Terms & Conditions

The contents of this website are issued in the United Kingdom by North of South Capital LLP (North of South) and are provided solely to give an introduction to North of South, its partners and its business. The information contained in this website may not be reproduced, distributed or published for any purpose without the prior written consent of North of South. North of South is authorised and regulated by the Financial Services Authority in the United Kingdom (the “FSA”) to carry on regulated activities in the UK. Any references to funds or products managed or linked to the group are for background purposes only, do not purport to be full or complete and do not constitute investment advice. This website does not constitute or form part of any offer to issue or sell, or any solicitation of an offer to subscribe or purchase, any investment nor shall it or the fact of its distribution form the basis of, or be relied on in connection with, any contract therefor. The information on this website is not intended as an offer to buy or the solicitation of an offer to sell any security and should not be relied upon by you in evaluating the merits of investing in any securities. No representation, warranty or undertaking, express or implied, is given as to the accuracy or completeness of the information or opinions contained in this website by any of North of South, its members, employees or affiliates and no liability is accepted by such persons for the accuracy or completeness of any such information or opinions. This information is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use is contrary to local law or regulation. Distribution of this information to any person other than the person that received a unique user name and password to access this website and to such person’s advisors is unauthorized and any reproduction of this information, in whole or in part, or the disclosure of any such information, in each such instance is prohibited. The information included herein is not intended to be complete, and material aspects of the descriptions contained herein may change at any time. If you express an interest in investing, you should carefully review the applicable offering memorandum and risk factors disclosed therein prior to making a decision to invest. You should rely only on the information contained in the offering memorandum in making your decision to invest. An investment will be suitable only for certain sophisticated investors who have no need for immediate liquidity in their investment. Such an investment will provide limited liquidity because interests in the fund will not be freely transferable and may be withdrawn infrequently and only under certain limited circumstances. There will be no public or secondary market for interests in the fund, and it is not expected that a public or secondary market will develop. Investing in financial markets involves a substantial degree of risk. There can be no assurance that the investment objectives described herein will be achieved. Investment losses may occur, and investors could lose some or all of their investment. Nothing herein is intended to imply that an investment in any fund may be considered “conservative,” “safe,” “risk free” or “risk averse.” No regulatory authority has passed upon or endorsed this summary or the merits of an investment in any fund. If you wish to receive information about our funds or other products] you should apply for a password by filling out a registration form found on the investor login page, or by contacting North of South directly. If you are a person to whom information about our funds may lawfully be provided under The Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 and Rule 4.12 of the FSA’s New Conduct of Business Sourcebook, you will be provided with a password. The products of the group are available only to certain sophisticated investors and any other persons may not rely upon the communications of the group.

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The Stewardship Code & Shareholder Rights Directive

  1. Stewardship Code

This Stewardship Code and Engagement Policy (the “Policy”) sets out how North of South Capital LLP, ( ‘NoS’ “we” or “us”) undertakes stewardship and stakeholder engagement for its Global Equity Emerging Market Mandates. The purpose of this Policy is to describe how NoS applies each of the twelve principles of the Stewardship Code as per the rule 2.2.3R of the Conduct of Business Sourcebook (“COBS”) written by the UK Financial Conduct Authority (“FCA”) as well as how NoS ensures the integration of shareholder engagement as per the Shareholder Rights Directive II (EU) 2017/828 (“SRDII”).

  1. Regulation

COBS 2.2.3R requires a firm which is managing investments for a professional client to disclose clearly on its website the nature of its commitment to the Financial Reporting Council’s UK Stewardship Code 2020 (the “Code”). SRDII requires a firm to describe how it integrates shareholder engagement into its investment strategy. NoS endorses and supports the principles on engagement with the investee companies set out in the Code and SRDII.

