MiFID Policy - Amsterdam Trade Bank · 1 Introduction The aim of MiFID is to make European...

MiFID Policy

MiFID Policy 1 of 17 | P a g e

Definitions

Record(s) Any piece of information that can be used to establish an audit trail of or

help reconstruct the series of events in the services or activities performed

by ATB

Execution venue A regulated market, an MTF, an OTF, a systematic internaliser, or a market

maker or other liquidity provider or an entity that performs a similar

function in a third country to the functions performed by any of the

foregoing

Systematic Internaliser An investment firm which, on an organised, frequent systematic and

substantial basis, deals on own account when executing client orders

outside a regulated market, an MTF or an OTF without operating a

multilateral system

Execution of a transaction MiFIR defines execution of a transaction as the provision of any of the

following activities that result in a transaction:

a. Reception and transmission of orders in relation to one or more

financial instruments

b. Execution of orders on behalf of clients

c. Dealing on own account

d. Making an investment decision in accordance with a discretionary

mandate given by a client

e. Transfer of financial instruments to or from accounts

Trading venue A regulated market, an MTF, or an OTF

APA An Approved Publication Arrangement (APA) is a regulated entity under

MiFID II that is authorised to provide the service of publishing trade reports

on behalf of investment firms.

ARM An Approved Reporting Mechanism (ARM) is a regulated entity under

MiFID II that is authorised to provide the service of reporting details of

transactions to competent authorities or to ESMA on behalf of investment

firms.


Contents

1 Introduction .................................................................................................................................................... 4

2 Purpose ........................................................................................................................................................... 4

3 Scope ............................................................................................................................................................... 4

4 Client Classification ......................................................................................................................................... 5

4.1 Eligible Counterparties .......................................................................................................................... 5

4.2 Professional Client ................................................................................................................................. 5

4.3 Retail Clients .......................................................................................................................................... 5

4.4 Classification of clients .......................................................................................................................... 5

4.5 No service to retail clients ..................................................................................................................... 5

4.6 Product suitability matrix ...................................................................................................................... 6

5 Conflicts of interest ......................................................................................................................................... 6

5.1 Conflicts of interest applicable to ATB and their examples ................................................................... 6

5.2 Conflict of interest resulting from investment services and activities offered to clients ...................... 6

5.2.1 Conflicts of interest in relation to the reception and transmission of orders ................................... 7

5.2.2 Conflicts of interest in relation to the execution of orders on behalf of clients ............................... 7

5.2.3 Conflicts of interest in relation to dealing on own account .............................................................. 7

5.3 Conflicts of interest resulting from ATB being part of the Alfa Bank group. ......................................... 7

5.4 Management of conflicts of interest ..................................................................................................... 7

5.4.1 Independence Policy ......................................................................................................................... 7

5.4.2 Decline to Act .................................................................................................................................... 7

5.4.3 Chinese Walls .................................................................................................................................... 7

5.4.4 Conflicts Procedures .......................................................................................................................... 8

5.4.5 Disclosure .......................................................................................................................................... 8

5.4.6 Client Consent ................................................................................................................................... 8

6 Order Execution .............................................................................................................................................. 8

6.1 Best Execution ....................................................................................................................................... 8

6.1.1 Best execution factors ....................................................................................................................... 8

6.1.2 Best execution criteria ...................................................................................................................... 8

6.1.3 Execution venues .............................................................................................................................. 9

6.1.4 Exceptions to best execution ............................................................................................................ 9

6.1.5 Annual disclosure on best execution ................................................................................................ 9

6.1.6 Monitoring & review ......................................................................................................................... 9

6.1.7 Interaction with clients ................................................................................................................... 10

6.2 Order Handling .................................................................................................................................... 10


7 Reporting obligations .................................................................................................................................... 10

7.1 No LEI, no trade ................................................................................................................................... 10

7.1.1 Exception ......................................................................................................................................... 10

7.2 Post-trade disclosure in respect of bonds, structured finance products, emission allowances and

derivatives ......................................................................................................................................................... 10

7.3 Obligation to report transactions ........................................................................................................ 11

7.4 Avoiding duplicate reporting ............................................................................................................... 11

8 Maintenance of Records ............................................................................................................................... 11

8.1 Recording of telephone conversations or electronic communications ............................................... 11

8.2 Recording of face-to-face meetings .................................................................................................... 11

8.3 Record of services or activities giving rise to detrimental conflicts of interest. .................................. 12

