GENERATION INVESTMENT MANAGEMENT LLP

Similar documents
First State Investments Annual Order Execution Report Year Ending April 2018

Henderson Global Investors Limited (HGIL) Annual Best Execution Disclosure 2017

2017 MiFID II EXECUTION QUALITY REPORT

Russell Investments Implementation Services, LLC (832R0263EHR5038Q2Z24) 100% 100% 0%

Parvus Asset Management Europe Limited

ST. JAMES S PLACE UNIT TRUST GROUP ORDER EXECUTION POLICY

Percentage of passive orders

Och-Ziff Management Europe Limited Annual RTS 28 Best Execution Disclosures Oz Management

Annual Trade Execution Report April 2018

Pictet Asset Management Best Execution Policy

Best Execution Policy. Crossbridge Capital LLP

Equities - Shares & Depositary Receipts

Top 5 Execution Venues and Top 5 Brokers Report by Credit Suisse Asset Management (Switzerland) Ltd.

NEWTON ORDER EXECUTION POLICY

Order Execution Policy

Sparinvest S.A. RTS 28 report

Classes of Financial Instrument traded during the period

Quality of Execution 2017 Annual Report

Saxo Capital Markets UK Limited

A.1 INFORMATION ON THE TOP FIVE EXECUTION VENUES

State Street Global Advisors Ireland Limited. Best Execution Policy

D. E. Shaw & Co. (London), LLP Annual Summary of Execution Arrangements

BlueBay Asset Management LLP RTS 28 Qualitative Assessment of Execution (year ending 31 st December 2017)

Eurobank Cyprus Ltd MIFID II Annual Report on the Quality of Deal Execution for 2017

EXECUTION POLICY JANUARY 2018

Best Execution Policy

William Blair: Client Order Execution Policy

BGC Brokers L.P. RTS 28 Quality of Execution

BlueBay Order Execution Policy

Miton Asset Management Limited Order Execution Policy

For the Period: 1 January 2017 to 31 December 2017 inclusive ( 2017 Calendar Year ) Publication date: 30 April 2018

Best Execution Disclosure Reporting Period: 1 st January 31 st December 2017

Order Execution Policy financial instruments

DALTON STRATEGIC PARTNERSHIP LLP ORDER EXECUTION POLICY DECEMBER 2017

Information on the RBCCM Europe Best Execution Policy

Best Execution & Order Handling Policy

ISAM Funds (UK) Limited

Apr Napier Park Global Capital Ltd Annual Best Execution Disclosure 2017

Execution Policy. For Professional Clients

BestExHub RTS 28 & DA 65(6) OVERVIEW

C. EXECUTION POLICY TERMS OF BUSINESS

MIFID II: RTS 28 REPORT INFORMATION ON EXECUTION VENUES AND QUALITY OF EXECUTION HPC SA

Best Execution & Order Handling Policy

Measuring your approach MiFID II Paper: Best execution

NORTHERN TRUST SECURITIES LLP

BEST EXECUTION AND CLIENT ORDER HANDLING POLICY FOR PROFESSIONAL AND RETAIL CLIENTS

Putnam Investments Limited Annual Best Execution Report 2017

Execution Principles

Canada Life Investments

Order Handling & Execution Policy Policy & Guidance

MiFID II Top 5 Venue Reporting Table. Date: 30 th April Prepared by: Integra Private Wealth Limited

MiFID II Top 5 Venue Reporting Report

MiFID II RTS 28 Report - Reception and Transmission of Orders Top 5 Brokers, Professional Clients Argus Stockbrokers Ltd

Order Execution Policy - Corporate and Investment Bank

Top 5 Execution Venues/Brokers & Annual Qualitative Report

2017 ORDER EXECUTION REPORT- DERIVATIVES

Citi Markets & Banking EXECUTION POLICY

Order Execution Policy 3 rd January 2018

RTS28 - Execution quality reports

CITI SECURITIES SERVICES EXECUTION POLICY

UK Disclosures. 1. Annual publication of information on the identity of execution venues and on the quality of execution (MiFID II RTS 28 disclosure)

BofAML EMEA Order Execution Policy Summary

Order Execution Policy

Execution Policy. 1 Purpose. to and taking into account the execution factors (see paragraph 4).

