Execution venues

Overview

Under the second Markets in Financial Instruments Directive (“MiFID II”), Phanar Asset Management (UK) Ltd., as a firm that is subject to MiFID II must take all sufficient steps to obtain, when executing orders, the best possible result for our clients.

The objective of best execution is that Phanar Asset Management (UK) Ltd. takes all sufficient steps to obtain the best possible result for our clients. In order to achieve this, Phanar Asset Management (UK) Ltd. takes into account a number of execution factors.

The factors we take into account are:

• size of the transaction;
• speed of execution and settlement;
• likelihood of execution;
• likelihood of settlement; and

any other factor we consider is relevant to the transaction.

In determining the applicability of the factors we consider:

• Market information
• The details we hold about our client

The nature of the transaction including the specific financial instrument and the markets that the specific financial instruments

The application of these factors is a matter of judgement. Other firms may exercise their judgement differently and reach a different conclusion as to how to achieve the overarching objective. In most cases the factors other than total consideration to the client will not be applicable and thus this execution factor will be the determining factor. The remaining factors are not listed in any order of priority. The factors may be interlinked such that for example, in fast moving markets, particularly for large orders, the way Phanar Asset Management (UK) Ltd. would seek to achieve best total cost/revenue may involve giving the order to a broker who Phanar Asset Management (UK) Ltd. believes can execute the entire order in a timely manner even if part of the order could be filled at a more advantageous price from another broker.

Execution Venues

 For some financial instruments there are a range of execution venues where the trade could be executed. Phanar Asset Management (UK) Ltd. regularly assess the execution venues available and may add or delete venues in accordance with the overall objective.

Phanar Asset Management (UK) Ltd. is at all times instructed by the client to use a particular trading venue of the client’s choice. Phanar accepted those terms as stipulated in its agreements with clients.

The underlying reason for this is the particular set up of Phanar. Phanar trades directly on the clients account under a limited power of attorney. Trading is limited to the respective counter-party.

In the case of a broker in the European Economic Area or Switzerland that broker will have their own best execution policy and will be under the same requirement as we are under MiFID II to seek to achieve best execution for our clients. In the case of brokers outside the EEA and Switzerland those brokers may or may not be subject to local best execution rules. In all cases the selection of a broker is based upon the execution factors.

What information about best execution will we report

As required by MiFID II we will report to you:

• The top five brokers we have used for each asset class in terms of volumes; and
• Information on the quality of our execution