8.4 Record of assessment of appropriateness .......................................................................................... 12

8.5 Record keeping of right and obligations of the investment firm and the client.................................. 12

8.6 Record keeping of client orders and decision to deal ......................................................................... 12

8.7 Record keeping of transactions and order processing ........................................................................ 12

8.8 Record keeping of reporting ................................................................................................................ 12

8.9 Retention period of Records ................................................................................................................ 12

Appendix A. Best Execution Factors, Criteria, and Execution Venues ............................................................. 14

Appendix B. Annual disclosure Best Execution ............................................................................................... 16

Appendix C. List of class of financial instruments (for best execution purposes) ........................................... 17


1 Introduction

The aim of MiFID is to make European financial markets more transparent and to strengthen the protection of

investors. MiFID II (Markets in Financial Instruments Directive) is a revision of the European Markets in

Financial Instruments Directive. MiFID II came into effect in 2007 and will apply in full as of 3 January 2018.

Although commonly referred to as MiFID II the revision of MiFID consists of multiple instruments:

Directive 2014/65/EU of 15 May 2014 (MiFID II)

Regulation (EU) No 600/2014 of 15 May 2016 (MiFIR)

Commission Delegated Directive of 7 April 2016

Commission Delegated Regulation of 25 April 2016

Multiple Regulatory Technical Standards (RTS)

Multiple Implementing Technical Standards (ITS)

Various ESMA Guidelines and Q&A’s

In this document a reference to MiFID will be a reference to all over the above, unless specifically mentioned

otherwise.

2 Purpose

As a licensed credit institution Amsterdam Trade Bank (ATB) must comply with the relevant MiFID II

requirements. Whether a specific requirement applies to ATB is dependent on the scope of the specific

regulation, the activities and services of ATB, and the financial instruments used in these activities and services.

ATB performs the following services and activities:

Reception and transmission of orders in relation to financial instruments

Execution of orders on behalf of clients

Dealing on own account

ATB uses the following financial instruments when performing these activities and services:

Transferable securities – i.e. bonds

Derivative contracts relating to securities, currencies, interest rates or yields, emission allowances or

other derivatives instruments, financial indices or financial measures which may be settled physically

or in cash

Derivative contracts relating to commodities that must be settled in cash or may be settled in cash at

the option of one of the parties other than by reason of default or other termination event

The purpose of this policy is to capture ATB’s response to the applicable MiFID II requirements.

3 Scope

This Policy applies to ATB, its subsidiaries, representative offices, other affiliates and branches (if any). This

includes ATB in the Netherlands and ATB’s representative offices.

This Policy contains the minimum standards. The Policy will highlight where ATB has chosen to apply stricter

standards.


This policy details the ‘What’ of the MiFID II requirements, ‘How’ ATB will adhere to these requirements and

‘Who’ does what will be detailed in process flows and procedures as appropriate.

4 Client Classification

ATB’s clients have different levels of knowledge about and expertise dealing in financial instruments; therefore,

it is necessary to provide clients with the appropriate level of investor protection. The investor protection

offered to ATB’s client depends on their classification.

ATB’s clients will be classified under MiFID in accordance with the predefined criteria. The following categories

are recognised:

Eligible Counterparty

Professional Client

Retail Client

4.1 Eligible Counterparties

Eligible counterparties (ECPs) are banks, credit institutions, insurance companies, and similar companies that

can be presumed to have sufficient knowledge and understanding in dealing with investment products, and

therefore get the least of consumer protection.

4.2 Professional Client

Professional clients (Professionals) are considered to have some experience and knowledge to be able to assess

their risks and therefore are offered more regulatory protection than ECPs.

4.3 Retail Clients

Retail clients are those that do not qualify as ECPs or Professionals, and have the least understanding of

investment services, and therefore should receive the highest level of regulatory protection.

4.4 Classification of clients

The Account Manager is responsible for collecting the necessary information to perform a client classification.

The result of the client classification is communicated to the client through a Client Classification Letter. Clients

have the right to request a change in classification, opting up – and giving up investor protection – or opting

down – increasing the level of investor protection.

Reclassification can only be initiated by the client in writing stipulating the reasons for such a request,

especially if requesting an opt-up.

4.5 No service to retail clients

ATB will not provide MiFID services to Retail Clients. Clients classified as a Retail Client can choose to opt-up to

Professional Client if they wish to receive MiFID services.