  1. Application of Principles
  2. Purpose, strategy and culture

NoS regards voting as an integral part of being a responsible steward of capital and exercises proxy voting rights independently and solely in the interests of our clients and beneficiaries standpoint and not to promote its own interests. We are committed to ensuring consistent exercise of voting rights and voting on all shares held, where it is in the best interest of our clients. Through implementation of our voting policy & guidelines, we aim to enhance the long-term value of our shareholdings and to foster corporate governance best practices. We apply our voting principles with full consideration to a company’s circumstances, following investigation of any concerns and in line with our investment philosophy and voting guidelines.

  1. Governance, resources and incentives

It is our preference to support and build long term relationships with the companies in which we invest. We therefore evaluate the actions and strategies of companies constructively. Where we may have concerns over the value of investee companies, we will take steps to protect the value of our clients’ investments. This is undertaken through participation in shareholder meetings, private management meetings and formal written communications. Our portfolio managers hold the ultimate sanction against management action by selling their investment. This will only be necessary if deemed to be in the best interests of our clients. The above mentioned interactions between NoS and the investee companies is governed by NoS’s Research Policy. The separation of execution and supervisory functions in management is encouraged as a necessary function of superior corporate governance. A company’s board of directors must be appropriately sized and composed so as to ensure adequate discussions take place and appropriate decisions are made. Main corporate governance principles that we expect from our investee companies:

  1. Conflict of interest

NoS acknowledges that conflicts of interest may arise in relation to stewardship activities, and in such cases the interests of our clients must come first. NoS has established a comprehensive Conflicts of Interest Policy, and the firm maintains a Code of Ethics Policy, in order to mitigate and manage conflicts or potential conflicts. We will assess voting on a case-by-case basis and may vote on or deviate from a policy with due consideration to the best interest of our clients. Where a decision has been made to deviate from a policy, this will be documented to evidence that NoS has acted in the best interest of our clients.

  1. Promoting well-functioning markets

Our portfolio managers will consider the company’s management strategy, financial standing and market environment when voting on resolutions relating to the issuing of capital.

  1. Review and assurance

NoS does not use standing instructions for voting; all voting decisions are made by the portfolio managers on an individual basis and votes cast via a third party vendor, Institutional Shareholders Services (ISS). ISS provides research for all proxy votes but the final decision rests with the Global Emerging Markets Team. This enables NoS to control its voting policy and final vote decisions, whilst outsourcing the processing of the proxy voting process. NoS’s voting rights to date classify as insignificant voting rights, per Recital 18 of SRDII, due to the holding size compared to the investee companies’ share capital, therefore no standalone reporting is conducted. We review the Stewardship Code and Engagement Policy at least annually. We maintain a record on all voting activity and explanations as to the reasons for voting against management. A summary of our proxy voting activity, including disclosure where we have voted against management, can be provided upon request.

  1. Client and beneficiary needs

Our portfolio managers make investment decisions based upon the characteristics of an investee company by analysing financial information, such as earnings trends and capital structures, as well as non-financial information like management strategies, corporate governance, social responsibilities and risk. Such data is acquired by accessing publicly disclosed material, holding regular meetings with management and appropriately engaging with investee companies. As a regulated firm, we recognise that there may be circumstances where it may be appropriate to receive inside information (i.e. non-public, price sensitive information) on companies in which we invest in. Our default position is that we generally do not wish to be made party to inside information unless permission is sought from us first. Procedures and controls are maintained to manage those circumstances where we do decide to receive inside information. NoS is opposed to resolutions aimed at maintaining company control or that prevent corporate takeover. Acquisition proposals and/or defensive strategies may be assessed to the extent that the existence of such acquisition risks are clear and existing shareholder value would not be damaged. As stewards of our clients’ capital, our portfolio managers will assess corporate transactions such as mergers & acquisitions of businesses from the view point of consistency with its management strategy and medium to long term enhancement of shareholder value.

