MiFID Disclosure & RS28 Data

Prompted by changes in the way financial markets operate, the European Commission introduced the Markets in Financial Instruments Directive (MiFID), as part of its Financial Services Action Plan (FSAP) in order to create a level playing field in the European Economic Area (EEA) from 1 November 2007.

From 2018, a revised Directive, 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.  Details on this are available in our Best Execution policy available here.  {Note – insert link}

We must also make disclosures by publishing reports on execution venue selection, being the platforms we use for transmitting orders for financial instruments such as equities and units in collective investment schemes (unit trusts & OEICs).

This is in line with the RTS 28 template as set out by the European regulator ESMA and the latest data can be found below.

2017 – Equities

Class of instrument Equities
Notification if <1 average trade per business day in the previous year Yes
Top five execution venues ranked in terms of trading volumes (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
Pershing Securities Ltd
549300NC3GURN0AEZU06
(used for Seven Investment Management Ltd)
84.67% 60.74 n/a n/a 0%
Downing LLP
213800G3X76VBG9SB504
4.82% 2.22% n/a n/a 0%
Octopus Investments Ltd
213800D8ZGDJZPOC9180
4.34% 22.22% n/a n/a 0%
Blackfinch Investments Ltd 213800F8C8V12SJ7UO74 2.97% 4.44% n/a n/a 0%
Foresight VCT plc
213800GNTY699WHACF46
2.40% 2.22% n/a n/a 0%

2017 – ETFs

Class of instrument ETFs
Notification if <1 average trade per business day in the previous year Yes
Top five execution venues ranked in terms of trading volumes (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
SIPPDeal Trustees Ltd
21380064FX4C2KL2T584
(used for AJ Bell Investcentre Ltd)
44.37% 10.26% n/a n/a 0%
Pershing Securities Ltd
549300NC3GURN0AEZU06
(used for Seven Investment Management Ltd)
31.54% 28.21% n/a n/a 0%
Utmost Ltd
213800MY9B6KWBWCJT05
11.73% 15.38% n/a n/a 0%
La Mondiale Europartner S.A.
5493006JYRVV78QV6K46
7.23% 41.03% n/a n/a 0%
Canada Life International Ltd
213800EXPQHAMX5C3C89
5.13% 2.56% n/a n/a 0%

2017 – Collectives

Class of instrument Collectives (unit trusts & OEICs)
Notification if <1 average trade per business day in the previous year No
Top five execution venues ranked in terms of trading volumes (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
Pershing Securities Ltd
549300NC3GURN0AEZU06
(used for Seven Investment Management Ltd)
86.27% 48.77% n/a n/a 0%
SIPPDeal Trustees Ltd
21380064FX4C2KL2T584
(used for AJ Bell Investcentre Ltd)
5.28% 29.01% n/a n/a 0%
Canada Life International Ltd
213800EXPQHAMX5C3C89
2.89% 2.31% n/a n/a 0%
Transact Nominees Ltd
213800D67UJCAHGLI875
2.67% 8.33% n/a n/a 0%
Utmost Ltd
213800MY9B6KWBWCJT05
1.25% 4.09% n/a n/a 0%