All model portfolios managed by Copia are held on investment platforms. On each of these investment platforms, Copia instructs changes to investment portfolios at the model portfolio level, and then relies on the platform portfolio trading capability to implement those changes.

Consequently, the trade execution of investments is under the control of the respective platforms, and so in each case Copia relies on the relevant Best Execution policy of each platform. Although Copia is not directly involved in executing the trades, it maintains sufficient oversight of the platforms’ execution arrangements to provide investing consumers with comfort that they are being provided with best execution of their investment orders.

As a matter of course, Copia monitors platform Best Execution annually, along with relevant errors and breaches, and how these are remediated. An annual due diligence questionnaire is sent to each platform for completion. This ensures no detrimental policies changes are implemented and any exceptions to these policies by way of error are identified and addressed.

Any lack of platform response to the due diligence questionnaire is escalated on a monthly basis.

Under Copia’s terms and conditions, platforms are further obliged to notify Copia of any material changes to their Order Execution policy, relevant errors or breaches affecting Copia clients in the interim. Failure to do so could also result in a potential breach of the contract, which would result in sanctions against the platform including but not limited to withdrawal of the Copia model portfolios.