Synergy Markets · Client document
Order Handling and Best Execution Policy
Version 1.1 · September 2026 · Reviewed at least annually
1 · What this policy covers
Synergy Markets Ltd (FRN 623190) advises on investments and arranges deals. Synergy does not execute transactions itself and does not hold client money or assets. When you ask us to buy or sell, or when we implement advice you have accepted, we place your order with a firm that executes it. This policy explains how we do that and how we act in your best interests when we do. It applies to every order we place for a retail client, whether the order follows our advice or is your own instruction (an execution-only transaction).
2 · Where your orders are executed
At present we place orders with Transact (Integrated Financial Arrangements Ltd, FRN 190856), the platform on which your investments are held. Transact executes orders under its own Order Execution Policy, which forms part of its Wrap Service Terms and Conditions and is available on Transact Online. We have selected Transact because it holds your investments, executes and settles trades in the funds and exchange-traded investments we advise on, deals at published dealing points, and reports every transaction to you on a contract note. We do not use any other execution venue or broker for client orders unless and until it is named in a later version of this policy.
3 · How we act in your best interests when placing an order
We take all sufficient steps to obtain the best possible result for you by placing orders with an entity whose execution arrangements let us do so, and by monitoring that they continue to. For a retail client the best possible result is judged on total consideration — the price of the investment and the costs of executing — before speed, likelihood of execution and settlement, size, and the nature of the order, unless your instructions or the circumstances make another factor more important.
4 · How orders are placed
Orders are placed through Transact Online by your Synergy investment adviser, on your instruction or to implement advice you have accepted. Transact places them with the relevant fund manager or broker that day and they receive the price at the next available valuation point; where an exchange-traded investment is to be dealt immediately, Transact’s Express Trade facility can be instructed at an additional charge. We do not promise any execution time. Transact’s dealing cut-off times, charges and any express-dealing charge are set out in its Charges Schedule, which we give you with your illustration.
5 · Specific instructions
If you give us a specific instruction about how or where an order is to be executed, we follow it. Following a specific instruction may prevent us from obtaining the best possible result in respect of the aspects the instruction covers.
6 · Execution-only orders
Where you instruct us to buy or sell without asking for our view, we place the order on the same basis as any other and record it as your own decision. We make no recommendation and do not assess whether the transaction is right for you, and you have been told in your client agreement that the rules on assessing appropriateness do not apply to such orders in investments that are non-complex under the FCA’s rules.
7 · Managed Portfolios
Where you hold a managed portfolio, day-to-day investment decisions and rebalancing of the model portfolio are BlackRock’s, and the resulting trades are executed and settled by Transact under Transact’s policy. Our own orders in relation to a managed portfolio are limited to instructing Transact to invest your money into the recommended model at the outset, to link your account to it, and to invest money you later add. This policy applies to those instructions.
8 · Charges, and no inducements
You pay Transact’s dealing and platform charges as set out in its Charges Schedule and in your illustration. Synergy receives no payment, commission or other benefit from any executing firm for placing orders with it, and no such benefit influences where an order is placed.
9 · Monitoring and review
We review the execution quality we obtain, including by reference to contract notes and Transact’s costs and charges reporting, and we review this policy at least once a year and whenever a change affects our ability to obtain the best possible result. We will tell you of any material change to this policy.
10 · Your consent and how to obtain this policy
By accepting our client agreement you consent to this policy. It is provided with the client documents and is available at all times on our website. If you would like a copy, ask your Synergy investment adviser.
11 · Records
We keep a record of every order we place, including what was instructed, when, by whom and on what basis, and whether it followed our advice or your own instruction, and we can demonstrate to you or to the Financial Conduct Authority on request that an order was placed in accordance with this policy.
Synergy Markets Ltd is authorised and regulated by the Financial Conduct Authority (FRN 623190). Registered in England and Wales, company 08843450.