Order Handling Policy
1. Purpose
This policy defines Rest Capital Ltd's approach to handling customer orders fairly and in the best interests of customers. It sets out the firm's obligations when transmitting orders for execution, the delegation of execution responsibilities to WealthKernel Ltd, and the arrangements for monitoring execution quality.
As an Appointed Representative of RiskSave Technologies Ltd ("RiskSave") operating under RiskSave's FCA permissions pursuant to Section 39 of FSMA, Rest Capital is subject to order handling requirements through RiskSave's regulatory obligations and the AR agreement.
This policy meets requirements under:
- FCA COBS 11.1 (Best execution — obligation to act in the client's best interest)
- FCA COBS 11.3 (Client order handling)
- FCA Principle 6 (Customers' interests — treating customers fairly)
- FCA PRIN 2A (Consumer Duty)
2. Scope
This policy applies to:
- All customer orders to subscribe to (invest in) or redeem from (withdraw from) money market fund units through the Rest platform
- All staff involved in the processing, transmission, or monitoring of customer orders
- The Rest Vault product and any future products involving the arrangement of investments
3. Context and Proportionality
3.1 Rest Capital's role in the order handling chain is as follows:
(a) The customer initiates an order through the Rest platform (subscription or redemption of money market fund units).
(b) Rest transmits the order to WealthKernel Ltd for execution.
(c) WealthKernel executes the order and arranges settlement and custody.
(d) The underlying money market fund (currently BlackRock) processes the subscription or redemption at the fund's next dealing point.
3.2 Rest Capital does not:
(a) Execute orders directly — all execution is performed by WealthKernel.
(b) Exercise discretion over order routing, timing, or execution venue — orders are transmitted to WealthKernel for execution at the fund's dealing point.
(c) Aggregate customer orders for execution as a block.
(d) Provide investment advice.
3.3 Given this model, Rest Capital's primary obligation is to act in the best interests of customers when transmitting orders and to maintain appropriate oversight of WealthKernel's execution arrangements. This policy is proportionate to the firm's role as an arranger rather than an executor.
4. Definitions
(a) Best Execution — The obligation to take all sufficient steps to obtain the best possible result for the customer when executing or transmitting orders, taking into account price, costs, speed, likelihood of execution and settlement, size, nature, and any other consideration relevant to the execution of the order.
(b) Order — A customer instruction to subscribe to or redeem from money market fund units through the Rest platform.
(c) Transmission — The process by which Rest Capital passes a customer order to WealthKernel for execution.
(d) Execution Venue — The venue at which an order is executed. For Rest's products, this is the money market fund itself (subscriptions and redemptions processed at the fund's dealing point via WealthKernel).
5. Obligations When Transmitting Orders
5.1 When transmitting customer orders to WealthKernel, Rest Capital shall:
(a) Act honestly, fairly, and professionally in the best interests of the customer.
(b) Transmit orders promptly and accurately, without undue delay.
(c) Ensure that order details (customer identity, instrument, amount, direction) are transmitted completely and correctly.
(d) Not give unfair priority to any customer order over another — orders shall be transmitted in the sequence in which they are received, unless a different sequence would be in the overall best interests of customers.
(e) Not misuse information relating to pending customer orders.
6. Delegation of Best Execution to WealthKernel
6.1 Rest Capital delegates execution of customer orders to WealthKernel Ltd, an FCA-authorised firm providing regulated investment and custody services.
6.2 WealthKernel is responsible for:
(a) Executing customer orders at the money market fund's dealing point.
(b) Achieving best execution in accordance with its own best execution policy and FCA COBS 11.
(c) Arranging settlement and custody of money market fund units.
6.3 The delegation of execution does not relieve Rest Capital of responsibility for the overall customer outcome. Rest retains the obligation to:
(a) Satisfy itself that WealthKernel's execution arrangements are adequate and likely to deliver good outcomes for customers.
(b) Monitor WealthKernel's execution quality on an ongoing basis.
(c) Take action if WealthKernel's execution arrangements are found to be inadequate.
7. Monitoring Execution Quality
7.1 Rest Capital shall monitor WealthKernel's execution quality on an ongoing basis, including:
(a) Settlement timeliness — Whether subscriptions and redemptions are settled within the expected timeframes (typically same-day or next-day for CNAV QMMFs).
(b) Execution accuracy — Whether orders are executed at the correct NAV and for the correct number of units.
(c) Service availability — Whether WealthKernel's systems are available and processing orders without undue interruption.
(d) Error rates — The frequency and nature of any order processing errors, failed trades, or misallocations.
