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Policy – RTS 28 Disclosure

RTS 28 Disclosure

As part of the MiFID II best execution requirements, Global Shares Execution Service Limited (“GSESL”) is required to publish on its website the top five execution venues and information on the quality of execution obtained. Please see below a report on the top five counterparties used and a qualitative assessment from the monitoring on the quality of the execution.


Class of InstrumentEquities – Shares & Depositary Receipts (Tick size 1&2)
Top five execution venues ranked in terms of trading volumes (descending order)Proportion of volume traded as a percentage of total in that classProportion of orders executed as a percentage of total in that classPercentage of passive ordersPercentage of aggressive ordersPercentage of directed orders
HSBC CONTINENTAL EUROPE – F0HUI1NY1AZMJMD8LP6747.40%40.30%0.00%0.00%0.00%
SMBC Nikko Securities Inc – 549300HIK4TTS0OCL43712.83%2.95%0.00%0.00%0.00%
MIZUHO INTERNATIONAL PLC – 213800HZ54TG54H2KV031.09%1.47%0.00%0.00%0.00%
Maxim Group LLC 254900OJ6JZO6SDMHQ831.90%0.71%0.00%0.00%0.00%
Above top 5 brokers, covers majority of our executing brokers, where our orders are traded through

Quantitative Report 2023

Quantitative Report 2023


This assessment contains a summary of the analysis and conclusions Global Shares have drawn from its monitoring of the quality of execution.

RTS 28, Article 3(3) Reference
An explanation of 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.The primary factor in the assessing the quality  of execution is determined in terms of the total consideration of the trade, representing the price of the financial instrument and all costs and expenses relating to the execution (such as execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order). The size the order, the likelihood of execution and settlement, the speed of execution and nature of the order are also factors taken into consideration.
A description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute ordersThere are no close links, conflicts of interests or common ownership with respect to any of the counterparties used to execute orders.
A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.Global Shares does not have any arrangements with execution venues other than their standard execution terms and commissions with brokers.
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.GSESL does not undertake direct market access. GSESL utilises brokers to access market venues therefore this is inapplicable.
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.Global Shares does not differentiate on client category when executing client orders.
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.In some instances, liquidity of the security is taken into consideration when executing the order and therefore the immediate price and cost may be considered in the context of obtaining the best execution.
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) 201575 [RTS 27]Global Shares receives and reviews the best execution reports provided by the executing brokers on a monthly basis and through the support of a third-party provider, Steeleye, Global Shares, reviews any Best Execution exceptions, as and when they arise.
Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider established under Article 65 of Directive 2014/65/EUNot applicable.