MIFID II RTS 28 Publication 2019 on venue commodity derivatives

 Quality of Execution Summary – Calendar Year 2019

1. Out of the execution factors of price, costs, speed, likelihood of execution and settlement, size and nature of the order and any other consideration relevant to the execution of orders, Triland Metals Limited (“TML”) generally assigned price as the most important execution factor in relative terms. Price was followed by likelihood of execution and settlement, particularly in light of liquidity considerations relevant in some of our markets. Any other execution factor was given equal relative importance when assessing the quality of execution.
2. TML has no close links or common ownerships with respect to any of the execution venues specified in the table above. TML is unaware of any facts or circumstances that are reasonably likely to give rise to conflicts of interest with respect to any of the above execution venues to the detriment of its clients. TML is, however, a holder of a certain amount of “B” shares issued by the London Metal Exchange (“LME”), which grant TML trading rights on the LME. These shares have a monetary value but do not entitle TML to any dividends declared by the LME or grant TML any voting rights.
3. TML is liable to pay trading and clearing fees to the venues specific above (or to an entity with close links therewith) at such rates specified by them from time to time for any transactions traded and/or cleared on such venues. These fees also apply to any business executed by TML on behalf of clients. TML may charge similar fees to its clients at rates disclosed by TML to such clients. Further, TML is liable to pay licence and similar fees to the above venues for use of any of their intellectual property rights (e.g. market data) at rates determined by the venues from time to time. Finally, TML is liable to pay annual membership fees to the above venues in order to remain as a member of them. TML did not receive any remuneration, discount or non-monetary benefits for routing orders to the above execution venue.
4. No changes occurred in respect of the list of execution venues listed in TML’s order execution policy during the period to which this publication relates.
5. TML does not execute orders for, or conduct any other business with, any persons or entities that would be classified as “retail clients” under the rules of the Financial Conduct Authority (“FCA”). TML only executes orders for and conducts business with persons or entities that are classified as “professional clients” or “eligible counterparties” under the rules of the FCA. When executing orders on behalf of professional clients, TML complies with its best execution obligations under the relevant rules of the FCA. Such obligations do not apply where TML executes orders for eligible counterparties.
6. TML uses different data and tools to monitor and assess the quality of execution achieved when executing orders on behalf of clients. These include exception reporting by front office staff who execute orders on behalf of clients and comparing the prices of executed orders with prices prevailing on the relevant market for the relevant contracts, as published by the above execution venues and/or data tools provided by third party service providers engaged by TML. Information on quality of execution based on the foregoing data is provided to senior management on a regular basis.