The European Securities and Markets Authority (ESMA) requires investment firms to publish, on an annual basis, information on the identity of execution venues and the quality of execution obtained.  This reporting requirement falls under MiFID II (Markets in Financial Instruments Directive) which is a European Union law that aims to standardise regulation for investment services across all member states of the European Economic Area.

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Under MiFID II there are a number of Regulatory Technical Standards (RTS) which investment firms are required to implement. RTS 28 outlines the requirements designed to increase transparency related to executing client orders on trading venues intended to improve investor protection.

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Investment firms such as SAFE CAPITAL INVESTMENTS LTD are required to adhere to RTS 28 in respect of their MiFID II business activities.  These are required to publish information on the top five execution venues in terms of trading volumes where they executed client orders in the preceding year and information on the quality of execution obtained for each class of financial instrument. The information provided in this report is for professional clients. The Company does not provide its investment services to retail clients.

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SAFE CAPITAL INVESTMENTS LTD places orders to be executed with approved counterparties. A list of counterparties is found in the firm’s Best Execution Policy. The list is reviewed and updated as necessary by the portfolio management teams. The Best Execution Policy is reviewed and adhered by the Investment Committee and ultimately at the responsibility of the Board of Directors. Any concerns should be raised with the firm’s management or Compliance Officer.

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Under RTS 28, relevant reporting is in a prescribed format on an annual basis within deadlines set under the regulations. This information is provided in a machine-readable format and available for downloading hereunder.