1. Best execution obligation
When executing orders on behalf of clients, Luminar Invest Capital takes all sufficient steps to obtain the best possible result, considering price, costs, speed, likelihood of execution and settlement, size and any other consideration relevant to the order.
2. Execution factors and weighting
- Price and total cost — primary factor for liquid instruments
- Likelihood of execution and settlement — primary for illiquid blocks
- Speed — material for volatile digital assets
- Size and nature — material for large block trades
3. Execution venues
- Precious metals: LBMA-cleared OTC dealers, LME, Comex
- Global equities: regulated markets (NYSE, Nasdaq, Euronext, LSE, SIX, HKEX) via tier-1 prime brokers
- Digital assets: regulated CeFi venues (Binance, Coinbase Prime, Kraken, OKX) and qualified custodians
4. Venue selection criteria
Venues are selected on liquidity, average spread, settlement reliability, fee schedule, operational resilience and regulatory standing. The list is reviewed at least annually.
5. Aggregation and allocation
Orders may be aggregated across client portfolios when this is unlikely to disadvantage any individual client. Allocation follows a documented pro-rata rule based on target weights.
6. Monitoring
The Execution Committee reviews realised execution quality quarterly using independent transaction cost analysis (TCA). Material deviations trigger venue review.
7. Client consent
By entering into a discretionary management agreement, the client consents to this policy and to execution outside a regulated market or multilateral trading facility where appropriate.