Execution reporting

As required under Article 65(6) of the Commission Delegated Regulation (EU) 2017/565 when placing a client order

There is no conflict of interest or common ownership between Martin Currie Investment Management (“MCIM”), or affiliates, and any of the execution venues used to execute orders on behalf of our clients.

Conflicts – do we need to declare we have holdings in any of the top 5 brokers? (we hold Macquarie Group Ltd Common stock – right one?) – spoken to Stewart and he suggests a bland statement about how as a discretionary manger in global equities we could have owned shares in any listed broker. Managed through our conflicts policy which is available on request.

MCIM has not made or received discounts, rebates or non-monetary benefits, from any execution venue

All MCIM clients are classified as professional clients

We have chosen to include all asset classes, all regions, with the exception of Spot FX. This includes non-EEA instruments.

Class of Instrument a) Equities – shares and depository receipts
Notification if <1 average trade per business day in the previous year N
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as a percentage of total in that class
UBS AG, London Branch 24.90% 28.36%
Bank of America Merrill Lynch International Limited 21.08% 15.20%
Morgan Stanley & Co International plc 10.36% 10.50%
Instinet Europe Limited 8.88% 13.17%
Macquarie Capital (Europe) Limited 7.06% 9.43%

To be added by trading an explanation of the relative importance given to the execution factors of price, cost, speed, likelihood of execution and any other consideration including qualitative factors when assessing the quality of execution.

See additional requirements – see RTS Article 3 (3 g), also Q10 of BE Q&A

Class of Instrument b) Debt Instruments
Notification if <1 average trade per business day in the previous year Y
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as a percentage of total in that class
Citigroup Global Markets Limited 100% 100%

To be added by trading an explanation of the relative importance given to the execution factors of price, cost, speed, likelihood of execution and any other consideration including qualitative factors when assessing the quality of execution.

Class of Instrument g) Equities derivatives
Notification if <1 average trade per business day in the previous year Y
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as a percentage of total in that class
UBS AG, London Limited 69.90% 87.95%
Goldman Sachs International 30.02% 9.64%
Morgan Stanley & Co International plc 0.07% 2.41%

To be added by trading an explanation of the relative importance given to the execution factors of price, cost, speed, likelihood of execution and any other consideration including qualitative factors when assessing the quality of execution.

Class of Instrument k) Exchange Trade Products
Notification if <1 average trade per business day in the previous year Y
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as a percentage of total in that class
UBS AG, London Branch 42.78% 22.43%
JP Morgan Europe Limited 20.28% 24.30%
Société Générale 16.59% 20.56%
Bank of America Merrill Lynch International Limited 8.34% 14.95%
Morgan Stanley & Co International plc 3.74% 3.74%

To be added by trading an explanation of the relative importance given to the execution factors of price, cost, speed, likelihood of execution and any other consideration including qualitative factors when assessing the quality of execution.

As required under Regulating Technical Standard (RTS) 28 when executing a client order:

Class of Instrument g) Equity Derivatives
Notification if <1 average trade per business day in the previous year Y
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as a percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
Deutsche Bank Aktiengesellschaft 46.11% 34.34% 0 0 0
UBS AG, London Branch 31.64% 38.38% 0 0 0
Goldman Sachs International 16.37% 19.19% 0 0 0
Morgan Stanley & Co International plc 5.89% 8.08% 0 0 0

To be added by trading an explanation of the relative importance given to the execution factors of price, cost, speed, likelihood of execution and any other consideration including qualitative factors when assessing the quality of execution.

Class of Instrument j) Contracts for Difference
Notification if <1 average trade per business day in the previous year N
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as a percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
UBS AG, London Branch 24.45% 43.53%
Bank of America Merrill Lynch International Limited 12.65% 8.74%
Nordea Bank AB 12.52% 7.66%
Redburn (Europe) Limited 10.48% 5.67%
Morgan Stanley & Co International Limited 8.71% 5.82%

To be added by trading an explanation of the relative importance given to the execution factors of price, cost, speed, likelihood of execution and any other consideration including qualitative factors when assessing the quality of execution.

FCA suggested that we should add that the above are our execution brokers for CFDs, but all positions are given-up and settled with the client’s Prime Broker.

Class of Instrument Securities Financing Transactions
Notification if <1 average trade per business day in the previous year N
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as a percentage of total in that class
UBS AG, London Branch 62.02% 69.38%
Deutsche Bank Aktiengesellschaft 28.31% 14.48%
Goldman Sachs International 9.62% 13.27%
Morgan Stanley & Co International plc 0.05% 2.87%