Reporting Date as at 31st December 2023

 

Prepared by: Diaman Partners Ltd

 

MiFID II Top 5 Venue Reporting Commentary

 

The Markets in Financial Instruments Directive - MiFID II mandates that investment firms, as part of their best execution obligations, report their top five venues for all trading on behalf of clients. Firms are required to make an annual public disclosure detailing these order routing practices for retail and professional clients across all asset classes.

 

Requirement of the Directive

 

Best execution rules are intended to protect investors by ensuring that investment firms seek the best possible result for their clients, taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.

 

For each class of financial instruments, Investment firms are to publish a summary of the analysis and conclusions they draw from their detailed monitoring of the quality of execution obtained on the execution venues where they executed all client orders in the previous year. The below commentary is applicable to all classes of financial instruments, unless otherwise specified.

 

(A) 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 importance of the various execution factors stipulated by the Rules will vary depending on the circumstances and context of the order. The main execution factors we consider in normal market conditions are price, costs and size.

In conditions where the market is poorly liquid, the main execution factors we consider are price, cost and likelihood of execution.

 

(B) Description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders

 

Diaman Partners Ltd does not have any close links, conflicts of interests or common ownerships with respect to any execution venues used to execute orders.

 

(C) Description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received

 

Diaman Partners Ltd does not have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non‐monetary benefits received.

 

 

(D) 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.

 

No changes during the year 2023

 

 

(E) 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.

 

All Diaman Partners Ltd‘s clients are treated the same under its Best Execution Policy.

 

(F) 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

 

Diaman Partners Ltd does not execute retail client orders

 

(G) Explanation of how the investment firm has used any data or tools relating to the quality of execution

 

During 2023, Diaman Partners Ltd has regularly monitored the quality of execution obtained from the custodian banks used to place the orders. Each trade is monitored by the portfolio manager when placing the trade instruction to ensure that it is executed on the best terms available.

 

(H) Explanation of how the investment firm has used output of a consolidated tape provider

 

Not applicable