January 2018

Purpose of the Policy:

In accordance with the ‘EU Markets in Financial Instruments Directive II’ (“MiFID II”), Hobart Capital Markets LLP (“Hobart”) is required to take all sufficient steps to obtain the best possible result when executing orders on behalf of its clients (“Best Execution”).

Accordingly, Hobart has in place an ‘Order Execution Policy’, which applies to our clients and is operated when executing clients’ orders and/or receiving and transmitting orders for execution.

This Order Execution Policy forms an integral part of Hobart’s Terms and Conditions of Business.

 

Venues of Execution:

Hobart uses certain electronic trading platforms that have access to a large number of markets and venues, many of which have arisen in the post MiFID environment. These markets and venues include primary exchanges, Multilateral Trading Facilities (“MTFs”), ‘Dark Pools’ (private securities exchanges used to trade anonymously) and Systematic Internalisers

Access to these venues is achieved via Direct Market Access (“DMA”) agreements with other regulated entities or via local brokers, who also have an obligation to provide Best Execution.

Hobart’s choice of DMA provider(s) is reviewed regularly to determine who is offering access to suitable venue(s), in order for Hobart to ensure that it complies with its MiFID II  requirements, in ensuring client’s Best Execution needs are being met.

Venues may be restricted where we have agreed to do so with specific clients.

 

Selection of Execution Venue:

Hobart takes into consideration a number of different factors when selecting the venue(s) on which to execute client orders:

  • Price: The relative importance we attach is high. We will consider whether the venue provides competitive prices for the different sizes of client orders. Information sources such as Bloomberg and Thompson Reuters may be used to determine best price.
  • Speed of Execution: In order to protect clients from adverse price movements in highly volatile markets, Hobart will consider the speed at which the venue can execute transactions.
  • Complexity of Orders: Hobart will consider whether the venue can handle the typical types of complex orders received from our clients, such as limit orders and volume weighted average price orders that may be filled over the course of the day.
  • Likelihood of Execution:Hobart selects the execution venues to endeavour to ensure that we obtain access to the pools of liquidity most likely to facilitate execution of our trades.

Hobart may also choose to ‘cross’ an order between clients, where Hobart believe Best Execution can be met.

 

Carrying Out Execution:

When applying our Order Execution Policy, we use established electronic systems to access the venue(s) we have selected. We may also use Smart Order Routers and Algorithmic trading engines where it is appropriate.

The systems that we use do not distinguish, and therefore do not discriminate, between orders for any client, which helps ensure Best Execution for all orders and clients.

 

Monitoring:

Hobart monitors the effectiveness of our execution venue(s), DMA provider(s) and Order Execution Policy to identify and, where appropriate, correct any deficiencies.  The review of DMA provider(s) and venues used takes place at least once every 2 months.

The effectiveness of our Smart Order Routers used is reviewed monthly by comparing price executed against available venue liquidity and pricing.

 

Consents:

Under MiFID, Hobart is required to obtain your express consent before we trade outside a Regulated Market or Multilateral Trading Facility. Unless you advise us, in writing, to the contrary, Hobart will consider your acceptance of this Order Execution Policy as including your express consent to trade outside a Regulated Market or Multilateral Trading Facility.

 

Reports:

Hobart will publish, on an annual basis, our top five execution venues for the previous year, along with specific data relating to the quality of execution of transactions on that venue in accordance with RTS 28 of MiFID II. These reports will be published on our website. www.hobartcapital.com/regulatory.