RTS 28

Requirement

Article 3(3): Investment firms shall publish for each class of financial instruments, a summary of the analysis and conclusions they draw from their detailed monitoring of the quality of execution obtained on the execution venues where they executed all client orders in the previous year. The information shall include:

(a) an explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution;

The relative importance of each of these factors within our dealing process will vary
depending upon a number of criteria, namely:-

1. the investment intent of the investment manager who created the order at the Firm;
2. the characteristics of the execution venues to which that order can be directed
3. The asset class

Each order is unique in its characteristics and market conditions are never constant.
The relative importance of the execution factors is therefore variable. That said, the particular combination of total consideration (price of the instrument and costs of execution, both implicit and explicit) and size are usually the most considered factors when setting our execution strategy. Where an instrument is less liquid, then likelihood of execution becomes a more important consideration.

(b) a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders;

The Firm does not trade with any affiliates.

(c) a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received;

The Firm does not receive payments, discounts, rebates or non-monetary benefits in its trading arrangements.

(d) an explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurred;

Brokerage firms remain on our list of execution venues subject to an authorisation and ongoing monitoring process, which includes, but is not limited to, a review of the performance of execution services provided by the broker, and the broker’s ability to trade effectively on our clients’ behalf.

(e) an explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements;

All clients are treated the same.

(f) an explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client;

This is not applicable, as the Firm does not trade retail client orders.

(g) an explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS 27];

We have carried out a transaction cost analysis to help us understand the quality of execution on the execution venues where we execute/place orders.

(h) where applicable, an explanation of how the investment firm has used output of a consolidated tape provider

This is not applicable