RTS reporting as of 30th April 2021 - For the calendar year 2020 transactions

The purpose of this document is to provide clients with information about how the firm has ensured compliance with its Best Execution policy during 2020. The report's scope includes any financial instrument traded on a ‘trading venue’. It includes up to the top five trading venues/brokers used in 2020 and summarises the quality of execution achieved. Note that as ‘collective investment scheme’ funds are not ‘traded’, they are excluded from this report.

Quantitative ‘top-five’ reports

Table 1: Equities (retail clients)

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)
The proportion of volume traded as a percentage of the total in that class
The proportion of orders executed as a percentage of the total in that class
Percentage of passive orders
Percentage of aggressive orders
Percentage of directed orders
Seven Investment Management LLP 213800Z67VYVM8EQ1C25
72%
31%
N/A
N/A
N/A
Integrated Financial Arrangements Ltd [“Transact”] 213800ZSEMCXQOTV1O47
28%
69%
N/A
N/A
N/A

Table 2: Exchange-traded products (retail clients)

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)
The proportion of volume traded as a percentage of the total in that class
The proportion of orders executed as a percentage of the total in that class
Percentage of passive orders
Percentage of aggressive orders
Percentage of directed orders
Seven Investment Management LLP 213800Z67VYVM8EQ1C25
65%
50%
N/A
N/A
N/A
Integrated Financial Arrangements Ltd [“Transact”] 213800ZSEMCXQOTV1O47
35%
50%
N/A
N/A
N/A

Table 3: Debt instruments (retail clients)

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)
The proportion of volume traded as a percentage of the total in that class
The proportion of orders executed as a percentage of the total in that class
Percentage of passive orders
Percentage of aggressive orders
Percentage of directed orders
Seven Investment Management LLP 213800Z67VYVM8EQ1C25
100%
100%
N/A
N/A
N/A
Integrated Financial Arrangements Ltd [“Transact”] 213800ZSEMCXQOTV1O47
0%
0%
N/A
N/A
N/A

Qualitative report

Required information
Our disclosure
Relative factor importance - An explanation of the relative importance the firm gave to the execution factors such as price, costs, speed, and likelihood of execution when making assessments of the quality of execution.
The firm will assess the quality of execution by taking into consideration the execution factors outlined below: • Price. • Cost of the transaction. • Speed of execution. • Likelihood of execution and/or settlement. • Size and complexity of the order; and • Characteristics and nature of the orders • Other considerations relevant to the execution of an order For all Clients, the price will normally be the most important aspect in determining the quality of execution. In some scenarios, other factors may be taken into greater consideration such as the size and complexity of large orders or if a large order will impact the price received. The above factors will be reviewed in relative importance to assess the ‘Total Consideration’ to the client. Total consideration is defined as the price of the financial instrument and the costs related to execution, including all expenses incurred which are directly related to the execution such as execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.
Venue conflicts - A description of any close links, conflicts, and common ownerships with respect to any execution venues used to execute orders.
The firm and some directors of the firm are shareholders in “Transact”. This interest does not impact or dictate how the platform is used to execute client orders. The firm has no other known close links, conflicts of interests or any common ownership with respect to execution venues used to execute orders.
Venue payments - A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.
There are no specific arrangements with any venue regarding payments made or received, discounts, rebates or non-monetary benefits received.
Venue changes - An explanation of the factors that led to a change in the list of execution venues listed in the firm's execution policy (if applicable).
The firm has continued to mainly use the same platforms to which it transmits orders. The largest proportion of assets (by value) is held on the Transact platform, with Seven Investment Management being the second largest platform for clients.
Client categorisation - An explanation of how order execution differs according to client categorisation, where the firm treats such a category of client differently and where it may affect the order execution arrangements.
The firm deals only with ‘retail clients’ such that no differences in order execution arise.
Retail factors - An explanation of when 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.
Orders are transmitted to these platforms for execution and no criteria are placed on them when they are executing those orders. The firm is limited to platforms that we use, and the location of our client's assets is predominantly held on Transact & Seven Investment Management Platforms. We are therefore somewhat reliant upon the price that the platform quotes. During 2019 all retail client orders were placed with price and cost as the most important criteria.
Execution analysis tools - An explanation of how the firm has used any data or tools related to the quality of execution, including data published by execution venues under RTS 27.
No execution analysis has been carried out. Trades are reviewed in line with our execution policy to ensure they are executed on the best terms possible. Further analysis will be made available by trading venues indicating how they have performed in relation to others in the market. The firm will where applicable look to use this in the future analysis of quality of execution.
CTP usage - An explanation of how the firm has used the output of a consolidated tape provider which will allow for the development of enhanced measures of execution quality or any other algorithms used to optimise and assess execution performances (if applicable).
N/A