RTS 28 Tables

MiFID Org Regulation Article 65(6)

Montpelier, being the portfolio manager, trades on specific instructions to an order, that instruction is understood to mean that the counterparties will execute the order in a fashion that is either passive or aggressive as shown in the tables below.

2018

Equities: 2018

         
Notification if<1 average trade per business day in the previous year Yes        
Top five counterparties 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
Tavira, LEI: 213800KDMRJLS2KX8Z18 16.02% 9.09% 7.69% 92.31% 0%
Barclays Capital, LEI: K9WDOH4D2PYBSLSOB484 15.51% 25.87% 56.76% 43.24% 0%
BMO Capital Markets, LEI: L64HM9LHPDOS1B9HJC68 14.08% 12.59% 50.00% 50.00% 0%
Goldman Sachs, LEI: W22LROWP2IHZNBB6K528 13.93% 18.18% 23.08% 76.92% 0%
Topline, LEI: 2549000HYYAUPFRFTQ09 12.50% 1.40% 100.00% 0.00% 0%

 

Debt Instruments: 2018

         
Notification if<1 average trade per business day in the previous year Yes        
Top five counterparties 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

No Debt Instruments Traded

 

Exchange Traded Products: 2018

Notification if<1 average trade per business day in the previous year Yes        
Top five counterparties 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
BMO Capital Markets, LEI: L64HM9LHPDOS1B9HJC68 56.50% 20.93% 66.67% 33.33% 0%
Goldman Sachs, LEI: W22LROWP2IHZNBB6K528 21.67% 32.56% 78.57% 21.43% 0%
RBC Capital Markets, LEI: TXDSU46SXBWIGJ8G8E98 11.51% 16.28% 85.71% 14.29% 0%
Tavira, LEI: 213800KDMRJLS2KX8Z18 6.45% 23.26% 100.00% 0.00% 0%
Barclays Capital, LEI: K9WDOH4D2PYBSLSOB484 3.88% 6.98% 66.67% 33.33% 0%

 

Currency Derivitives: 2018

         
Notification if<1 average trade per business day in the previous year Yes        
Top five counterparties 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
The Northern Trust Co, LEI: 6PTKHDJ8HDUF78PFWH30 100% 100% 0% 100% 0%

2017

Equities: 2017

         
Notification if<1 average trade per business day in the previous year Yes        
Top five counterparties 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
Tavira, LEI: 213800KDMRJLS2KX8Z18 44.21% 18.39% 43.75% 56.25% 0%
Clarkson Platou, LEI: 549300ED05S7MWQ8U215 16.50% 17.24% 46.67% 53.33% 0%
Goldman Sachs, LEI: W22LROWP2IHZNBB6K528 15.24% 29.31% 60.78% 39.22% 0%
Liberum Capital, LEI: 213800U6KUF87S1KCC03 7.10% 6.90% 83.33% 16.67% 0%
RBC Capital Markets, LEI: TXDSU46SXBWIGJ8G8E98 3.83% 5.17% 33.33% 66.67% 0%

Debt Instruments: 2017

         
Notification if<1 average trade per business day in the previous year Yes        
Top five counterparties 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
Morgan Stanley, LEI: 4PQUHN3JPFGFNF3BB653 95.54% 93.33% 28.57% 71.43% 0%
Goldman Sachs, LEI: W22LROWP2IHZNBB6K528 4.46% 6.67% 100% 0.00% 0%

Exchange Traded Products: 2017

Notification if<1 average trade per business day in the previous year Yes        
Top five counterparties 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
BMO Capital Markets, LEI: L64HM9LHPDOS1B9HJC68 52.28% 33.33% 27.27% 72.73% 0%
Goldman Sachs, LEI: W22LROWP2IHZNBB6K528 18.55% 24.24% 50% 50% 0%
RBC Capital Markets, LEI: TXDSU46SXBWIGJ8G8E98 8.67% 12.12% 50% 50% 0%
Renaissance Capital, LEI: 213800RZ3GCUXMBGYN59 7.52% 9.09% 33.33% 66.67% 0%
Barclays Capital, LEI: K9WDOH4D2PYBSLSOB484 5.53% 9.09% 100% 0% 0%

Currency Derivitives: 2017

         
Notification if<1 average trade per business day in the previous year Yes        
Top five counterparties 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
The Northern Trust Co, LEI: 6PTKHDJ8HDUF78PFWH30 100% 100% 0% 100% 0%

Best execution involves the Firm taking all sufficient steps to obtain the best possible result for its clients' transaction(s). Where an order is placed with a broker, then it will be caught within the MiFID Org Regulation Article 65(6), This result can be measured by a number of execution factors (the 'Execution Factors'), comprising of price, costs and clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. The following Execution Factors are taken into account: Price; Costs; Speed; Likelihood of execution; Settlement; Order size; Nature; and any other relevant consideration.

The Firm does not need to obtain the best possible results for its clients on every single occasion; rather it will verify on an ongoing basis that the execution arrangements it has established work well throughout the different stages of the order execution process. The Firm will take all appropriate remedial actions if any deficiencies are detected to achieve the best possible results for its clients on an ongoing basis.

In the majority of cases, the Firm would typically expect that the primary and most significant issue to be taken into account will be the total consideration to be paid or received. However, there will be occasions when other factors (liquidity, access to market) may be more important or relevant and, as discretionary managers, the Firm may use its judgement and experience to give greater prominence to other Execution Factors other than price.

The Firm has prepared a Conflicts of Interest Policy, which identifies the types of conflicts it faces. It also assesses close links and common ownerships. These policies and procedures identify and mitigate potential conflicts. The Firm and its staff does not have close links, common ownerships and conflicts of interest with the counterparties that it uses.

From 1 January 2018, the Firm has elected to pay for all eligible third party research using the Firm's P&L.

Brokers are selected based on their ability to meet the best Execution Factors listed above. The lists of counterparties to be used will be updated from time to time depending on the nature of any changes to the type of investments which the Firm manages and in the light of experience. The firm’s orders are executed directly and placed with a broker to execute. The top five counterparties are listed where orders are routed in two separate tables in the disclosure.

The Firm provides investment advisory services to Professional Clients only. Unless there is a client specific request, the Firm order execution procedure does not differ and execution arrangements are applied consistently across its clients' accounts.