Best Execution and Order Handling Disclosure - Managed accounts
June 2026
Wealthsimple Investments Inc. (“WSII”) is a registered investment dealer and member of the Canadian Investment Regulatory Organization (“CIRO”). Under CIRO’s rules, WSII is required to have policies and procedures that are designed to achieve “best execution” for client orders and provide its clients with information on those policies and procedures.
This disclosure applies to our order handling practices for managed accounts, where WSII has investment discretion over which listed securities the managed account invests into. Managed accounts may invest in exchange-traded funds (“ETFs”) in Canada and the United States and certain mutual funds. This disclosure applies to our order handling practices for listed stocks and ETFs. WSII may review and amend this disclosure to reflect changes in our business practices or changes in our regulatory environment.
Best execution is defined as “obtaining the most advantageous execution terms reasonably available under the circumstances.” WSII will take all reasonable steps to achieve best execution for client orders, taking into consideration the ETF to be traded and the nature of the order and in accordance with applicable regulatory requirements and the rules of the applicable exchanges, alternative trading systems and market centers (collectively, “marketplaces”).
Some investment dealers are a Participating Organization, member, or subscriber of the available Canadian or U.S. marketplaces (referred to as “Executing Brokers”). WSII is not an Executing Broker. WSII routes client orders to unaffiliated Executing Brokers that we have assessed and entered into agreements with, which then execute the orders on WSII’s behalf.
Factors Considered for Achieving Best Execution
WSII considers several factors in its attempt to achieve best execution, including the:
Price;
Speed of execution;
Certainty of execution;
Overall cost of the transaction;
Prevailing market conditions, which includes the direction of the market, the depth of the posted market, the last sale price and prices and volumes of previous trades, the size of the spread and the liquidity of the ETF.
Accordingly, orders generated by WSII are subject to, at all times, prevailing market conditions.
Additional factors such as the managed account’s investment objective, investment strategy, portfolio construction, tax implications, subscription and redemption timing constraints of underlying investment funds and the timing of cash flows may also be relevant.
Order Handling and Routing
WSII utilizes vendor-provided order management systems and routes orders to its Executing Brokers for execution. Executing Brokers may use Smart Order Routers (“SORs”) to manage client orders routed to marketplaces or other trading venues. Orders for stocks listed in the United States may be routed by our U.S. Executing Brokers to a marketplace, trading venue or liquidity provider. Executing Brokers may act as principal in facilitating the execution of orders generated by WSII for managed accounts.
WSII and/or its Executing Brokers may pay marketplace fees or receive marketplace rebates when routing orders to certain Canadian marketplaces. The fee schedules of each marketplace are available on the respective websites.
WSII and/or its Executing Brokers may receive remuneration in the form of cash, rebates and/or credits against fees in return for routing client orders for U.S. ETFs to its U.S. Executing Brokers. However, WSII’s best execution obligation requires prioritization of and consideration for the factors listed above, outside of any remuneration WSII may receive.
Executing Brokers
Orders routed to WSII’s Executing Brokers are subject to the order handling and routing practices of that Executing Broker. WSII’s Canadian Executing Brokers are all registered investment dealers and members of CIRO, and like WSII, are required to have in place policies and procedures designed to achieve best execution. Our U.S. Executing Brokers are all registered broker-dealers and members of the Financial Industry Regulatory Authority. U.S. Executing Brokers may apply different criteria when assessing execution quality due to local rules and regulations but are similarly subject to best execution obligations.
WSII conducts recurring assessments of the execution quality provided by all of its Executing Brokers. In addition, at least annually, WSII reviews and obtains certifications from each of its Executing Brokers, attesting that the Executing Broker has complied with and tested its best execution policies and procedures in accordance with Part C of Rule 3100 of CIRO’s Investment Dealer and Partially Consolidated Rules.
Additional information on our Executing Brokers and/or their policies and procedures related to best execution are available upon request.
Foreign Organized Regulated Markets
Certain stocks and ETFs are “inter-listed”, which means they are listed on an exchange in both Canada and a foreign jurisdiction (usually the United States). In certain cases, when handling an order in an inter-listed stock or ETF, WSII’s Executing Broker may decide that all or part of the order could be transacted outside of Canada. In such cases, WSII’s Executing Brokers are required to consider the available liquidity domestically and in the foreign market, any pricing or foreign exchange considerations in the foreign market as well as any clearing or settlement issues before deciding to transact outside of Canada. Any resulting trade would be executed through the Executing Broker on a Foreign Organized Regulated Market. This ensures that trades conducted outside of Canada are conducted on a market that provides substantially the same standards as found in Canada for both regulatory monitoring and public data dissemination.
Pooled Orders
Certain orders generated for your managed account may be pooled together with other client orders to buy or sell the same security on the same day. Orders are pooled when it is likely that the orders may benefit from pooling and manual order handling given the aggregate order size.
Client Instructions
For managed accounts, Wealthsimple has the discretionary authority to determine what securities or funds an account should invest in, as well as how those orders should be invested. Wealthsimple does not accept client instructions for orders in managed accounts.
Conflicts of Interest Relating to Best Execution
WSII considers a conflict of interest to be any circumstance where the interests of different parties, such as the interests of a client and those of WSII, are inconsistent or divergent. WSII takes reasonable steps to identify all existing and potential material conflicts of interest, and those we would reasonably expect to arise with regards to fulfilling our best execution obligation.
In certain circumstances, client orders in discretionary managed accounts may be executed in securities of investment funds or other products that are managed by WSII or an affiliate of WSII. WSII recognizes that such transactions may give rise to potential conflicts of interest.
WSII’s best execution obligation applies equally to related-party transactions. For more information, please refer to our Conflicts of Interest Disclosure.