Similarly, clients classified as a Professional Client opting-down to Retail Client will not be provided MiFID

services.


4.6 Product suitability matrix

ATB’s Clients will only be offered access to the services and financial instruments that correspond with their

client classification. The product suitability matrix captures this requirement.

The product suitability matrix will be updated from time to time if appropriate upon discretion of ATB.

5 Conflicts of interest

ATB considers that conflict of interest may occur in any of the following situations, whether because of

providing investment or ancillary services or investment activities or otherwise:

ATB or that person is likely to make a financial gain, or avoid a financial loss, at the expense of the

client.

ATB or that person has an interest in the outcome of a service provided to the client or of a

transaction carried out on behalf of the client, which is distinct from the client's interest in that

outcome.

ATB or that person has a financial or other incentive to favour the interest of another client or group

of clients over the interests of the client.

ATB or that person carries on the same business as the client.

ATB or that person receives or will receive from a person other than the client an inducement in

relation to a service provided to the client, in the form of monetary or non-monetary benefits or

services.

Where organisational or administrative arrangements made by ATB are not sufficient to ensure, with

reasonable confidence that risks of damage to client interests will be prevented, ATB will clearly disclose to the

client the general nature and/or sources of conflicts of interest and the steps taken to mitigate those risks

before undertaking business on its behalf.

ATB will disclose such conflicts of interest in writing to the client.

5.1 Conflicts of interest applicable to ATB and their examples

ATB has identified potential conflicts of interests that exist in its business activities in order to put in place

measures to monitor, manage and control the realisation of those conflicts of interests. Potential conflicts of

interests may arise through the interaction of different capacities in which we act.

ATB identified the following roles that we play as potentially giving rise to conflicts of interests:

Conflicts of interest resulting from investment services and activities performed.

Conflicts of interest resulting from ATB being part of the Alfa Bank group

5.2 Conflict of interest resulting from investment services and activities offered to

clients

ATB performs the following investment services and activities:

Reception and transmission of orders in relation to financial instruments

Execution of orders on behalf of clients

Dealing on own account


5.2.1 Conflicts of interest in relation to the reception and transmission of orders

Conflicts of interest in relation to the reception and transmission of orders may occur where:

ATB receives opposing orders from multiple clients in the same financial instrument.

Where substantial gifts and entertainment (including non-monetary gifts) are received that may

influence ATB’s behaviour in any way that conflicts with the interests of the clients of ATB.

5.2.2 Conflicts of interest in relation to the execution of orders on behalf of clients Conflicts of interest in relation to the execution of orders may occur where:

ATB is executing orders on behalf of multiple clients in the same financial instrument.

ATB trades with its clients using positions in financial instruments which it holds on its proprietary

book.

ATB trades its proprietary positions in a financial instrument when at the same time it has information

about potential future client orders in relation to that instrument.

5.2.3 Conflicts of interest in relation to dealing on own account Conflicts of interest in relation to dealing on own account may occur where:

ATB trades with its clients using positions in financial instruments which it holds on its proprietary

book.

ATB trades its proprietary positions in a financial instrument when at the same time it has information

about potential future client orders in relation to that instrument.

5.3 Conflicts of interest resulting from ATB being part of the Alfa Bank group.

Conflicts of interest in relation to ATB being part from the Alfa Bank group may occur where:

Group policies prohibit ATB dealing in certain instruments with its clients.

ATB is offering services to a group entity as well as a client.

ATB has choice to execute against a group entity or another financial institution.

5.4 Management of conflicts of interest

For each conflict that ATB identified, measures are put in place to manage, control and prevent its potential

adverse impact. For any conflict of interest one or more of the measures described below may be adopted as

required.

5.4.1 Independence Policy ATB has adopted a policy that each department and its staff should act independently insofar as the interests

of their respective clients are concerned.

5.4.2 Decline to Act When ATB is already acting for one customer, it may be inappropriate for ATB to undertake business for

another customer if ATB is not able to manage the conflict of interest on a reasonable basis or are precluded

from doing so by a legal or regulatory constraint.

5.4.3 Chinese Walls To control access to material, non-public information, a series of “Chinese Walls” have been erected within ATB

to prevent the potential or perceived misuse of such information.


5.4.4 Conflicts Procedures

Conflicts of Interest Procedures have been implemented within ATB to manage actual or potential conflicts of

interest.

