RTS 28 Reporting 2018

Equities – Shares & Depositary Receipts – Tick Size Liquidity Band 1-2

Class of
Instrument
Notification if <1 average trade per business day in the previous year Top five execution broker 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 percentage of total in that class
Percentage
of passive orders
Percentage of aggressive orders
Equities – Shares & Depositary Receipts N Cowen Execution Services 99.19 98.59 41.62 58.38
Equities – Shares & Depositary Receipts Y Canaccord 0.70 1.11 0 100
Equities – Shares & Depositary Receipts Y Castle Harbour Securities Ltd,
Bermuda
0.05 0.27 28.57 71.43
Equities – Shares & Depositary Receipts Y Banca Finnat 0.06 0.04 0 100

Equities – Shares & Depositary Receipts – Tick Size Liquidity Band 3-4

Class of
Instrument
Notification if <1 average trade per business day in the previous year Top five execution broker 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 percentage of total in that class
Percentage
of passive orders
Percentage of aggressive orders
Equities – Shares & Depositary Receipts N Cowen Execution Services 95.75 99.58 52.44 47.56
Equities – Shares & Depositary Receipts Y Canaccord 4.20 0.28 0 100
Equities – Shares & Depositary Receipts Y Castle Harbour Securities Ltd,
Bermuda
0.05 0.14 100 0

Equities – Shares & Depositary Receipts – Tick Size Liquidity Band 5-6

Class of
Instrument
Notification if <1 average trade per business day in the previous year Top five execution broker 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 percentage of total in that class
Percentage
of passive orders
Percentage of aggressive orders
Equities – Shares & Depositary Receipts N Cowen Execution Services 99.89 99.18 32.34 67.66
Equities – Shares & Depositary Receipts Y Canaccord 0.11 0.82 0 100

Debt instruments (Fixed Income)

Class of
Instrument
Notification if <1 average trade per business day in the previous year Top five execution broker 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 percentage of total in that class
Percentage
of passive orders
Percentage of aggressive orders
Debt instruments (Fixed Income) Y Oppenheimer & Co 74.63 62.98 100 0
Debt instruments (Fixed Income) Y Castle Harbour Securities Ltd, Bermuda 10.32 17.31 100 0
Debt instruments (Fixed Income) Y Leonteq Securities 5.50 6.73 100 0
Debt instruments (Fixed Income) Y Exane 2.83 5.77 100 0
Debt instruments (Fixed Income) Y Natixis 0.47 1.44 100 0

Exchange Traded Funds/Notes/Commodities

Class of
Instrument
Notification if <1 average trade per business day in the previous year Top five execution broker 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 percentage of total in that class
Percentage
of passive orders
Percentage of aggressive orders
Exchange Traded Funds / Notes / Commodities N Cowen Execution Services 99.91 99.85 60.78 39.07
Exchange Traded Funds / Notes / Commodities Y Canaccord 0.09 0.00 100 0

Warrants & Certificates

Class of
Instrument
Notification if <1 average trade per business day in the previous year Top five execution broker 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 percentage of total in that class
Percentage
of passive orders
Percentage of aggressive orders
Warrants & Certificates Y Cowen Execution Services 17.47 66.67 N/A N/A
Warrants & Certificates Y Commerzbank 32.89 6.25 N/A N/A
Warrants & Certificates Y Oppenheimer & Co 30.04 2.08 N/A N/A
Warrants & Certificates Y Castle Harbour Seucrities Ltd, Bermuda 8.28 14.58 N/A N/A
Warrants & Certificates Y Union Bancaire Privee 2.38 4.17 N/A N/A

(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;

Where CHS LLP determined that we owed a duty of Best Execution in relation to a transaction we, in accordance with our Best Execution Policy, took all reasonable steps to obtain the best possible result for the client in relation to that transaction.

In the absence of any specific instructions from the client, we took into account, if relevant, the following factors when executing a transaction on the client’s behalf:
• Price (excluding external costs and CHS LLP’ fees and charges );
• Any ‘External Costs’ relevant to the execution (i.e. any external costs charged by third parties which are
related to the execution of the transaction and which are directly passed on to the client, such as, execution
venue fees, clearing and settlement fees and any other fees paid to third parties);
• Speed of execution;
• Likelihood of execution and settlement;
• Size and nature of the order;
• Likely market impact;
• Nature of the market for the financial instrument; and
• Any other consideration deemed relevant to the execution of the transaction.

The applicability of, and importance attached to, each Execution Factor varies according to the type of transaction that was executed and the instructions that the client gave us. In determining the relative importance of these factors, we used reasonable judgment together with our understanding of the appropriate execution criteria for the specific transaction. For example, when transacting a large order, minimising market impact might be more important than price or, when trading an illiquid product, certainty of execution might be more important than price.

In determining the level of importance that we attached to the Execution Factors, we took into account any specific instructions that the client gave us and the following criteria:
• The characteristics of the transaction that the client submitted to us including any specific instructions that they gave us.
• Relevant financial instrument (the instrument or instruments that the client has asked us to deal in).
• Execution Venues (the options available to us to execute the order).

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

No close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders.

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

Outside of standard business relations which are in accordance with the disclosed public fee schedules provided by execution venues, no specific arrangements have been made with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.

(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;

The execution venues we access are subject to regular review.

(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;

Not applicable (no retail)

(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 Commission Delegated Regulation (EU) …/…to be inserted before publication [RTS 27];

We monitor the effectiveness of our Best Execution Policy and its implementation in order to identify and correct any deficiencies. We have a governance framework in place which is responsible for reviewing the business on an on-going basis to ensure that that our Best Execution obligations are complied with. We undertake a review of our Best Execution Policy at least annually and notify Clients of any material changes.

(h) where applicable, an explanation of how the investment firm has used output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU.

Not applicable