Not applicable, as there were no such CTPs available in Europe
during the period to which this disclosure relates. |
A summary of the analysis and conclusions the firm draws
from its detailed monitoring of the quality of execution obtained on the
execution venues where it executed all client orders in the previous
year |
Equities - Shares & Depositary Receipts
As part of Arabesque Asset Management Limited (“Arabesque”) analysis of best
execution in relation to equities, the Firm analysed the trades during the
relevant period to determine whether any of the trades were greater than 5% from
the VWAP. |
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
|
Arabesque’s delivery of best execution is a key element in its
commitment to act in the best interests of its clients, as well as being a
regulatory requirement. The Firm prioritises ensuring that all sufficient steps
are taken to obtain the best possible result for its clients when it executes,
places or transmits orders on their behalf. This means taking into account the
‘execution factors’ such as price, costs, speed, likelihood of execution and
settlement, size, nature or any other consideration relevant to the execution of
the order.
The relative importance of the execution factors is judged on an order-by-order
basis in line with the Firm’s industry experience and prevailing market
conditions. In addition, common key factors for relevant asset classes have been
identified as follows:
Equities
For small direct orders over a short period of time, the key factors are
generally price, quantity based on market availability, and likelihood of
execution. For larger orders executed across a period of time, the Firm
additionally takes into account confidentiality, minimising the impact on the
market, and slippage historically achieved on each venue.
Where transactions are executed indirectly, relevant factors are overall costs
including broker fee schedules, impact and observed slippage.
The impact of implicit costs is taken into account when considering the
execution strategy of orders to ensure that they are managed and do not result
in an undue impact to total costs.
|
A description of any close links, conflicts of
interests, and common ownerships with respect to any execution venues used
to execute orders
|
The Firm does not have any close links, conflicts of
interests or common ownerships with respect to the execution venues it uses to
execute orders.
|
A description of any specific arrangements with any
execution venues regarding payments made or received, discounts, rebates or
non-monetary benefits received
|
Arabesque has not entered into any arrangements with its execution
venues regarding payments made or received, discounts or non-monetary benefits
that would compromise its ability to meet its obligations in regards to best
execution, conflicts of interest or inducements.
The Firm has determined that it will pay for research from its own P&L and
if necessary would put in place arrangements to remunerate certain firms for the
receipt of such research. Additionally Arabesque may on occasion receive or
provide minor non-monetary benefits from execution venues. They must be
received/provided in accordance with the Firm’s Inducements policy.
|
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
|
The list of execution venues contained within the Best
Execution policy did not change during the period under review.
|
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
|
While Arabesque does take the characteristics of its clients into
account when judging the relative importance of the execution factors, the
Firm’s clients are exclusively professional clients and so are treated with a
consistent approach.
|
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
|
The Firm does not execute retail client orders. |
An explanation of how the Firm has used any data or tools
relating to the quality of execution, including any data published under
Commission Delegated Regulation (EU) 2017/575
|
Arabesque does not currently use data or tools relating to the
quality of execution, but will utilise such data and tools as are made available
in due course, particularly data published by trading venues under ‘RTS 27’.
|
Where applicable, an explanation of how the
investment firm has used output of a consolidated tape provider established
under Article 65 of Directive 2014/65/EU. |
This is not currently applicable. |