their investment regardless of which time an individual client put in a buy or sell order, and regardless if position netting occurred or not.
Wise Assets ensures that all orders received by clients before the fund cut off time are aggregated and netted in time for the open buy/sell order to be placed directly with the Fund Manager on the same day. This ensures that clients are in no way prejudiced by placing their orders through Wise Assets when compared to placing orders directly with the Fund Managers. We believe this to be in the clients best interests and results in the best execution of client orders.
4. Cancellation
Wise Assets reserve the right to cancel a transaction without notice where we believe there is sufficient justification. If, for operational, legal or regulatory reasons (or any other reason outside of our control), the order cannot be executed on a given trading day Wise Assets shall use its best endeavours to facilitate the execution of that order on the next trading day. Wise Assets will inform you about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.
5. Specific Client Instructions
Due to the nature of the services provided by Wise Assets, it is not possible for you to issue a specific execution instruction in relation to the purchase or sale of units in an available fund. An exception to this exists in relation to in-specie transfers where you may request Wise Assets to accept or transfer out your units in specie to another platform. If you choose to give such an instruction to the firm, then the firm will attempt to provide best execution as far as is possible.
6. Providing Information to Clients on Order Execution
Wise Assets is executing orders with fund managers directly. Thus, the execution venue is always known prior to order execution as indicated in the “Execution Venues” section of this Policy.
We are required to obtain consent from you in relation to this policy prior to executing any orders.
We are also required to obtain your prior express consent before we execute an order outside of a Regulated Market or Multilateral Trading Facility (MTF) in an instrument admitted to trading on a Regulated Market or MTF.