Order Execution Policy for Retail Clients Settling Through Pilling Cantor Fitzgerald Europe ( CFE )

J. P. M O R G A N E M E A C U S T O D Y & F U N D S E R V I C E S : E X E C U T I O N P O L I C Y

Primary execution factors considered. 1 Most Least

Taconic Capital Advisors UK LLP ( TCA UK ) Best Execution Report

Morgan Stanley s EMEA Equity Order Handling & Routing. Frequently Asked Questions. (Last Updated: March, 2018)

State Street Bank Luxembourg S.C.A. Order Execution Policy

Best Execution Policy Information for Eligible Counterparties, Professional clients and Retail clients

Order Execution (RTS 28) Disclosure

STONEHAGE FLEMING INVESTMENT MANAGEMENT ORDER EXECUTION POLICY

KILTEARN PARTNERS LLP BEST EXECUTION SUMMARY 2017

Statement on Best Execution Principles of Credit Suisse Asset Management (Switzerland) Ltd.

Top 5 Execution Venue Reporting of Vontobel Asset Management AG

The jurisdiction of this policy is extended to Tokyo Marine Rogge Asset Management Limited.

BNY Mellon EMEA Order Handling and Execution Policy

Best Execution. Andre Nogueira

Order Execution Policy for clients of the SEB

2018 RTS28 Report - Summary of the analysis BNP Paribas SA Swaps and Other Equity Derivatives

Mega Equity Securities & Financial Services Public Ltd ( Mega Equity )

MARKETS IN FINANCIAL INSTRUMENTS DIRECTIVE (MIFID) INFORMATION TO PRIVATE CLIENTS

Liquidnet Order Execution Policy

J.P. MORGAN EMEA FIXED INCOME, CURRENCY, COMMODITIES AND OTC EQUITY DERIVATIVES: EXECUTION POLICY

Castlefield Investment Partners LTD RTS 28 Best Execution report.

Millennium Global Investment Limited RTS 28 Disclosure Report. Disclosure Period: 01/01/2017 to 31/12/2017

Best Execution, Order and Placement Policy

Best Execution How we execute client orders. Wealth Management

Global Prime Finance Annex to the MiFID Order Execution Policy Corporate & Investment Bank EEA

GLOBAL ORDER EXECUTION POLICY

Information on the RBC I&TS (UK) Best Execution Policy

RTS 28 Reports Equities - Shares and Depositary Receipts. Table 1 - Top 5 Brokers for Professional Clients

Information. MiFID II Best Execution Top 5 Execution Venues and Top 5 Brokers

Summary of the Best Execution Policy

REPORT OLD MUTUAL GLOBAL INVESTORS (UK) LIMITED QUALITATIVE EXECUTION

Order Execution Policy. Rothschild Wealth Management (UK) Limited (including Milan branch) 3 January 2018

B E S T E X E C U T I O N P O L I C Y

PVM Execution and Order Handling Policy

Annual publication on the identity of execution venues and on the quality of execution required by Directive 2014/65/EU

Transcription:

GENERATION INVESTMENT MANAGEMENT LLP BEST EXECUTION REPORT FOR 2017 APRIL 2018

1. BACKGROUND Following the implementation of MiFID II on 3 January 2018, Generation is required to make certain annual disclosures on the top five execution venues/investment firms with whom it has placed orders for execution in the previous year. The specific information to be provided is set out in Regulatory Technical Standard 28 ( RTS 28 ) of MiFID II. RTS 28 requires Generation to complete specific templates for each class of financial instrument in which it places orders, setting out the percentage volume and number of orders of its top five brokers and information on the quality of the execution obtained. This information has to be broken down by retail clients and professional clients. Generation does not provide services to retail clients so the information provided is solely based upon orders executed on behalf of professional clients. CONFLICTS OF INTEREST In accordance with RTS 28, Generation is also required to provide information on any close links, conflicts of interest and common ownerships it might have with the investment firms with which it places orders. Generation can confirm that it has no close links, conflicts of interest nor common ownerships with its brokers. Generation is also able to confirm that it has not entered into specific arrangements with its brokers regarding payments made or received, discounts, rebates or non-monetary benefits. Prior to the implementation of MiFID II Generation took the decision to pay for all research it receives from its brokers and third party research providers directly out of its own resources. Generation has agreed common execution only commission rates with its brokers which are solely subject to variations by region and transaction type. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 1

2. ORDER EXECUTION POLICY Prior to the provision of portfolio management services Generation provides its professional clients with its Order Execution Policy. The Policy includes information on inter alia: > Arrangements for and commitment to the achievement of best execution; > broker selection and approval process; > broker commission rates; > current approved brokers for each asset class; > the operation of its independent dealing desk; > aggregation and allocation arrangements; > broker oversight and monitoring arrangements; and > the main execution factors that Generation considers when placing orders, ranked by level of importance. As required by RTS 28, in the tables set out at section 3 below, Generation has set out (for each class of financial instruments) the relative importance it assigns to the following execution factors: price, costs, speed, likelihood of execution, size and nature of the order. In its selection of brokers and order execution Generation applies the same process consistently across all of its clients, except where a client has directed Generation to deal exclusively through a particular broker of the client s choice. Broker execution performance in listed equities is monitored on a continuous basis by Generation s dedicated dealing desk. Once a trade has been placed with a broker, prices are checked against the prevailing price in the market; its progress is monitored on a real time basis by the independent dealing desk to full execution. The executed price is monitored against the prevailing market volume weighted average price. In addition, Generation has contracted the services of an independent third party provider of transaction cost analysis. Generation works to identify and establish appropriate benchmarks for our style of investing and process. The analysis aims to capture the effectiveness of the execution process in aggregate whilst also identifying exceptions based on predefined criteria and tolerances versus benchmarks that may include opening and closing prices, volume and volatility events and possibly news events. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 2

3. TOP FIVE BROKERS BY CLASS OF FINANCIAL INSTRUMENT N.B. RTS 28 requires firms to set out the percentage of orders that were passive and aggressive orders. A passive order is an order that effectively provides liquidity, while an aggressive order is one that takes liquidity. As set out in ESMA s Investor Protection Q&A (Q 14), portfolio managers should only identify passive or aggressive orders where the portfolio manager has attached a specific instruction to an order, and that instruction is understood to mean that the broker will execute the order in a fashion that is either passive or aggressive. CLASS OF INSTRUMENT: : (A) EQUITIES - SHARES & DEPOSITARY RECEIPTS - (I) TICK SIZE LIQUIDITY BANDS 5 AND 6 (FROM 2000 TRADES PER DAY) PROPORTION OF N CLASS TOTAL EQUITY VOLUMES: 16.59% PASSIVE AGGRESSIVE DIRECTED Credit Suisse International 36.2% 25.1% N/A N/A 0.0% Liquidnet Europe Limited 32.5% 40.9% N/A N/A 0.0% Bank of America Merrill Lynch 20.6% 20.0% N/A N/A 0.0% Morgan Stanley 3.1% 1.4% N/A N/A 0.0% Goldman Sachs International 2.5% 4.2% N/A N/A 0.0% Execution Factors Equities Liquidity Band 5 and 6 - Liquid equities : > These represent orders that can generally be completed within 1 2 days > Special Client Order Instructions, acting in accordance with client direction, is considered of the highest importance when seeking to meet client expectations. > The nature of the order as received from the Investment Decision Maker is the next most important criteria for consideration; objective and intention of the portfolio manager, any order constraints such as price limits and level of urgency. > Price is subsequently considered a key measurable factor when assessing best execution. > Liquidity / Size is of increasing importance when trading larger size orders. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 3