(e) Customer complaints — Any complaints relating to order execution, settlement delays, or pricing discrepancies.
7.2 Monitoring will be conducted through:
(a) Review of operational and transactional information received from WealthKernel.
(b) Internal reconciliation of orders transmitted against orders executed.
(c) Complaints trend analysis.
(d) Periodic assessment as part of the vendor risk management process (RC-ISMS-POL-006).
7.3 If monitoring identifies material concerns about WealthKernel's execution quality, the CEO shall:
(a) Raise the concern with WealthKernel and request remediation.
(b) Assess whether the concern constitutes a risk to customer outcomes requiring escalation to RiskSave (STOB clause 3.4).
(c) Consider whether temporary or permanent changes to execution arrangements are required.
8. Order Aggregation
8.1 Rest Capital does not aggregate customer orders for execution as a block. Each customer order is transmitted individually to WealthKernel.
8.2 If aggregation is introduced in the future, this policy will be updated to include the firm's aggregation and allocation policy, ensuring that aggregation does not disadvantage any individual customer.
9. Information to Customers
9.1 Customers are informed, before first dealing, that:
(a) Rest Capital transmits orders to WealthKernel for execution.
(b) WealthKernel is responsible for execution and custody.
(c) Orders are executed at the money market fund's dealing point — typically daily.
(d) Details of applicable costs and charges are provided in accordance with the Client Disclosure & Customer Classification Policy (RC-COND-POL-004).
9.2 Customers may request additional information about the firm's order handling arrangements. Such requests shall be dealt with promptly.
10. Roles and Responsibilities
10.1 CEO
(a) Accountable for the firm's order handling arrangements and oversight of WealthKernel's execution quality.
(b) Approves this policy.
(c) Takes action where monitoring identifies concerns about execution quality.
(d) Ensures material concerns are reported to RiskSave (STOB clause 3.4).
10.2 CTO and Engineering Team
(a) Ensure the technical infrastructure supporting order transmission is reliable, accurate, and auditable.
(b) Implement and maintain logging of all orders transmitted to WealthKernel.
(c) Escalate any technical issues affecting order transmission to the CEO.
10.3 All Staff
(a) Transmit orders promptly and accurately.
(b) Do not misuse information relating to pending customer orders.
(c) Report any concerns about order handling or execution quality to the CEO.
10.4 RiskSave Compliance
(a) Oversight of Rest Capital's order handling arrangements.
(b) Support with assessment of WealthKernel's execution quality where required.
11. Record Keeping
(a) Records of all customer orders (including order details, time of receipt, time of transmission, and execution confirmation) shall be retained for a minimum of six years, consistent with RiskSave's record retention obligations (STOB clause 12.3).
(b) Records of execution quality monitoring, including any concerns raised and actions taken, shall be retained for the same period.
(c) Records shall be stored securely and classified in accordance with the Data Classification Policy (RC-ISMS-POL-004).
12. Policy Review
(a) This policy shall be reviewed annually, or sooner if triggered by: a material change to execution arrangements, a material complaint relating to order handling, regulatory changes, or at the request of RiskSave.
(b) The CEO is responsible for approving any amendments to this policy.
Document Control
| Version | Date | Author | Changes |
|---|---|---|---|
| 1.0 | 6 March 2026 | Joe Kemsley | Initial version |
Approval
| Role | Name | Signature | Date |
|---|---|---|---|
| CEO | Joe Kemsley |
Appendix A: Regulatory Mapping
| Requirement | Source | Section |
|---|---|---|
| Best execution — client's best interest | FCA COBS 11.1 | 5, 6 |
| Client order handling | FCA COBS 11.3 | 5 |
| Treating customers fairly | FCA Principle 6 | 5 |
| Consumer Duty | FCA PRIN 2A | 5, 7 |
| AR oversight | FCA SUP 12 | 10.4 |
Appendix B: Order Flow Diagram
| Step | Actor | Action |
|---|---|---|
| 1 | Customer | Initiates order via Rest platform |
| 2 | Rest Capital | Validates and transmits order to WealthKernel |
| 3 | WealthKernel | Executes order at fund dealing point |
| 4 | BlackRock (fund) | Processes subscription/redemption |
| 5 | WealthKernel | Confirms execution and settlement to Rest |
| 6 | Rest Capital | Updates customer account and provides confirmation |
Appendix C: Related Documents
- RC-ISMS-POL-006: Vendor Risk Management Policy (WealthKernel oversight)
- RC-COND-POL-004: Client Disclosure & Customer Classification Policy
- RC-COND-POL-001: Consumer Duty & Vulnerable Customers Policy