January 2024


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 when executing orders take all sufficient steps to ensure the ‘best possible result’ for clients, taking into account price, size, speed, likelihood of execution and settlement, cost, nature or/any other factor relevant for the execution of a client order from Hobart.

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 multiple SOR’s (Smart Order Router’s) to a large number of markets and venues as well as various algorithmic trading strategies.  These markets and venues include primary exchanges, Multilateral Trading Facilities (“MTFs”), ‘Dark Pools’ (private securities exchanges used to trade anonymously) and Systematic Internalisers to constantly ensure Hobart is executing at the best price available at the time for our clients.

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 providers is reviewed regularly to determine who is offering access to suitable venues, in order for Hobart to ensure that it complies with its MiFID II requirements, in ensuring client’s Best Execution needs are being met.


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 compare the execution price of the trades with the consolidated best bid/offer or with recent prices across eligible venues at the time.

  • Size of Transaction:

The firm will consider the size of transaction when executing a client’s order. In certain circumstances, the firm might choose to execute part of an order when the overall benefit to the client exceeds that of executing the full amount at an adverse price.

  • Speed of Execution:

In order to protect clients from adverse price movements in highly volatile markets, Hobart use DMA providers that measure time that elapses between the algorithm making the trading decision and the venue’s response, measured in milliseconds or microseconds.  The execution of trades will be done in a timely matter to receiving the client order.

  • Nature / Complexity of Orders:

Hobart will consider the complexity of orders received from our clients, taking into account market liquidity, available venues, size of order or any limits.  Without any direct client instruction Hobart will determine the best trading strategy in order to minimize market impact.

  • Likelihood of Execution & Settlement:

Hobart’s SOR’s select the execution venue to endeavor to ensure that we obtain access to the pools of liquidity most likely to facilitate execution of our trades.

  • Cost of Execution:

While the firm endeavors to access as wide a range of venues as possible, some venues can be cost prohibitive. The firm will consider the cost of accessing a venue to ensure this does not outweigh the benefit to the client.

In situations where clients provide no specific execution instructions Hobart will generally give priority to the following execution factors: Price, Size, and Speed of Execution.

Hobart may also choose to ‘cross’ an order between clients, where Best Execution is being met.


Carrying Out Execution: 

When applying our Order Execution Policy, we use established electronic systems to access SOR’s 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.

Hobart’s Dealing Team will execute client orders using their discretion unless instructed otherwise by the client, with whom specific instructions and trading strategies can be arranged.



Hobart monitors the effectiveness of our execution venues, DMA providers and Order Execution Policy to identify and, where appropriate, correct any deficiencies. The review of is DMA providers and venues used takes place at least once every 3 months and we use a data-driven approach.

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



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.



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.