(A) EQUITIES - SHARES & DEPOSITARY RECEIPTS - (II) TICK SIZE LIQUIDITY BANDS 3 AND 4 (FROM 80 TO 1999 TRADES PER DAY) PROPORTION OF N CLASS TOTAL EQUITY VOLUMES: 11.06% PASSIVE AGGRESSIVE DIRECTED Credit Suisse International 35.6% 47.1% N/A N/A 0.0% Bank of America Merrill Lynch 14.5% 15.3% N/A N/A 0.0% Sanford C. Bernstein Limited 12.1% 6.6% N/A N/A 0.0% Liquidnet Europe Limited 11.7% 13.5% N/A N/A 0.0% William Blair International Limited 7.3% 2.3% N/A N/A 0.0% Execution Factors Equities Liquidity Band 3 and 4 - Liquid equities : > These represent orders that can generally be completed within 1 2 days > Special Client Order Instructions, acting in accordance with client direction, is considered of the highest importance when seeking to meet client expectations. > The nature of the order as received from the Investment Decision Maker is the next most important criteria for consideration; objective and intention of the portfolio manager, any order constraints such as price limits and level of urgency. > Price is subsequently considered a key measurable factor when assessing best execution. > Liquidity / Size is of increasing importance when trading larger size orders. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 4

(A) EQUITIES - SHARES & DEPOSITARY RECEIPTS - (III) TICK SIZE LIQUIDITY BANDS 1 AND 2 (FROM 0 TO 79 TRADES PER DAY) PROPORTION OF N CLASS TOTAL EQUITY VOLUMES: 70.48% PASSIVE AGGRESSIVE DIRECTED Liquidnet Europe Limited 57.2% 61.1% N/A N/A 0.0% Credit Suisse International 19.6% 19.9% N/A N/A 0.0% William Blair International Limited 5.3% 2.6% N/A N/A 0.0% Bank of America Merrill Lynch 5.0% 5.2% N/A N/A 0.0% Sanford C. Bernstein Limited 4.2% 4.1% N/A N/A 0.0% Execution Factors Equities Liquidity Band 1 and 2 - Illiquid equities : > These represent orders that generally take more than 5 days to complete > As with Liquid Equities described in the previous two tables Client Order Instruction and the Nature of the Order retains the highest order of importance. > Size and Liquidity factors are of growing importance when trading illiquid securities, and further consideration and care needs to be taken when selecting a venue for the avoidance of market impact (implicit cost) and information leakage. Price remains a key measurable factor for assessing best execution. > Likelihood of execution, costs and the speed of execution are less relevant as liquidity opportunity and natural contra flow and indications will take precedence. > The desk will primarily search for natural blockable liquidity to minimise market impact and signalling risk. This may take the form of searching indications of interest (IOIs), use of block discovery and matching platforms (such as Liquidnet) and the use of conditional order types on strategies accessing limited number of venues or exchanges (e.g. LIS indications on conditional venues like IEX). GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 5

(E) CURRENCY DERIVATIVES - (II) SWAPS, FORWARDS, AND OTHER CURRENCY DERIVATIVES N PROPORTION OF PASSIVE AGGRESSIVE DIRECTED Royal Bank of Canada 35.6% 48.9% N/A N/A 0.0% The Northern Trust Company 35.5% 32.6% N/A N/A 0.0% Bank of New York Mellon 18.0% 10.3% N/A N/A 0.0% CACEIS Bank Luxembourg 8.6% 3.9% N/A N/A 100.0% Russell Implementation Services 2.3% 4.3% N/A N/A 100.0% Execution Factors Currency Derivatives Swaps, forwards, and other currency derivatives: > Special Client Order Instructions, acting in accordance with client direction, is considered of the highest importance when seeking to meet client expectations. The nature of the order remains another key consideration. > Price is considered a key measurable factor when assessing best execution. Price is considered on an all-in basis (Spot Rate + Points). > Likelihood of execution and settlement is a key criteria when executing forward currency trades (Deliverable and Non-Deliverable Forwards). Currency Forwards trades can only be executed with counterparts who are approved and have the required documentation in place (ISDA agreements). > The extended settlement cycle of these instruments also means that counterparty exposure and risks are a key criteria when trading. The size of the trades and inherent underlying volatility elevates the counterparty risk as a criteria for consideration. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 6