5.4.5 Disclosure Where a potential conflict of interest is identified a normal pre-condition for adopting conflict management

measures is that the respective customers are informed that ATB may have conflicting interests (or that ATB is

not acting exclusively for the client). ATB may then decide whether to continue on this basis. This disclosure will

be made in writing.

Disclosure is considered as a measure of last resort that shall be used only where measures established by ATB

to prevent or manage its conflicts of interest are not sufficient to ensure that risks of damage to the interests of

the client will be prevented.

5.4.6 Client Consent Where there is an agreement with the client concerning conflicts of interest, a written record of this will be

kept by ATB’s respective staff.

6 Order Execution

6.1 Best Execution

ATB will take all sufficient steps to obtain the best possible result for clients when executing orders. Where ATB

receives a specific instruction from the client, the order will be executed following the specific instruction. In

this case ATB may not be able to obtain the best possible result.

6.1.1 Best execution factors

When executing client orders the following factors should be considered to achieve the best possible result:

Price

Costs

Speed

Likelihood of execution

Likelihood of settlement

Size

Nature

ATB shall also consider any other consideration relevant to the execution of the order.

6.1.2 Best execution criteria

When executing client orders ATB will use the following criteria to determine the relative importance of the

factors referred to in paragraph 8.2:

The characteristics of the client

The client classification

The characteristics of the client order

The characteristics of the financial instruments referred to in the order (market conditions, time zone,

etc.)


The characteristics of the execution venues to which that order can be directed.

6.1.3 Execution venues When executing client orders ATB will consider the execution venues available and how these venues support

achieving the best possible result.

ATB has identified the following execution venues which will be used to execute client orders:

ATB’s own book.

The book of another broker or investment firm.

Systematic Internaliser (SI)

Other third-country liquidity providers that have a similar function to any of the above.

Crossing order with a matching order of another client.

When ATB executes client orders using a third party, ATB will ensure that the third party’s execution

arrangements are adequate to enable ATB to comply with the best execution obligations.

The relevance of execution venues per class of financial instrument including the relevance of the best

execution factors considered can be found in Appendix A.

6.1.4 Exceptions to best execution

ATB will not be able to guarantee achieving the best possible result in the cases listed below:

Request for Quote Trading: where the client merely requests or takes a price but is not relying on ATB

to protect its interests.

Highly structured and customised transactions: e.g. customised OTC financial instruments, tailored to

the specific circumstances of the client, for which the market does not provide a comparable

alternative.

Single venue transactions: if the order given by the client relates to only one execution venue.

Direct market access: where the client has direct market access through an electronic interface

provided by the firm and in each case it links only to a certain exchange.

Specific client instruction: where we receive a specific client instruction we must execute in

accordance with it and to that extent our obligation of best execution is satisfied.

6.1.5 Annual disclosure on best execution On an annual basis ATB will make public for each class of financial instrument, the top five execution venues in

terms of trading volumes where ATB executed client orders in the preceding year and information on the

quality of execution obtained.

The annual disclosure will take place in the template included in Appendix BB. A list of the class of financial

instrument can be found in Appendix C.

On an annual basis ATB will publish for each class of financial instrument a summary of the analysis and

conclusions drawn from the monitoring of the quality of execution obtained on the execution venues where

ATB executed all client orders in the previous year.

6.1.6 Monitoring & review ATB will monitor the effectiveness of the order execution arrangements and execution policy described in this

paragraph to identify and, where appropriate, correct any deficiencies.


ATB will assess on a quarterly basis, whether the execution venues provide for the best possible result for the

client or whether changes to the execution arrangements are necessary, taking account of the information

published and disclosed in accordance with MiFID II requirements.

ATB will notify clients with whom they have an ongoing client relationship of any material changes to their

order execution arrangements or execution policy.

6.1.7 Interaction with clients ATB shall demonstrate to their clients, at their request, that they have executed their orders in accordance with

the paragraphs listed above.

ATB reserves the right to limit this right of clients where the number, size or frequency of requests is deemed

excessive.

Similarly, ATB will demonstrate to AFM at its request, their compliance with the best execution requirements

under MiFID.

6.2 Order Handling

ATB will execute client orders in a prompt and fair manner.

ATB will execute otherwise comparable client orders sequentially in accordance with the time of receipt of the

order unless:

Otherwise instructed by the client.

The characteristics of the client order or prevailing market conditions make such course of action

impracticable.

The interest of the client requires otherwise.

ATB will not aggregate multiple client orders and/or multiple client orders with transactions for ATB’s own

account.

