BEST EXECUTION POLICY
1. INTRODUCTION AND POLICY STATEMENT
At Lambeth Capital Limited ("Lambeth" or "the Company"), we are committed to conducting our
business with the highest standards of integrity, transparency, professionalism and accountability.
We recognise that trust is essential to our relationships with clients, shareholders, regulators and other
stakeholders. Accordingly, we conduct our business in accordance with our corporate values, Code of
Conduct and Ethics, and all applicable laws, regulations, rules and professional standards.
This Best Execution Policy outlines the principles and procedures that guide how Lambeth handles and
executes client orders for the purchase and sale of securities.
The Policy is designed to comply with the applicable rules of the Nigerian Stock Exchange (NSE) on Order
Handling and Best Execution, as well as other relevant statutory and regulatory requirements.
Our objectives are to:
• Ensure that reasonable steps are taken to obtain the best possible execution results for our
clients when buying or selling securities.
• Execute client orders promptly and fairly, in accordance with the terms and conditions of each
client's mandate.
• Protect clients' interests throughout the order execution process.
• Maintain transparency, accountability and proper records of all executed transactions.
2. SCOPE AND APPLICATION
This Policy applies to all client mandates received and handled by Lambeth Capital Limited in connection
with the purchase or sale of securities.
It governs how client orders are received, processed, executed, recorded and monitored to ensure that
clients receive fair and appropriate execution services.
3. OUR BEST EXECUTION COMMITMENT
Lambeth Capital Limited is committed to taking reasonable steps to achieve the best possible results
when executing transactions on behalf of clients.
In carrying out client mandates, we will:
• Act in the best interests of our clients when purchasing or selling securities.
• Execute orders within a reasonable timeframe, subject to market conditions and the specific
instructions contained in the client's mandate.
• Consider the individual circumstances and requirements of each client when handling their
orders.
• Apply this Policy consistently to all applicable client mandates.
3.1 Factors Considered in Order Execution
When executing client orders, Lambeth considers several factors to determine the most appropriate
execution approach. These include:
Price: The price at which the securities can be bought or sold, with the objective of obtaining the most
favourable available price.
Transaction Costs: Any costs, charges or expenses associated with executing the transaction.
Speed of Execution: The time required to execute the order, taking into account prevailing market
conditions.
Likelihood of Execution and Settlement: The possibility that the order will be successfully executed and
that the transaction will be settled accordingly. Order Size: The volume or quantity of securities involved in the transaction.
Nature of the Order: The specific characteristics, instructions and requirements attached to the client's
mandate.
Price Improvement: Opportunities to obtain a more favorable execution price than initially available or
expected.
Market Impact: The potential effect of executing an order on the prevailing market price of the security.
Other relevant factors may also be considered where they affect the proper execution of a client's
mandate.
The importance attached to each factor may vary depending on the circumstances of the transaction,
the client's instructions and prevailing market conditions.
4. CLIENT ORDER HANDLING
Lambeth Capital Limited is committed to ensuring that all client orders are handled fairly, accurately and
promptly.
To achieve this, we maintain processes and procedures designed to:
• Ensure the prompt, fair and timely execution of client mandates.
• Accurately record all client orders and transactions.
• Ensure that executed orders are properly allocated to the relevant clients.
• Maintain appropriate records of transactions and order execution activities.
4.1 Treatment of Client Orders
To protect the interests of our clients and promote fairness in the execution process:
• Client mandates will be handled individually and in accordance with the specific instructions
received.
• Lambeth will not aggregate one client's mandate with another client's mandate.
• Client mandates will not be combined with transactions undertaken for the Company's
proprietary account.
• Information relating to pending client orders will be treated appropriately and will not be
misused.
• Reasonable measures will be taken to prevent the unauthorised use or misuse of information
relating to pending client transactions.
5. CLIENT NOTIFICATION AND COMMUNICATION
Lambeth Capital Limited is committed to maintaining open and transparent communication with its
clients regarding this Policy and its application.
Accordingly, the Company will:
• Make this Best Execution Policy publicly available on its official website.
• Notify clients of relevant regulatory provisions under this Policy and any material changes that
may affect their transactions.
• Promptly inform affected clients of any material difficulties encountered that may prevent or
affect the proper execution of their mandates, once such difficulties become known.
Clients are encouraged to familiarise themselves with this Policy and contact the Company if they
require further clarification.
6. ORDER MONITORING AND AUDIT TRAIL
Lambeth Capital Limited maintains systems and procedures for tracking and monitoring client orders
and their execution.
Appropriate transaction records and supporting evidence will be maintained to provide an audit trail of
order handling and execution activities.
These records support transparency, accountability, internal monitoring and regulatory compliance.
7. POLICY MONITORING AND REVIEW
Lambeth Capital Limited regularly monitors the effectiveness of its order execution arrangements and
the implementation of this Policy.
The Company will periodically assess its procedures to identify any weaknesses, operational challenges
or areas requiring improvement.
Where deficiencies are identified, appropriate corrective measures will be taken to strengthen the
Company's order execution arrangements and ensure continued compliance with applicable regulatory
requirements.
This Policy is subject to an annual review and may be updated when necessary to reflect changes in
applicable laws, regulations, market practices or the Company's operational requirements.
8. CONTACT INFORMATION
For enquiries, clarification or further information regarding this Best Execution Policy, please contact:
Department: Compliance Department
Contact Person: Head of Compliance
Email: info@lambethcapital.com.ng
9. POLICY APPROVAL
This Best Execution Policy has been approved by the Board of Directors of Lambeth Capital Limited.
Approved By: Board of Directors, Lambeth Capital Limited
Approval Date: August 2026
Review Frequency: Annually LAMBETH CAPITAL LIMITED Committed to integrity, transparency, accountability and the protection of our clients' interests.