BEST EXECUTION
Under the Directive 2014/65/EU on Markets in Financial Instruments (“MiFID II”), the ‘Guidelines and Notices’ issued by the Monetary Authority of Singapore (the “MAS”), and the Hong Kong Securities and Futures Commission’s (“SFC”) ‘Code of Conduct’, Partners Capital LLP (“PCL”), Partners Capital Europe S.A.S (“PCE”), Partners Capital Investment Group (Asia) Pte. Ltd. (“PCS”), and Partners Capital Asia Limited (“PCA”) (together, “Partners Capital”) is required to take all sufficient steps to obtain the best possible result for clients when executing orders (or receiving and transmitting orders) on their behalf, taking into account factors such as price, costs, speed, likelihood of execution and settlement, size, nature, or any other consideration relevant to the execution of the order.
We are required to provide clients with our Order Execution Policy (which can be found below) that includes how we will handle specific client instructions, as well as the processes to monitor executions and the evidencing of compliance to our policy.
All clients of PCL and PCE will be treated in accordance with their MiFID client categorisations, which will have been communicated to them.
Under MiFID II, we must also make disclosures to clients by publishing a report (under RTS 28) on execution venue selection. This requirement is only applicable to PCE.
As described in our Order Execution Policy, we have not provided a list of the venues upon which we place significant reliance. This is due to the fact that most Partners Capital clients have existing custody accounts through whom it is most beneficial to place client orders. To the extent Partners Capital has discretion over the choice of one execution venue over another, the selection of the execution venue will be made based on which venue (or venues) provide for the best overall result for the client. Partners Capital undertakes on-going assessments of the execution venues used to determine whether existing venues continue to provide for the best possible result for clients and also to review the suitability of new execution venues. In making this assessment we will utilise information derived from our own internal best execution monitoring tools and processes as well execution quality data reported by execution venues under MiFID II and its implementing measures. This will include the following factors:
i. Price;
ii. Liquidity;
iii. Execution and clearing costs;
iv. Clearing arrangements such as settlement reliability;
v. Execution venue trading controls; and
vi. Scheduled actions.
In executing client orders Partners Capital does not receive any remuneration, discount or nonmonetary benefit for routing client orders to a particular execution venue which would infringe any conflicts of interest or inducement requirements under MiFID II.
ORDER EXECUTION POLICY
This document sets out Partners Capital’s approach to providing best execution and how it intends to monitor the achievement of best execution.
BEST EXECUTION REPORTS
The RTS 28 reports are published annually for Partners Capital Europe.
Equity - Liquidity Bands 1 & 2
RTS 28 Report for professional clients: 2017 2018 2019 2020 2021 2022
RTS 28 Report for retail clients: 2017 2018
Analysis: 2017
Equity - Liquidity Bands 3 & 4
RTS 28 Report for professional clients: 2017 2018 2019 2020 2021 2022
RTS 28 Report for retail clients: 2017
Analysis: 2017
Equity - Liquidity Bands 5 & 6
RTS 28 Report for professional clients: 2017 2018 2019 2020 2021 2022
Analysis: 2017
Future
RTS 28 Report for professional clients: 2017 2018 2019 2020 2021
Analysis: 2017
ETF
RTS 28 Report for professional clients: 2017 2018 2019 2020 2021 2022
RTS 28 Report for retail clients: 2017 2018 2019 2020 2021
Analysis: 2017
ETN
RTS 28 Report for professional clients: 2017 2018 2019 2020 2021
Analysis: 2017
ETC
RTS 28 Report for professional clients: 2017 2018 2019 2020 2021 2022
Analysis: 2017
Option
RTS 28 Report for professional clients: 2017 2019 2020 2021
Analysis: 2017
AIF
RTS 28 Report for professional clients: 2017 2018 2019 2020 2022
RTS 28 Report for retail clients: 2017 2018 2019 2020 2022
Analysis: 2017
CIF
RTS 28 Report for professional clients: 2017 2018 2019 2020 2021 2022
RTS 28 Report for retail clients: 2017 2018 2019 2020 2021
Analysis: 2017
Bonds
RTS 28 Report for professional clients: 2022
Analysis: 2017