Order Execution Disclosure Statement

1. Introduction

The Order Execution Disclosure Statement, herein, summarises certain procedures and practices adopted by MMPI Limited (“MMPI”, “the Company”, “we”, “us”, “our”) in order to comply with the requirements of the Central Bank of Ireland, the Markets in Financial Instruments Directive II (MiFID), Market Abuse Regulations, Consumer Protection Code and best industry practice relating to the handling of client orders and acting in the client’s best interests. The policy, herein, applies to all Directors, Senior Managers and employees of the Company.

This Disclosure Statement relates explicitly to the execution of client orders in transferrable securities and other financial instruments, as appropriate, and is intended to meet the requirements and obligations of the Company under the provisions of the EU Market in Financial Instruments Directive II (“MiFID”). We have a duty of care to conduct our business with you in an honest, fair and professional manner and to act in your best interests when executing orders.

2. Scope of Activities

When executing transactions with you, MMPI will take all sufficient steps to achieve the best possible result for you by executing your order in accordance with our Order Execution Policy, which comprises a set of procedures that are designed to obtain the best possible execution result, taking into account the nature of your order, the priorities you have identified to us in relation to filling of your order and the practices relating to specific markets producing a result that provides, in our view, the appropriate balance across a range of possible conflicting factors. This Disclosure Statement provides a summary of our Order Execution Policy.

3. Client Orders & Specific Instructions

MMPI is required to have procedures and arrangements in place that provide for the prompt, fair and expeditious execution of client orders unless the characteristics of the order or the prevailing market conditions make this impracticable or the interest of the client requires otherwise. MMPI is also required to consider the need to manage any potential conflicts of interest between clients and/or between MMPI and our client.

MMPI is deemed to be in receipt of a Client Order when a client gives us a trading instruction that requires MMPI to act on the client’s behalf in relation to the pricing or other aspect(s) of the transaction that may be affected by how MMPI executes the order.

4. Execution Factors

It is acknowledged that the importance and relevance of the various factors of order execution may vary from time-to-time, particularly in relation to volatile market conditions. However, it is recognised that price will, in the normal course, merit a high relative importance in obtaining the best possible result in the execution of a client order.

5. Execution Venues & Instruments

MMPI will place client orders with regulated entities that have the necessary authorisations to transact such orders on recognised, authorised exchanges. MMPI relies on its appointments with regulated stockbrokers and regulated market-facing entities to execute client orders. These are the execution venues to which MMPI is exposed and through which all client orders are routed. MIFID II does not prohibit MMPI from selecting only one execution venue to execute client orders once we can demonstrate that such a choice enables us to get the best results for our clients on a consistent basis. MIFID II requires us to determine whether or not suitable venues exist. Reports published under RTS 28 or Article 65(5) of the MiFID II Delegated Regulation are intended to provide the public with valuable data and help investors select the firms they want to work with. MMPI will publish this information on or before 30th April following the end of the period to which the report relates.

When choosing regulated stockbrokers and regulated market-facing entities MMPI will be influenced by the performance consistency and the service reliability of the broker/entity. This may not always result in the most favourable price being obtained but we will be consistent with the execution of client orders in accordance with MMPI’s Order Execution Policy. MMPI will provide a summary of the analysis and conclusions we draw from our detailed monitoring of execution quality in relation to each class of financial instrument. The aim is to provide clients with meaningful information in order to effectively assess and scrutinise the execution quality achieved by MMPI during the year.

In relation to some financial instruments, there may be only one possible execution venue and/or only one regulated stockbroker or regulated market-facing entity that has the necessary permissions or expertise to execute an order. Where MMPI executes a client order in such circumstances it will be assumed that the Company has acted in good faith and has achieved best execution.

6. Monitoring of Order Execution

MMPI will monitor the effectiveness of its order execution arrangements and Order Execution Policy. The Company will assess from time to time whether the execution venues used continue to provide optimal arrangements for best execution on a consistent basis. If any deficiencies are detected MMPI will take all appropriate remedial action so that we can verify that we have taken “all sufficient steps” to achieve the best possible results for our clients.

MMPI will review its order execution arrangements and Order Execution Policy in respect of material changes in one of our chosen execution venues that affect our ability to continue to achieve best execution. Should there be any material changes to MMPI’s order execution arrangements or Order Execution Policy the Company will post the changes on its website – www.mmpi.

7. Consent & Communication

This disclosure statement forms part of MMPI’s terms of business. Therefore, by agreeing to the terms of the MMPI Standard Client Agreement, you are also agreeing to the terms of the MMPI Order Execution Policy, as summarised in this document.


Order Execution Disclosure Statement v6.0 Jan 2018

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