7 Reporting obligations

7.1 No LEI, no trade

ATB will not enter into new transactions with a counterparty which will trigger the obligation to report prior to

obtaining the legal entity identifier (LEI) from that counterparty – a so called no LEI, no trade policy.

7.1.1 Exception An exception to the no LEI, no trade policy is made where the counterparty intends to close any outstanding

position. When such an event occurs, Treasury Front office will inform the Integrity Department, who will

register the event.

7.2 Post-trade disclosure in respect of bonds, structured finance products, emission

allowances and derivatives

ATB shall make public the volume and price and the time at which they were concluded of transactions in

bonds, structured finance products, emission allowances and derivatives traded on a trading venue. That

information shall be made public through an APA.


7.3 Obligation to report transactions

ATB will report transactions in financial instruments no later than the close of the following working day. ATB

opts to report these transactions to an ARM rather than directly to the AFM.

7.4 Avoiding duplicate reporting

In order to avoid duplicate reporting ATB will not report on behalf of other investment firms unless specifically

agreed in writing prior to the transaction. ATB will also not ask another investment firm to report on its behalf.

8 Maintenance of Records

ATB will keep records of all MiFID II regulated services, activities and transactions undertaken.

The records kept include the recording of telephone conversations or electronic communications relating to

transactions concluded when dealing on own account and the provision of client order services that relate to

the reception, transmission and execution of client orders.

8.1 Recording of telephone conversations or electronic communications

ATB will record relevant telephone conversations and electronic communications, made with, sent from or

received by equipment provided by ATB to an employee or contractor or the use of which by an employee or

contractor has been accepted or permitted by ATB.

Records of telephone conversations and electronic communications will include those that are intended to

result in transactions concluded when dealing on own account or in the provision of client order services that

relate to the reception, transmission and execution of client orders, even if those conversations or

communications do not result in the conclusion of such transactions or in the provision of client order services.

Interacting with clients

The staff listed above is required to inform clients in writing prior to offering services that the conversations

and communications are being recorded. ATB staff will also inform clients that a copy of the recording of such

conversation and communications will be available on request for a period of five (5) years.

8.2 Recording of face-to-face meetings

ATB will keep records of face-to-face meetings where these meetings included discussion of any possible client

orders.

When meeting a client face-to-face and discussing a possible client order the following information will need to

be captured in a call report:

Date and time of meeting

Location of meeting

Identity of the attendees

Initiator of the meeting

Relevant information about the client order including the price, volume, type of order and when it will

be transmitted or executed

These records will need to be made in writing and an electronic record will need to be kept.


Contractors working for a department listed above will have to follow this policy as well.

8.3 Record of services or activities giving rise to detrimental conflicts of interest.

ATB will keep and regularly update the records of the kinds of investment or ancillary service or investment

activity carried out by or on behalf of ATB in which a conflict of interest entailing a risk of damage to the

interests of one or more clients has arisen or, in the case of an ongoing service or activity, may arise.

8.4 Record of assessment of appropriateness

ATB will maintain records of the appropriateness assessments undertaken which shall include the following:

The grounds on which ATB classified the client

the result of the appropriateness assessment (including reasoning behind assessment)

any warning given to the client where the investment service or product purchase was assessed as

potentially inappropriate for the client, whether the client asked to proceed with the transaction

despite the warning and, where applicable, whether ATB accepted the client’s request to proceed with

the transaction

any warning given to the client where the client did not provide sufficient information to enable ATB

to undertake an appropriateness assessment, whether the client asked to proceed with the

transaction despite this warning and, where applicable, whether ATB accepted the client’s request to

proceed with the transaction.

8.5 Record keeping of right and obligations of the investment firm and the client

ATB will retain records which set out the respective rights and obligations of the investment firm and the client

under an agreement to provide services, or the terms on which the ATB provides services to the client, for the

duration of the relationship with the client and for five (5) years after the termination of the relationship.

8.6 Record keeping of client orders and decision to deal

ATB will retain in relation to every initial order received from a client and in relation to every initial decision to

deal taken.

8.7 Record keeping of transactions and order processing

ATB will retain immediately after processing a client order or making a decision to deal on its own account.

8.8 Record keeping of reporting

ATB will retain records of the post trade disclosures and transaction reports made in accordance with the ATB

Reporting Policy respectively. Such records will be kept immediately after such a report has been made.

