Mifid RTS 28 Disclosure

Order execution- RTS 28

Investment firms are required to publish, on an annual basis, information on the identity of execution venues and the quality of execution obtained. Regulatory Technical Standard (RTS) 28 outlines the requirements designed to increase transparency related to executing client orders on trading venues, including systematic internalisers intended to improve investor protection. The RTS 28 Spring (UK) disclosures are presented below:

Qualitative analysis:

Requirement under Article3(3) Analysis
An explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or other considerations including qualitative factors when assessing quality of execution The importance of the various execution factors stipulated by the Rules will depend on the circumstances and context of the order. The factors most commonly regarded as key are price, size and the liquidity of the security concerned. Business is therefore allocated to brokers on their ability execute transactions at competitive prices and in acceptable volumes.   Where the security is illiquid, the market impact can outweigh the direct cost of trading and so the execution venue selected in such circumstances is by reference to where sufficient liquidity may best be accessed.
Description of any specific close links, conflicts of interests and common ownership with respect to venues used Spring does not have any close links or conflicts of interest or common ownership with any venues used.
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 have any arrangements with any venue regarding payments made or received, discounts or rebates.
An explanation of the factors that led to a change in the list of execution venues listed in the execution policy (if applicable) Not applicable. All brokerage firms used by the Firm are subject to ongoing assessment and monitoring.
An explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how those other criteria were instrumental in delivering the best possible result in terms of total consideration to the client Not applicable. The firm does not act for retail clients
An explanation of how the investment firm has used any tools relating to the quality of execution, including any data published under Regulation 2017/575 (RTS 27)

During the period the firm has regularly monitored the quality of execution obtained from the different venues used to place client orders for execution.

We are satisfied that we have adhered to the requirements of our execution policy in seeking to obtain best execution for clients by reference to all relevant factors.

Each trade is monitored when initiating the order instruction to ensure that it is executed on the best terms available. We keep under review prices and quality of execution offered by all different venues to ensure we continue to provide the best possible results for clients.

Where applicable an explanation of how the investment firm has used output of a consolidated tape provider. Not applicable.

Quantitative analysis

CLASS OF INSTRUMENT: Equities, Shares and depositary Receipts

Notification if < 1average trade per business day in the previous year (Y/N): N

Top 5 execution venues ranked in terms of trading volumes (descending order)

 

Proportion of volume traded as a % of total in that class

Proportion of orders executed as a % of total in that class

Percentage of passive orders

Percentage of aggressive orders

Percentage of directed orders

Citibank

(LEI: XKZZ2JZF41MRHTR1V493)

33

40

0%

0%

0%

Morgan Stanley

(LEI: 4PQUHN3JPFGFNF3BB653)

22

30

0%

0%

0%

Sberbank

(LEI: F68F5WN6OGTEHIP5ZT82)

21

20

0%

0%

0%

VTB

(LEI 74OG4PIVJ3TT4O5NSN12)

11

4

0%

0%

0%

Aton

(LEI 213800PZWYFKIOAGQY35)

 

5

1

0%

0%

0%