Best Execution

Best Execution Reporting Method

Pamplona Capital Management LLP (hereinafter “the Firm”) is an investment manager providing portfolio management services, and reception and transmission services, for its clients. Under MIFID II, the Firm is required to adhere to a best execution policy, and in support of that policy, publish on its website the top five execution trading venues by trading volume on an annual basis. Trading venues include regulated markets, Multilateral Trading Facilities (MTFs), Organised Trading Facilities (OTFs), Systematic Internalisers (SI), market makers or other liquidity providers or entities that perform a similar function in a third country.

MIFID II Article 3(1) sets out that firms must disclose the following, excluding securities financing transactions (SFTs):

1) class of financial instruments*;
2) venue name and identifier;
3) volume of client orders executed on that execution venue expressed as a percentage of total executed volume;
4) number of client orders executed on that execution venue expressed as a percentage of total executed orders;
5) percentage of the executed orders referred to in point (d) that were passive and aggressive orders;
6) percentage of orders referred to in point (d) that were directed orders;
7) confirmation of whether it has executed an average of less than one trade per business day in the previous year in that class of financial instruments.

*RTS28 Annex I Lists the Classes of financial instruments as:

(a) Equities – Shares & Depositary Receipts
(i) Tick size liquidity bands 5 and 6 (from 2000 trades per day)
(ii) Tick size liquidity bands 3 and 4 (from 80 to 1999 trades per day)
(iii) Tick size liquidity band 1 and 2 (from 0 to 79 trades per day)
(b) Debt instruments
(i) Bonds
(ii) Money markets instruments
(c) Interest rates derivatives
(i) Futures and options admitted to trading on a trading venue
(ii) Swaps, forwards, and other interest rates derivatives
(d) credit derivatives
(i) Futures and options admitted to trading on a trading venue
(ii) Other credit derivatives
(e) currency derivatives
(i) Futures and options admitted to trading on a trading venue
(ii) Swaps, forwards, and other currency derivatives
(f) Structured finance instruments
(g) Equity Derivatives
(i) Options and Futures admitted to trading on a trading venue
(ii) Swaps and other equity derivatives
(h) Securitized Derivatives
(i) Warrants and Certificate Derivatives
(ii) Other securitized derivatives
(i) Commodities derivatives and emission allowances Derivatives
(i) Options and Futures admitted to trading on a trading venue
(ii) Other commodities derivatives and emission allowances derivatives
(j) Contracts for difference
(k) Exchange traded products (Exchange traded funds, exchange traded notes and exchange traded commodities)
(l) Emission allowances
(m) Other instruments

The top five execution trading venues by trading volume for the years ended 31 December 2018 and 31 December 2019 can be accessed by clicking HERE

Best Execution Confirmation

For the year ending 2019 we confirm that there were no material close links, common ownership or conflicts of interest between us and the brokers used by the Firm. Brokers are paid on a pre-agreed cost per transaction. In this period no changes were made to the brokers used. We do not receive any discount, rebates or non-monetary benefits on these services. We may on occasion receive short term market colour from our execution providers. All our clients are categorised as professional clients under Article 4(1)(10) of Directive 2014/65.

The Firm may use broker Transaction Cost Analysis (TCA) reports and internal analysis to monitor the quality of execution against our best execution criteria. We conduct regular reviews of our chosen brokers against our Order Execution Policy, and may at our discretion, remove those which we believe are no longer offering us best execution.

During the period under review, ‘price’ and ‘costs’ were the chief execution factors used in determining whether the best possible result was obtained for each transaction.  However on occasion the firm may select another execution factor(s) with a view to achieving the best possible result.