(G) EQUITY DERIVATIVES - (I) OPTIONS AND FUTURES ADMITTED TO TRADING ON A TRADING VENUE PROPORTION OF Y PASSIVE AGGRESSIVE DIRECTED Goldman Sachs International 88.3% 90.1% N/A N/A 0.0% Danske Bank 11.7% 9.9% N/A N/A 100.0% Execution Factors Equity Derivatives Options and Futures admitted to trading on a trading venue: > Special Client Order Instructions, acting in accordance with client direction, is considered of the highest importance when seeking to meet client expectations. The nature of the order remains another key consideration. > The nature of the order as received from the Investment Decision Maker is the next most important criteria for consideration > The infrequent nature, instrument types and size of these orders mean that Price is considered the key measurable factor when assessing best execution. > Likelihood of execution and settlement is a key criteria when executing. These instruments are cleared and subject to initial and daily variation margin and there is a prerequisite for operational setup and documentation. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 7

(H) SECURITISED DERIVATIVES - (I) WARRANTS AND CERTIFICATE DERIVATIVES PROPORTION OF Y PASSIVE AGGRESSIVE DIRECTED Credit Suisse International 52.3% 59.0% N/A N/A 0.0% Morgan Stanley International 47.7% 41.1% N/A N/A 0.0% Execution Factors Securitised Derivatives Warrants and Certificate Derivatives: > Client Order Instruction and the Nature of the Order retains the highest order of importance. > Securitised Derivatives can only be executed with counterparts who are approved and have the required documentation in place and operational procedures in place. > Price is considered a key measurable factor when assessing best execution. > Likelihood of execution and settlement is a key criteria when executing Securitised Derivatives. > The extended holding period lifecycle f these instruments also means that counterparty exposure risk is a key criteria when trading. The size of the trades and inherent underlying volatility elevates the counterparty risk as a criteria for consideration in these fully cash settled instruments. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 8

(K) EXCHANGE TRADED PRODUCTS (EXCHANGE TRADED FUNDS, EXCHANGE TRADED NOTES AND EXCHANGE TRADED COMMODITIES) PROPORTION OF Y PASSIVE AGGRESSIVE DIRECTED Goldman Sachs International 90.1% 91.7% N/A N/A 0.0% Credit Suisse International 9.9% 8.3% N/A N/A 0.0% Execution Factors Exchange traded products (Exchange traded funds, exchange traded notes and exchange traded commodities): > Client Order Instruction and the Nature of the Order retains the highest order of importance. > The infrequent nature, instrument types and size of these orders mean that Price is considered the key measurable factor when assessing best execution. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 9

(M) OTHER INSTRUMENTS NON-EEA EQUITIES THAT ARE NOT TRADED ON A TRADING VENUE PROPORTION OF N CLASS TOTAL EQUITY VOLUMES: 1.87% PASSIVE AGGRESSIVE DIRECTED CLSA 64.2% 59.4% N/A N/A 0.0% Credit Suisse International 30.6% 34.5% N/A N/A 0.0% Bank of America Merrill Lynch 5.2% 6.1% N/A N/A 0.0% Execution Factors Other instruments Non-EEA Equities that are not traded on a trading venue : > The same factors that apply to EEA Equities that are traded on a trading venue apply to foreign equities. Please refer to the distinctions made in relation to liquid and illiquid equities in the earlier tables. GENERATION INVESTMENT MANAGEMENT LLP 2018 Page 10