RTS 28 BEST EXECUTION DISCLOSURE

Anavon Capital

RTS 28 BEST EXECUTION DISCLOSURE

YEAR TO 31 DECEMBER 2018

Introduction

Regulatory Technical Standard 28 requires Anavon Capital ( the Firm ) publishes on its website annually a review of its trade execution arrangements, covering the specific matters set forth under the headings below.

The Firm is a discretionary investment manager and may execute the decisions it makes to trade on behalf of its clients either directly on the execution venues set out in the Firm’s best execution policy, or via execution brokers who it selects for their ability to deliver “best execution” taking into account the execution factors that the Firm considers to be most important in the attainment of best execution.

Which instrument categories are covered by this report?

The Firm makes discretionary investment decisions for professional clients (unregulated and regulated fund vehicles). The strategies managed by the Firm utilise the following investments to deliver long term growth for clients:

Equities and Contracts for Difference s (CFD’s)

Unless otherwise stated, this report covers all of the instrument types above.

Importance of the relevant execution factors

The Firm’s investment strategy is global long short equity. The strategy is biased towards developed markets and analysable sectors with a focus on liquid, large or mid cap stocks. The Firm employs deep fundamental research to seek out individual long and short opportunities.

Consequently, the most important execution factors are price, size and nature of the order which influence the likelihood of execution, speed and costs.

These help to achieve best execution in the context of the investment strategy by Anavon Capital.

Close links, conflicts and common ownerships

The Firm has no “close links” (as defined by the Financial Conduct Authority), conflict or common ownerships with any execution venue or executing broker that it uses to execute its discretionary investment decisions made on behalf of clients.

Payments, discounts, rebates and non-monetary benefits

The Firm has not received any payments, discounts or non-monetary benefits from the trading venues or brokers used to execute trades on behalf of its clients.

Factors leading to a change in execution venues used

There have been no changes to the execution venues used during the period.

Do we view the execution factors differently depending on the client type?

All of the Firm’s clients are professional clients, either regulated and unregulated collective vehicles or individual managed accounts for individual professional investors. All investors are seeing access to the core strategy of the Firm as described above.

Changes to Execution Venues and Brokers

The Firm continually assesses the list of counterparties to ensure we obtain the best execution. There were no changes during 2017.


The Firm’s use of execution quality data/tools

The Firm uses Transaction Cost Analysis tools to assess execution quality. This system primarily considers implementation shortfall as well as highlighting outlying trades where costs deviated significantly from the pre-trade analysis.

The Firm’s use of consolidated tape providers

The Firm did not use any consolidated tape providers in determining “best execution” during the year.

Anavon Capital is satisfied that it has adhered to its best execution policy during 2018


Quantitative Analysis

This disclosure if being made pursuant to Article 3(1) of RTS 28, which require firms to disclose, for each class of financial instruments traded

during the period, the top 5 venues or counterparties on/with which client orders were executed.


Class of Instrument

Currency derivatives – Swaps, forwards, and other currency derivatives

Notification if < 1 average trades per business day in the previous year

No

Top five execution venues ranked in terms of trading volumes (descending order)

Proportion of volume traded as a percentage of total in that class

Proportion of orders executed as a percentage of total in that class

Percentage of passive order

Percentage of aggressive orders

Percentage of directed orders

Morgan Stanley & Co International Plc (4PQUHN3JPFGFNF3BB653)

73.17%

74.60%

-

-

100%

Goldman Sachs International (W22LROWP2IHZNBB6K528)

26.83%

25.40%

-

-

100%

Class of Instrument

Equities – Shares & Depositary Receipts

Notification if < 1 average trades per business day in the previous year

No

Top five execution venues ranked in terms of trading volumes (descending order)

Proportion of volume traded as a percentage of total in that class

Proportion of orders executed as a percentage of total in that class

Percentage of passive order

Percentage of aggressive orders

Percentage of directed orders

Morgan Stanley & Co International Plc (4PQUHN3JPFGFNF3BB653)

53.11%

49.19%

-

-

100%

Goldman Sachs International (W22LROWP2IHZNBB6K528)

37.68%

38.92%

-

-

100%

Sanford Bernstein (54930049G8WQ5OOUSD19)

7.17%

8.29%

-

-

100%

Goodbody (635400IL71G3SXS7OE16)

0.99%

0.54%

-

-

100%

Barclays Capital Securities Limited (K9WDOH4D2PYBSLSOB484)

0.48%

1.62%

-

-

100%