Terms of Use


Company information

This website is owned, managed and maintained by MMC Ventures Limited (‘MMC’) of 2 Kensington Square, London W8 5EP, a firm authorised and regulated by the Financial Conduct Authority (‘FCA’). Further details are available from the Financial Services Register at www.fsa.gov.uk/register.

Terms of use


Each user of this website agrees as follows:

  1. The content on this site – including trademarks, logos, photos, descriptions and other original material – should not be reproduced without our prior written consent. “MMC Ventures” is one of our registered trademarks. Other trademarks, such as those of our portfolio companies, are owned by their respective owners.
  2. Links to Other websites. This site may from time to time include links to other websites operated, or content provided, by third parties as a convenience.  For purposes of these Terms and Conditions, the term “link” includes both out links (hypertext links to external websites or content) and in links (hypertext links which draw material from other sources into this website). MMC has no control over any such other Web sites or their contents and will have no liability arising out of or related to such websites or their contents. The existence of any such links does not constitute an endorsement of such websites, the contents of the websites or the operators of the websites.
  3. Non-Confidentiality of Communications. If you send a message or information to this website, such as (but not limited to) a request for information, you hereby grant to MMC the right to read, use, distribute, disclose and otherwise handle the communication and any related information consistent with MMC’s Privacy Policy governing this website. For messages and information not covered by such Privacy Policy, you hereby grant to MMC the right to read, use, distribute, disclose and otherwise handle the communication and any related information as MMC deems appropriate in its sole judgment.


MMC and its directors have taken all reasonable care to ensure that all the facts stated on this website are true and accurate in all material respects and that there are no other material facts or opinions or information which have been omitted from them which would make any part of this website misleading. MMC will take reasonable care to ensure that the information provided on this website is accurate and up to date, although no respresentations or warranties are given of any kind, express or implied, with regard to the accuracy or completeness of this information.

MMC and its directors, employees and officers exclude all liability and responsibility in connection with the use of this website. Users of this website do so entirely at their own risk.

MMC may amend the content of this website or any part of it, or may periodically make it unavailable for updating, with or without notice, at any time, and are not liable to users of this website for any effect thereof.

The above limitations and exclusions shall not affect the duties or liabilities of MMC Ventures Limited under the Financial Services and Markets Act 2000, or purport to apply to liability for fraud, or for death or personal injury caused by negligence.

Order execution policy

This summary is aimed at professional and retail clients relating to when MMC Ventures Limited (“MMC”) executes orders on their behalf.   

The Conduct of Business sourcebook sets out a number of execution factors that MMC is required to take into account in respect of financial instruments where MMC receives and transmits client orders by arranging deals for its clients.  Throughout this summary, references to execution of orders should be interpreted as arranging deals for MMC’s clients.

The execution criteria are defined as the characteristics of the order which MMC will execute in relation to a financial instrument.  MMC will exercise its discretion in assessing the criteria that it needs to take into account to provide the client with the best possible outcome.  MMC will seek best execution by taking all reasonable steps. 

The execution factors are: –

  1. The price of the financial instrument;
  2. The speed and likelihood of execution;
  3. The overall costs;
  4. The location of assets relating to the execution;
  5. The location of the professional support;
  6. The settlement of the execution;
  7. The size of the execution;
  8. The prevailing market conditions
  9. Any other consideration relevant to the execution of the order.

Given the above list, in practice this means MMC will execute using the main variables as follows:


A key factor is price.  This is usually the most important factor in obtaining the best possible result for our customers.  The price paid or sold for an unquoted company takes into account a number of subjective investment variables which centre around the company’s business proposition.  At this initial stage of any transaction, a ‘deal price’ is agreed which is reflective of the term sheet agreed with all parties.  When the transaction has progressed to the final stages, an ‘execution price’ will be agreed which considers other factors e.g. currency exposure.  The difference between the two prices maybe slight and non-material but MMC will seek to achieve the best possible outcome for customers.

Probability and speed of execution

Transactions in unquoted private companies often involve multiple parties e.g. co-investors and therefore the probability and speed of execution to settlement can be subject to delays.  There may be other features of the final deal terms to be agreed e.g. deal fees not finalised.  MMC will seek to achieve the best possible outcome for customers.   

Other factors

External market conditions are a variable.  In some circumstances we may judge that the current market conditions are not compatible to the transaction or deal placed on the table.  MMC will determine the relative importance of the external market factors by using its commercial judgement and experience, and by taking into account the information available to them. 

On the rare occasion when MMC deals in market-traded financial instruments through brokers and market makers, we will rank price as being of primary importance and speed of settlement.  Other factors include any transaction or deal costs and any tax issues e.g. pre-clearance from HMRC that a company is an EIS qualifying company.

Specific instruction 

Where a client has provided us with specific instructions to deal on their behalf we will execute the order in accordance with those specific instructions.  However, we will not owe any duty to provide best execution because these instructions may prevent us from following the Order Execution Policy.  The Order Execution Policy is designed to obtain the best possible for our clients on a consistent basis taking into account the factors outlined above.

To be clear, MMC clients do not face or are subject to any individual transactional fees or costs.

Monitoring and review

MMC will monitor the effectiveness of the Order Execution Policy.  Based on regular reviews we identify any weaknesses which may lead to MMC clients not receiving best execution, we will correct any deficiencies

Order execution policy

MMC Ventures Limited (“MMC”) takes seriously its responsibilities as a regulated UK financial services company. One of these responsibilities involves identifying, avoiding, and managing any conflicts of interest that may occur in the course of business between us and our client or clients, between different clients and between any connected persons with MMC. MMC has put in place arrangements which ensures fair treatment for all parties concerned and ensures it does not adversely affect the interests of its clients.

How does MMC address conflicts?

MMC takes all reasonable steps to maintain and operate effective organisational and administrative arrangements to identify and manage relevant conflicts. Senior management within the organisation are responsible for ensuring that MMC’s systems, controls and procedures are adequate to identify and manage conflicts of interest. These include:
• Controls over the handling and flow of confidential and inside information
• An allocation policy to ensure that conflicts are managed across the Fund range
• Bespoke pricing models

How does MMC identify and manage conflicts?

MMC has in place business specific procedures that address the identification and management of actual and potential conflicts of interest that may arise during its day to day business. These procedures include: 
• Maintaining a restricted trading list and associated Personal Account dealing policy
• Information barriers and a clear separation of reporting lines
• Pricing models which identify conflicts or material interest at an early stage of any deal or transaction
• Accepting and receiving gifts and benefits which identify and manage potential conflicts
• Maintaining a separate oversight of remuneration arrangements

MMC address specific conflicts by: 
• Declining to act in certain circumstances where a conflict is apparent
• Applying unique procedures to ensure that the fair treatment of all parties is achieved
• Disclosing the conflict or material interests to the client at the beginning of any deal/transaction and getting their consent to proceed

If any arrangement made by MMC to manage conflicts of interest as shown above are not sufficient to ensure, with reasonable confidence, that risks to the interests of a client/customer will be prevented, then the business area must clearly disclose the general nature and/or sources of conflicts of interest to the client before undertaking business for the client.

The disclosure must be in writing and include sufficient detail to enable the client to take an informed decision.

Governance and review

MMC’s compliance with the Conflicts of Interest policy will be reviewed as part of MMCs compliance monitoring programme on at least an annual basis.



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