| Class of Instrument | Equities - Tick size liquidity band 1 and 2 | |
|---|---|---|
| Notification if <1 average trade per business day in the previous year |
N |
| Top 5 execution venues ranked in terms of trading volume (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 directed orders |
|---|---|---|---|---|---|
| Robert W Baird 549300772UJ AHRD6LO53 |
49.11% | 21.32% | NA | NA | NA |
| Morgan Stanley 9R7GPTSO7KV 3UQJZQ078 |
21.44% | 29.74% | NA | NA | NA |
| RBC 549300QJJX6 CVVUXLE15 |
9.39% | 14.21% | NA | NA | NA |
| Merrill Lynch GGDZP1UYGU9 STUHRDP48 |
9.05% | 12.63% | NA | NA | NA |
| Deutsche Bank 7LTWFZYICNS X8D621K86 |
8.10% | 15.26% | NA | NA | NA |
| Class of Instrument | Equities – Tick size liquidity band 3 and 4 | |
|---|---|---|
| Notification if <1 average trade per business day in the previous year |
Y |
| Top 5 execution venues ranked in terms of trading volume (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 directed orders |
|---|---|---|---|---|---|
| Morgan Stanley 9R7GPTSO7KV 3UQJZQ078 |
29.56% | 23.33% | NA | NA | NA |
| Robert W Baird 549300772UJ AHRD6LO53 |
24.39% | 16.67% | NA | NA | NA |
| Merrill Lynch GGDZP1UYGU9 STUHRDP48 |
14.47% | 13.33% | NA | NA | NA |
| RBC 549300QJJX6 CVVUXLE15 |
12.85% | 13.33% | NA | NA | NA |
| Deutsche Bank 7LTWFZYICNS X8D621K86 |
10.29% | 13.33% | NA | NA | NA |
| Class of Instrument | Equities – Tick size liquidity band 5 and 6 | |
|---|---|---|
| Notification if <1 average trade per business day in the previous year |
Y |
| Top 5 execution venues ranked in terms of trading volume (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 directed orders |
|---|---|---|---|---|---|
| Robert W Baird 549300772UJ AHRD6LO53 |
42.40% | 24.32% | NA | NA | NA |
| RBC 549300QJJX6 CVVUXLE15 |
19.50% | 21.08% | NA | NA | NA |
| Morgan Stanley 9R7GPTSO7KV 3UQJZQ078 |
17.63% | 23.78% | NA | NA | NA |
| Deutsche Bank 7LTWFZYICNS X8D621K86 |
15.82% | 24.86% | NA | NA | NA |
| Pavilion 89RLTMP2WM4 KXYJMWI06 |
2.60% | 4.32% | NA | NA | NA |
| Class of Instrument | Equities – No tick size liquidity band | |
|---|---|---|
| Notification if <1 average trade per business day in the previous year |
Y |
| Top 5 execution venues ranked in terms of trading volume (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 directed orders |
|---|---|---|---|---|---|
| Pavilion 89RLTMP2WM4 KXYJMWI06 |
93.21% | 57.69% | NA | NA | NA |
| Merrill Lynch GGDZP1UYGU9 STUHRDP48 |
6.56% | 15.38% | NA | NA | NA |
| Deutsche Bank 7LTWFZYICNS X8D621K86 |
0.13% | 15.38% | NA | NA | NA |
| Morgan Stanley 9R7GPTSO7KV 3UQJZQ078 |
0.09% | 11.54% | NA | NA | NA |
Note: the tick size liquidity bands are apportioned as per the MiFID II tick-size regime. As a global equity investor, many of our investments’ main pools of liquidity are outside the EU. As of the time of publishing, while ESMA has made recommendations to the European Commission regarding modifications to the tick size regime for this class of instruments, these have not yet been ratified by the Commission. Thus, in accord with the regulations as they currently stand, instruments are classified based purely on their ADNT in EU markets. We have also included an analogous table for those equities that we hold that have no EU pools of liquidity.
| Venue | Information Assessed | Conclusions | |
|---|---|---|---|
| All | 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 | The ability to execute the order accurately, as requested, and in a timely fashion is paramount (see explanation in 6th answer below). Overall cost for the trade is then the main determining factor, with the proviso that the broker is able to provide necessary trade summary information that we are required to report. |
|
| A description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders | None | ||
| A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received | None, relationships are on an execution-only basis. | ||
| 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 | NA | ||
| 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 | NA | ||
| 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 | Not all brokers have access to all markets in which we trade, so market coverage is also an overriding factor. Other brokers may have settlement issues in some markets, which may incur additional costs. Timing of the order also affects choice of broker, depending on whether the brokers are usually responsive out-of-hours. Trade data availability is also a factor. |
||
| An explanation of how the firm has used any data or tools relating to the quality of execution, including any data published by execution venues under RTS 27 | Independent internal comparison against Bloomberg-published VWAP undertaken regularly. | ||
| Where applicable, an explanation of how the firm has used 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) | NA |
GuardCap is a wholly-owned subsidiary of Guardian Capital Group Limited (GCG), a Canadian group which was founded in 1962 and whose shares are quoted on the Toronto Stock Exchange.
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