RTS28 Report

Monitoring and Review

• We operate in accordance with our best execution policy. Please refer to our website if you want to see a copy of our policy.
• Under the terms of our policy, we regularly assess the third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging for the execution of your orders.
• The third parties that we use, also have responsibilities in relation to best execution and client order handling. We undertake periodic monitoring to make sure that they continue to meet our requirements. This review is carried out at least annually or whenever a significant change occurs that we feel could affect our ability to continue to obtain the best possible results for our clients.

OBS 11 Annex1 EU Regulatory Technical Standard 28 (RTS 28) Article 3(3) (a) an explanation of the relative importance the firm gave to the execution factors of price, costs, speed, the likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution;

In the absence of express instructions from the client, PortfolioMetrix will exercise its own discretion in determining the relative importance it assigns to the execution factors (or the process by which it determines their relative importance) that it needs to take into account for the purposes of providing the client with the best possible result.

Exchange-Traded Products

PortfolioMetrix will instruct the platform to execute an Exchange Traded Product order. This will be filled in accordance with the platform’s best execution policy.

When acting as investment manager to an authorised fund (e.g. UCITS), PortfolioMetrix executes its Exchange Traded Products through Direct Market Access (‘DMA’). PortfolioMetrix instructs DMA which fund the trade is for and which instrument to trade, quantity and order type (e.g. market). DMA subsequently seek quotes from a number of brokers and transacts according to their best execution policies (including carrying out the required regulatory reporting). The following factors are taken into account:

Costs: PortfolioMetrix will always pay due regards to the costs related to any execution to ensure that the costs will not jeopardise the end result.

Likelihood of execution and settlement: PortfolioMetrix considers that for illiquid securities, the likelihood of execution may take precedence over price and speed.

Nature of order: PortfolioMetrix will consider how the characteristics of the transaction can impact how best execution is achieved.

Price: PortfolioMetrix will generally consider that price merits high importance, however, the nature of securities will determine if PortfolioMetrix shall give precedence of other factors such as speed or likelihood depending on the security characteristics.

Size of order: PortfolioMetrix considers the size of the transaction and how it may impact the price of execution.

Speed: PortfolioMetrix considers that for exchange-traded products, speed is paramount taking into account the fact that markets tend to move quickly, i.e. the price of the security may vary significantly.

Timing: PortfolioMetrix understands that certain exchange-traded products are likely to be more liquid at different times of the day and will thus discuss these intricacies with parties that will be more familiar with this matter (both with DMA and the exchange-traded product provider) which should also affect of the factors listed above.

(b) a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders;

PortfolioMetrix does not have any close links, conflicts of interests or common ownerships with respect to any execution venues used to execute orders. Execution of retail client orders takes place via platforms or via DMA (and, by extension Tourmaline Europe LLP) for the ETF trades. They provide a direct market access function. We undertake an annual platform review to ensure we are accessing the best platforms available to our clients. We continually monitor the brokers we use by regularly reviewing the order execution quality achieved and the broker’s ability to trade effectively on our and our client’s behalf.

(c) a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received;

PortfolioMetrix does not have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.

(d) 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;

N/A

(e) 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;

All of PortfolioMetrix’s clients are treated equally with respect to order execution.

(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;

Retail client trades are actioned upon instruction by our investment managers or clients, dependent upon the advice basis, within a reasonable timeframe. The trade is always therefore subject to the current price available upon instruction. Price, costs and therefore total consideration achievable are always the highest priority when the trade is able to be executed.

(g) an explanation of how the investment firm has used any data or tools relating to the quality of execution obtained from the execution venues used to place client orders for execution, with the use of quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS 27];

N/A