In accordance with MIFID II, from 3 January 2018, Partners Capital LLP is required to take sufficient steps to obtain the best possible result for its clients when executing orders on their behalf.
Under MiFID II 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 Partners Capital LLP will be treated in accordance with their FCA Classifications which will have been communicated to them.
MiFID II reiterates the MIFID requirements and specifies that we act in the best interests of clients when providing execution services and that we maintain monitoring arrangements that demonstrate compliance. We must also make disclosures to clients by publishing a report (under RTS 28) on execution venue selection.
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:
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 LLP’s approach to providing best execution and how it intends to monitor the achievement of best execution, as required by MiFID II.
BEST EXECUTION REPORTS
The RTS 28 reports are published annually.
Equity - Liquidity Bands 1 & 2
Equity - Liquidity Bands 3 & 4
RTS 28 Report for retail clients: 2017
Equity - Liquidity Bands 5 & 6