Execution model Requirements under Article 3(3)

In accordance with the requirements of the Markets in Financial Instruments Directive (MiFID II), investment firms that execute client orders are required to summarise and publish the top five execution venues based upon trading volumes for each class of financial instrument in the preceding year, as well as information on the quality of execution obtained. This information is based upon the average daily number of trades over the period. GPIM’s RTS 28 report is for the period 3rd December 2018 to 31st December 2018, this represents the period for which GPIM was directly authorised by the FCA during 2018, in the period 1st January 2018 to 2nd December 2018 the firm was an appointed representative of Sapia Partners LLP and any disclosure under the RTS 28 requirement is available on Sapia Partners website www.lawsonconner.com.

RTS 28 Report – December 2018

We have included tables that display the top 5 execution venues currently used by GPIM Limited, to execute all client orders. The table is provided in the layout as required by the Commission Delegated Regulation (EU) 2017/576 of 8 July 2016 (regulatory Technical Standard (RTS) 28).

We have summarised below the information regarding GPIM Limited’s execution practices. GPIM Limited operates under a Model B clearing arrangement with Third Financial and Third Financial may execute bargains on our clients’ behalf and they may process orders on our behalf.

Requirements Under Article 3(3)

1. 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;

GPIM Response;

The factors that are most important in the achievement of best execution are price and size, these factors are heavily dependent upon each other as the price will be affected by the size of any intended transaction. Speed and likelihood of execution have similar impacts on the price achievable and speed may have a direct correlation to size depending upon the particular circumstances prevalent at the time.

2. A description of any close links, conflicts of interest, and common ownerships with respect to any execution venues used to execute orders;

GPIM Response;

GPIM limited does not have any common ownerships, close links or conflicts of interest in regard to any execution venues.

3. A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received;

GPIM Response;

GPIM Limited does not have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.

4. 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;

GPIM Response;

The firm regularly monitors and reviews the list of firms available as execution venues; it actively seeks new venues.

5. 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;

GPIM Response;

The execution policy treats all clients in the same manner.

6. 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;

GPIM Response;

No other criteria are given precedence over immediate price and cost when executing retail client orders.

7. An explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS 27];

GPIM Response;

The firm regularly monitors the quality of execution obtained from the venues used.

8. Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider.

GPIM Response;

This is not applicable.

GPIM Limited RTS 28 Table

Execution model Requirements under Article 3(3)

In accordance with the requirements of the Markets in Financial Instruments Directive (MiFID II), investment firms that execute client orders are required to summarise and publish the top five execution venues based upon trading volumes for each class of financial instrument in the preceding year, as well as information on the quality of execution obtained. This information is based upon the average daily number of trades over the period. GPIM’s RTS 28 report is for the period 3rd December 2018 to 31st December 2018, this represents the period for which GPIM was directly authorised by the FCA during 2018, in the period 1st January 2018 to 2nd December 2018 the firm was an appointed representative of Sapia Partners LLP and any disclosure under the RTS 28 requirement is available on Sapia Partners website www.lawsonconner.com.

RTS 28 Report – December 2018

We have included tables that display the top 5 execution venues currently used by GPIM Limited, to execute all client orders. The table is provided in the layout as required by the Commission Delegated Regulation (EU) 2017/576 of 8 July 2016 (regulatory Technical Standard (RTS) 28).

We have summarised below the information regarding GPIM Limited’s execution practices. GPIM Limited operates under a Model B clearing arrangement with Third Financial and Third Financial may execute bargains on our clients’ behalf and they may process orders on our behalf.

Requirements Under Article 3(3)

1. 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;

GPIM Response;

The factors that are most important in the achievement of best execution are price and size, these factors are heavily dependent upon each other as the price will be affected by the size of any intended transaction. Speed and likelihood of execution have similar impacts on the price achievable and speed may have a direct correlation to size depending upon the particular circumstances prevalent at the time.

2. A description of any close links, conflicts of interest, and common ownerships with respect to any execution venues used to execute orders;

GPIM Response;

GPIM limited does not have any common ownerships, close links or conflicts of interest in regard to any execution venues.

3. A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received;

GPIM Response;

GPIM Limited does not have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.

4. 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;

GPIM Response;

The firm regularly monitors and reviews the list of firms available as execution venues; it actively seeks new venues.

5. 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;

GPIM Response;

The execution policy treats all clients in the same manner.

6. 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;

GPIM Response;

No other criteria are given precedence over immediate price and cost when executing retail client orders.

7. An explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS 27];

GPIM Response;

The firm regularly monitors the quality of execution obtained from the venues used.

8. Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider.

GPIM Response;

This is not applicable.

GPIM Limited doesn’t interact with the order book and clients do not specify execution venue