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Whitman Howard Limited Best Execution Report 2020

Whitman Howard Limited Best Execution Report (RTS 28 Report) – 30 April 2020

Whitman Howard Limited (“WH”) is an institutional stockbroking firm providing agency brokerage execution for institutional clients. WH only trades Equity instruments and only has clients who have been classified as Professional clients.

What is best Execution?

MiFID II requires that all sufficient steps are taken to obtain the best possible result for professional clients (Professional Clients) within the meaning of Annex II of MiFID II, when executing orders (or receiving and transmitting orders to a third party) on their behalf in respect of financial instruments (Best Execution), taking into account 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 (Execution Factors).

Best Execution does not mean that we can guarantee that the best price will be achieved for every single client order. However, we will look to ensure that we are acting, to the extent that it is possible, in the best interests of our clients.

RTS 28 Annex Disclosures Report

Top Five Execution venues:

WH has entered into a Trading and Settlement Agreement with Societe Generale, London Branch (“SG”). Accordingly all trading activity of WH is directed to SG and as such WH only has one trading execution venue.

Class of instruments
Equities – Shares and Depositary Receipts

Notification if <1 average trade per business day in the previous year

Top Five Execution venues ranked in terms of trading volumes
Societe Generale

Proportion of Volume trades as a percentage of total in that class

Proportion of Volume trades as a percentage of total in that class

% of Passive orders

% of Aggressive orders

% of Directed orders

In accordance with RTS 28 WH sets out below for the only class of financial instruments it traded namely equities, a summary of the analysis and conclusions we draw from their detailed monitoring of the quality of execution obtained on the execution venues where we executed all client orders in 2018:

  1. 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:
    WH has established and implemented transaction execution arrangements that are designed to allow the firm to take all reasonable steps to obtain the best result when executing or placing orders on behalf of its clients.

  2. a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders;
    WH has no common ownerships, close links or other conflicts of interest with any of our execution venues. Counterparties are obliged to provide us with best execution when acting as our broker.

  3. a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received;
    In consideration of the services provided by SG under the Trading and Settlement Agreement WH pays SG a service fee at a rate agreed between the parties from time to time. No other specific arrangements have been made with any execution venues regarding payments made or received, discounts, rebates.

  4. 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;
    No such change occurred.

  5. 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;
    Our order execution does not alter for trading purposes as all our clients are categorised as Professional Clients.

  6. 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;
    WH does not have Retail Clients.

  7. an explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Commission Delegated Regulation (EU)
    WH has considered the Best Execution policy of SG when selecting them as the Trading and Settlement agent to ensure it can meet WH's best execution requirements. WH also reviews the RTS 28 Annex disclosures provided by SG to ensure the quality of execution by SG.

  8. where applicable, an explanation of how the investment firm has used output of a consolidated tape provider established under Article 65 of Directive 2011/65/EU.

N/A - No consolidated tape providers in use across the industry at present.

Further information

Further information is available from Whitman Howard.