8.9 Retention period of Records

ATB will retain the records described in this Policy for five (5) years. Upon request of DNB or AFM, ATB will

retain the records described for seven (7) years.

Documents setting out rights and obligations of ATB and client will be retained throughout the duration of the

relationship with the client, after which the records will be kept in accordance with the retention period

defined in this policy – i.e. five (5) years or seven (7) if requested by DNB or AFM.


Records of post trade disclosures and transaction reports made will be retained throughout the life time of the

transaction after which the Record the retention period defined in this policy – i.e. five (5) years or seven (7) if

requested by DNB or AFM.

The retention period for all records at ATB will start from the moment of creation or submission (in the case of

orders).

MiFID Policy 14 of 17| P a g e

Appendix A. Best Execution Factors, Criteria, and Execution Venues

Professional clients

ClassSub-class Price Costs Speed

Likelihood

of

execution

Likelihood

of

settlement

Size NatureRegulated

marketMTF OTF SI

Market

Maker

Other

liquidity

provider

Tick size liquidity bands 5 and 6 (from 2000 trades per day)

Tick size liquidity bands 3 and 4 (from 80 to 1999 trades per day)

Tick size liquidity band 1 and 2 (from 0 to 79 trades per day)

Bonds

Money markets instruments

Futures and options admitted to trading on a trading venue

Swaps, forwards, and other interest rates derivatives 4 5 1 2 1 3 4 1 1 1 3 5 4




Swaps, forwards, and other credit derivatives 4 5 1 2 1 3 4 1 1 1 3 5 4


Swaps, forwards, and other equity derivatives

Warrants and Certificates Derivatives

Other securitised derivatives


Other commodities derivatives and emission allowances derivatives

Exchange traded funds

Exchange traded notes

Exchange traded commodities

Currency Derivatives

Class of financial instrument currently not offered to ATB clients

Class of instrument Best execution factors Execution venue

Debt Instruments

Equities – Shares & Depositary Receipts

Credit Derivatives

Structured Finance Instruments

Equity Derivatives

Securitised Derivatives

Commodities Derivatives and Emission Allowances Derivatives










Interest Rates Derivatives











Contracts for Difference

Exchange Traded Products

Emission allowances

Other instruments



Eligible Counterparties

Class Sub-class Price Costs Speed

Likelihood

of

execution

Likelihood

of

settlement

Size NatureRegulated

marketMTF OTF SI

Market

Maker

Other

liquidity

provider




Bonds







Swaps, forwards, and other credit derivatives 5 3 4 3 1 3 4 1 1 1 3 5 4


Swaps, forwards, and other equity derivatives

Warrants and Certificates Derivatives

Other securitised derivatives







Other instruments


Relevance of execution

factors:

scale of 1 to 5, where:

1 = Not relevant

5 = Most relevant






Emission allowances





Equity Derivatives



Securitised Derivatives






Credit Derivatives

Class of instrument Best execution factors Execution venue





Debt Instruments








Appendix B. Annual disclosure Best Execution

Preview Top-5 disclosure template:

Qualitative annual disclosure Best Execution:

The annual disclosure described in paragraph 8.1.6 shall include at least the following information:

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;

a description of any close links, conflicts of interests, and common ownerships with respect to any

execution venues used to execute orders;

a description of any specific arrangements with any execution venues regarding payments made or

received, discounts, rebates or non-monetary benefits received;

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;

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;

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;

an explanation of how the investment firm has used any data or tools relating to the quality of

execution, including any data published by execution venues;

Where applicable, an explanation of how the investment firm has used output of a consolidated tape

provider.

Class of Instrument

Notification if <1 average

trade per business day in

the previous year

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

percentage of

total in that

class

Percentage

of passive

orders

Percentage of

aggressive

orders

Percentage of

directive orders

Name and Venue Identifier

(MIC or LEI)


(MIC or LEI)


(MIC or LEI)


(MIC or LEI)


(MIC or LEI)


Appendix C. List of class of financial instruments (for best execution purposes)

The class of financial instrument is presented in red, the bullet point below the class highlight the category of

financial instrument recognized within that class. ATB may not be active (yet) in all classes.





Debt Instruments

Bonds




Swaps, forwards, and other interest rates derivatives

Credit Derivatives


Other credit derivatives



Swaps, forwards, and other currency derivatives


Equity Derivatives


Swaps and other equity derivatives

Securitized Derivatives

Warrants and Certificate Derivatives

Other securitized derivatives









Emission allowances

Other instruments

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