September 2026

1. Purpose

Hobart Capital Markets LLP (“Hobart” or “the Firm”) is authorised and regulated by the Financial Conduct Authority (“FCA”) and is subject to the requirements of the UK Markets in Financial Instruments regime (“UK MiFID”).

Under these requirements, Hobart must take all sufficient steps to obtain the best possible result when executing orders on behalf of clients, taking into account:

  • price;
  • costs;
  • speed;
  • likelihood of execution;
  • likelihood of settlement;
  • size;
  • nature of the order; and
  • any other consideration relevant to the execution of the order.

This document explains how Hobart seeks to achieve Best Execution when executing or transmitting client orders.

This Policy forms part of Hobart’s Terms of Business.

2. Scope

This Policy applies whenever Hobart executes, or transmits for execution, client orders in financial instruments covered by UK MiFID.

The Firm principally provides execution services to:

  • Retail Clients
  • Professional Clients

Eligible Counterparties

3. Business Model

Hobart is an institutional execution broker providing agency and riskless principal execution services to professional market participants. The firm also provides Execution-only and Advisory services to Retail clients.

The Firm provides execution across a broad range of international equity and fixed income markets.

Orders are executed using a combination of:

  • Direct Market Access (DMA)
  • Smart Order Routing (SOR)
  • Algorithmic execution strategies
  • Regulated brokers
  • Local market specialists

The Firm does not operate its own execution venue.

4. Best Execution Factors

When executing client orders Hobart considers a range of execution factors.

The relative importance of each factor depends upon:

  • characteristics of the client;
  • characteristics of the order;
  • characteristics of the financial instrument;
  • characteristics of available execution venues;
  • prevailing market conditions.

Execution factors include:

Price

For liquid securities price will normally receive the greatest weighting.

The Firm seeks to achieve the most favourable available execution price after considering all relevant execution costs.

Costs

Execution costs include:

  • exchange fees;
  • clearing costs;
  • settlement charges;
  • local broker commissions;
  • taxes;
  • venue access costs.

The Firm considers total consideration rather than execution price alone.

Speed

Speed may become the most important execution factor where:

  • markets are volatile;
  • liquidity is deteriorating;
  • clients request urgent execution.

Likelihood of Execution

For less liquid securities, the likelihood of obtaining execution may take precedence over obtaining the best quoted price.

The Firm may determine that partial execution represents the best outcome for the client.

Likelihood of Settlement

The Firm considers the reliability of counterparties, settlement arrangements and post-trade infrastructure when selecting execution venues.

Size

Large orders may require:

  • partial execution;
  • execution over time;
  • algorithmic execution;
  • execution across multiple venues.

Nature of the Order

The Firm considers:

  • order type;
  • trading instructions;
  • liquidity;
  • market impact;
  • confidentiality requirements.

5. Execution Venues

Orders may be executed through one or more of the following:

  • Regulated Markets
  • Multilateral Trading Facilities (MTFs)
  • Systematic Internalisers
  • Market Makers
  • Direct Market Access providers
  • Local Brokers
  • Other liquidity providers where appropriate.

Execution venues are selected according to their ability to deliver the best possible outcome for clients.

The list of approved execution venues is maintained separately by the Firm and is reviewed on an ongoing basis.

6. Smart Order Routing and Algorithms

The Firm makes use of Smart Order Routing technology and algorithmic trading strategies where appropriate.

These technologies assist in identifying appropriate sources of liquidity but do not replace Hobart’s responsibility to achieve Best Execution.

The Firm remains responsible for assessing the effectiveness of the routing and execution arrangements used.

7. Selection of Execution Venue

When selecting an execution venue the Firm considers:

  • available liquidity;
  • quoted prices;
  • transaction costs;
  • execution quality;
  • settlement arrangements;
  • market resilience;
  • operational reliability;
  • historical execution performance.

Different venues may be appropriate for different financial instruments and market conditions.

8. Client Instructions

Clients may provide specific execution instructions.

Where a client provides specific instructions, Hobart will execute the order in accordance with those instructions.

To the extent that Hobart follows specific client instructions, the Firm may be prevented from taking the steps that it would otherwise have taken to obtain the best possible execution result.

9. Crossing Client Orders

Where appropriate, Hobart may arrange for compatible client orders to be crossed.

Crossing will only occur where the Firm reasonably believes that doing so is consistent with achieving Best Execution for both clients.

The Firm manages any associated conflicts of interest in accordance with its Conflicts of Interest Policy.

10. Conflicts of Interest

The Firm selects execution venues solely on the basis of obtaining the best possible outcome for clients.

Venue selection is not influenced by:

  • commercial incentives;
  • rebates;
  • inducements;
  • ownership interests.

Conflicts relating to execution are managed under the Firm’s Conflicts of Interest Policy.

11. Monitoring

Hobart continually monitors the effectiveness of its execution arrangements.

Monitoring includes, where appropriate:

  • execution quality analysis;
  • execution venue performance;
  • Smart Order Router performance;
  • DMA provider performance;
  • exception reporting;
  • transaction cost analysis where available;
  • periodic reviews of execution quality.

Where deficiencies are identified, corrective action will be implemented promptly.

12. Governance

Responsibility for this Policy rests with the Compliance function.

Senior Management receives periodic management information regarding:

  • execution quality;
  • venue performance;
  • material execution issues;
  • policy breaches;
  • remedial actions.

This Policy is reviewed:

  • at least annually; and
  • whenever there is a material change affecting the Firm’s ability to obtain Best Execution.

13. Consent to Execute Outside a Trading Venue

Where permitted under applicable regulation, Hobart may execute transactions outside a Regulated Market, MTF or other trading venue.

By accepting the Firm’s Terms of Business and this Policy, clients provide their consent to such execution unless they notify Hobart otherwise in writing.

14. Record Keeping

The Firm maintains records sufficient to demonstrate compliance with this Policy, including records relating to:

  • execution decisions;
  • execution venue selection;
  • monitoring activities;
  • periodic reviews.

Such records are retained in accordance with applicable regulatory requirements.

15. Policy Review

The Firm reviews this Policy at least annually and whenever a material change occurs that may affect its ability to obtain the best possible result for clients.

Changes to this Policy will be communicated to clients where required.