Proportion of orders executed as a percentage of total in that class

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4 Retail Equities Notification if <1 average trade per N Top 5 Venue ranked in terms of Volume MIC Aggressive Directed LONDON STOCK EXCHANGE XLON 97.80% 89.36% n/a n/a n/a TURQUOISE TRQX 1.05% 3.82% n/a n/a n/a CBOE EUROPE - CXE ORDER BOOKS CHIX 0.64% 3.42% n/a n/a n/a AQUIS EXCHANGE PLC AQXE 0.12% 1.81% n/a n/a n/a CBOE EUROPE -BXE ORDER BOOKS BATE 0.06% 0.37% n/a n/a n/a Professional Equities Notification if <1 average trade per N Top 5 Venue ranked in terms of Volume MIC Aggressive Directed LONDON STOCK EXCHANGE XLON 57.67% 0.55% n/a n/a n/a TOKYO STOCK EXCHANGE XTKS 12.80% 22.86% n/a n/a n/a NASDAQ - ALL MARKETS XNAS 7.45% 33.56% n/a n/a n/a NEW YORK STOCK EXCHANGE, INC. XNYS 4.44% 18.08% n/a n/a n/a TURQUOISE TRQX 2.47% 0.01% n/a n/a n/a Report observations/assumptions; 1) Due to the diverse nature of the Panmure Gordon's business activities, to be able to produce this report the total client orders are proportioned by the quantity executed on each venue (i.e. if 90% of a client order is executed on the LSE, the table above attributes a client order of 0.9 to the LSE)

5 Notification if <1 average trade per Top 5 Venue ranked in terms of Volume Professional Exchange Traded Products N MIC Aggressive Directed NASDAQ - ALL MARKETS XNAS 62.25% 46.24% n/a n/a n/a NYSE ARCA ARCA 18.55% 28.30% n/a n/a n/a NEW YORK STOCK EXCHANGE, INC. XNYS 16.51% 23.70% n/a n/a n/a DEUTSCHE BOERSE AG XFRA 2.22% 0.12% n/a n/a n/a CBOE EDGX U.S. EQUITIES EXCHANGE EDGX 0.40% 1.40% n/a n/a n/a Report observations/assumptions; 1) Due to the diverse nature of the Panmure Gordon's business activities, to be able to produce this report the total client orders are proportioned by the quantity executed on each venue (i.e. if 90% of a client order is executed on the LSE, the table above attributes a client order of 0.9 to the LSE)

6 Professional Debt Instruments Notification if <1 average trade per Y Top 5 Venue ranked in terms of Volume MIC Aggressive Directed OTC PINK MARKETPLACE PINX 40.67% 2.27% n/a n/a n/a LONDON STOCK EXCHANGE XLON 26.99% 59.09% n/a n/a n/a OFF-EXCHANGE TRANSACTIONS - n/a n/a n/a LISTED INSTRUMENTS XOFF 12.00% 15.91% EURONEXT - EURONEXT AMSTERDAM XAMS 10.17% 11.36% n/a n/a n/a EURONEXT - EURONEXT PARIS XPAR 6.10% 6.82% n/a n/a n/a Report observations/assumptions; 1) Due to the diverse nature of the Panmure Gordon's business activities to be able to produce this report the total client orders are proportioned by the quantity executed on each venue (i.e. if 90% of a client order is executed on the LSE, the table above attributes a client order of 0.9 to the LSE)

7 Notification if <1 average trade per Top 5 Venue ranked in terms of Volume Retail Securitised Derivatives Y MIC Aggressive Directed NEW YORK STOCK EXCHANGE, INC. XNYS % % n/a n/a n/a

8 Professional Other Instruments Notification if <1 average trade per N Top 5 Venue ranked in terms of Volume MIC Aggressive Directed HONG KONG EXCHANGES AND n/a n/a n/a CLEARING LTD XHKG 57.67% 50.98% OTC MARKETS OTCM 42.05% 30.59% n/a n/a n/a OTC PINK MARKETPLACE PINX 0.21% 2.17% n/a n/a n/a NASDAQ - ALL MARKETS XNAS 0.05% 9.54% n/a n/a n/a NYSE ARCA ARCA 0.01% 5.21% n/a n/a n/a

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10 Notification if <1 average trade per business day in the previous year? Top 5 Broker ranked in terms of Volume Retail Equities N Aggressive Directed PANMURE GORDON (UK) LIMITED 75.29% 66.89% n/a n/a n/a CANTOR FITZGERALD EUROPE 6.93% 1.60% n/a n/a n/a NUMIS SECURITIES LIMITED 4.30% 0.27% n/a n/a n/a KEPLER CAPITAL MARKETS SA (DMA ALGO) 3.67% 20.53% n/a n/a n/a ADM INVESTOR SERVICES INTL LTD 1.95% 0.27% n/a n/a n/a Notification if <1 average trade per business day in the previous year? Top 5 Broker ranked in terms of Volume Professional Equities N Aggressive Directed J.P. MORGAN SECURITIES PLC 44.09% 45.13% n/a n/a n/a INSTINET EUROPE LIMITED 33.94% 36.00% n/a n/a n/a J.P. MORGAN SECURITIES LLC 15.70% 18.52% n/a n/a n/a PANMURE GORDON (UK) LIMITED 4.44% 0.25% n/a n/a n/a KEPLER CAPITAL MARKETS SA (DMA ALGO) 1.12% 0.06% n/a n/a n/a Report observations/assumptions; 1) Due to the diverse nature of the Panmure Gordon's business activities, to be able to produce this report the total client orders are proportioned by the quantity executed on each venue (i.e. if 90% of a client order is executed on the LSE, the table above attributes a client order of 0.9 to the LSE)

