For the period 1 January 2017 – 31 December 2017
Verno Capital UK LLP
There were no conflicts of interest, no specific arrangements for discounts, rebates or non-monetary benefits. No trading was executed on an exchange directly. There was no difference in order execution based on client category. The only clients were professional investors, so there were no retail client orders. No data or tools were used in relation to quality of execution and there was no use of output from a consolidated tape provider.
The relevant execution criteria were price, liquidity and order confidentiality. The firm maintains an approved broker list. Any changes to the list are approved by the Risk Committee which includes senior management of the firm. Two brokers stopped providing services and one broker was removed as no longer required. There were some changes in types of trading with brokers due to MIFID II.
A review of the brokers was carried out internally using 10 factors. The top five brokers in the internal review differed to those in Table 2 as approximately 75% of our trading is dictated by liquidity/availability of the security, which is the most important factor in our best execution.
During the year there was a single derivatives broker with an ISDA in place and one other broker that was used on an ad hoc basis only where necessary.
There were no bond trades executed during the year and so no review was performed.
We are satisfied in the circumstances we have met our obligation to serve the best interest of our clients on a consistent basis.