11 Notification if <1 average trade per Top 5 Broker ranked in terms of Volume Professional Exchange Traded Products N Aggressive Directed J.P. MORGAN SECURITIES PLC 50.68% 68.42% n/a n/a n/a INSTINET EUROPE LIMITED 29.51% 20.15% n/a n/a n/a J.P. MORGAN SECURITIES LLC 19.81% 11.43% n/a n/a n/a Report observations/assumptions; 1) Due to the diverse nature of the Panmure Gordon's business activities, to be able to produce this report the total client orders are proportioned by the quantity executed on each venue (i.e. if 90% of a client order is executed on the LSE, the table above attributes a client order of 0.9 to the LSE)

12 Professional Debt Instruments Notification if <1 average trade per Y Top 5 Broker ranked in terms of Volume Aggressive Directed J.P. MORGAN SECURITIES PLC 95.29% 34.09% n/a n/a n/a KING & SHAXSON LIMITED 4.17% 18.18% n/a n/a n/a PANMURE GORDON (UK) LIMITED 0.44% 43.18% n/a n/a n/a CANACCORD GENUITY LIMITED 0.10% 4.55% n/a n/a n/a Report observations/assumptions; 1) Due to the diverse nature of the Panmure Gordon's business activities to be able to produce this report the total client orders are proportioned by the quantity executed on each venue (i.e. if 90% of a client order is executed on the LSE, the table above attributes a client order of 0.9 to the LSE)

13 Notification if <1 average trade per Top 5 Broker ranked in terms of Volume Retail Securitised Derivatives Y Aggressive Directed PEEL HUNT LLP % % n/a n/a n/a

14 Professional Other Instruments Notification if <1 average trade per N Top 5 Broker ranked in terms of Volume Aggressive Directed INSTINET EUROPE LIMITED 53.28% 81.82% n/a n/a n/a J.P. MORGAN SECURITIES PLC 31.97% 18.15% n/a n/a n/a J.P. MORGAN SECURITIES LLC 14.74% 0.03% n/a n/a n/a

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16 (a) 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; Price: Depending on the type of instruction, it is usually the most important consideration and refers to the resulting price of the transaction excluding our own execution charges. Speed: It refers to the rate at which we progress your order in the market. Unless we obtain specific instructions from you, we will progress your order at a rate which we believe represents a balance between creating market impact and executing your order in a timely fashion so as to reduce execution risk. Likelihood of execution/size: We interpret this as the likelihood of being able to fill your order in its entirety. This factor increases in importance where access to liquidity is constrained. Costs: This relates to commissions, costs and fess that are charged for executing your order. They usually are the least important of our considerations. There are certain circumstances where best execution will either not apply or have limited scope such as where you give us a specific instruction, for example specifying an execution venue. Those specific instructions may prevent us from taking steps we have put in place to obtain the best possible result for the execution of your orders. (b) a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders; (c) a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received; For more detail refer to the firm's Order Execution Policy Panmure Gordon may use the execution venues listed in the Appendices of the Order Execution Policy when obtaining best execution as defined by MiFID II. Panmure Gordon will endeavor to minimise potential client detriment and avoiding any potential conflicts of interest, for more details refer to the Firm's Conflict of Interest policy on our website Panmure Gordon has no specific arrangements with any execution venues other than the standard terms of membership.

17 (d) an explanation of the factors that led to a change in the list Due to the expansion of the product set offered to client and of it s Prime Brokerage department, Panmure of execution venues listed in the firm s execution policy, if such Gordon has added the below execution venues to the firm s Order Execution Policy. a change occurred; CBOE EUROPE: CXE ORDER BOOKS, BXE ORDER BOOKS CBOE EDGX U.S. EQUITIES EXCHANGE HONG KONG EXCHANGES AND CLEARING LTD JAPAN EXCHANGE GROUP NYSE ARCA OTC PINK MARKETPLACE OTC MARKETS TOKYO STOCK EXCHANGE (e) an explanation of how order execution differs according to Panmure Gordon services all types of clients as classified by the regulation, Retail, Professional and Eligible client categorisation, where the firm treats categories of clients Counterparties however these clients aren't treated differently due to their classification, Panmure Gordon's differently and where it may affect the order execution will handle their orders in the same fashion irrespective of their classification. arrangements; (f) 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; (g) an explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under RTS 27: (h) 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. The main factor that will cause a change in the handling of order execution is the asset class. Over 2018, Panmure Gordon didn't deviate from the Order Execution Policy when servicing Retail clients. Panmure Gordon's MiFID Review Committee assess the execution quality using various data points, most of this data is sources internally or via the exchanges At the time of writing, Panmure Gordon doesn't use consolidated tape providers (CTPs)

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