  1. Stewardship, investment and ESG integration

NoS’s ESG policy can be located on our website. As mentioned in 3.4 of this Policy, our portfolio managers will consider the company’s management strategy, financial standing and market environment when voting on resolutions relating to the issuing of capital. In particular, we do not evaluate capital increases positively if there is a possibility that it will significantly dilute the equity of existing shareholders and place them in an overall disadvantageous position. Votes are cast on all shares, where there are no legal, client or technical constraints. Where our proxy voting principles or other general corporate governance best practice principles are not met, we would vote against a resolution and attempt to further engage with the investee company. Specifically on climate change our analysis will consider the physical, liability and transition risks associated with the changing climate and our engagement will encourage effective financial disclosure where appropriate.

  1. Monitoring managers and service providers

As laid out in 3.5 of this Policy, NoS utilises ISS for the provision of proxy voting services. ISS’ proxy voting solutions enable us to control our voting policy and final vote decisions while outsourcing the processing of the proxy process to a reliable partner. ISS receive our proxy ballots, work with our custodian banks, execute votes on our behalf, maintain vote records and provide us with comprehensive reports to deliver a complete, end-to-end solution. In the event we wish to vote against the recommendations made by ISS, we are able to access the ISS voting system and amend the vote accordingly.

  1. Engagement

As confirmed in 3.2 of this Policy, where we may have concerns over the value of investee companies, we will take steps to protect the value of our clients’ investments. This is undertaken through participation in stakeholder meetings, private management meetings and formal written communications. During such interactions between NoS and the investee companies, we acknowledge and follow the approaches set out under 3.1 and 3.6 of this Policy.

  1. Collaboration

NoS’s usual policy is to actively engage in discussions with an investee company and participate in collaborative engagement. However, subject to our conflicts of interest and code of ethics policies, we would consider engaging with other stakeholders on matters of mutual interest.

  1. Escalation

As explained in 3.5 of this Policy, our voting rights to date classify as insignificant voting rights due to the holding size compared to the investee companies’ share capital, therefore no escalation has been undertaken by the firm that resulted in actions taken by the investee companies.

  1. Exercising rights and responsibilities

As set out above, we utilise ISS to conduct our proxy voting. This provider can be utilised to produce disclosures on the proportion of share that we voted on, proportion of votes withheld and the underlying voting decisions. Client specific records are available to clients on request.

Shareholder Rights Directive

Under obligations arising from the revised Shareholder Rights Directive (EU 2017/828) (“SRD II”), a firm which trades shares on regulated and comparable markets, is required to either develop and publicly disclose an engagement policy as prescribed in COBS 2.2B.6R or disclose a clear and reasoned explanation of why it has chosen not to do so.

The objective of SRD II is to encourage long-term shareholder engagement with investee companies regarding performance on strategy, governance, environmental and social issues. This also aligns with our investment philosophy under our Environmental, Social and Governance Policy (ESG) and our undertaking to adopt as best practice the UK Stewardship Code 2020.

North of South fully endorse the objectives of SRD II and have decided that whilst they primarily operate within the Global Emerging Markets, there are occasions when some trades may be dual listed on the UK and EU regulated markets and for this reason the firm has decided it is in the best interests of its clients to provide an engagement policy on our website.

North of South Capital LLP Pillar 3 Disclosure Statement

North of South Capital LLP (“North of South”) is authorised and regulated by the UK Financial Conduct Authority (“FCA”) as a Collective Portfolio Management Investment firm (CPMI) and therefore requirements in BIPRU, GENPRU and IPRU INV are applicable with regards to the capital adequacy rules set out in the Financial Conduct Authority’s (“FCA”) Handbook. As a CPMI firm North of South is subject to rules set out in the fourth European Capital Adequacy Directive (“CRD IV”).
The capital adequacy framework consists of three Pillars:

As required by the rules of the FCA North of South has undertaken an ‘Internal Capital Adequacy Assessment Process’ (“ICAAP”). The ICAAP is reviewed annually or whenever there is a material change to the business, whichever is sooner. The most recent ICAAP review was undertaken as at 31 December 2020. The ICAAP process considered the risks that North of South is exposed to and the controls that exist to mitigate those risks. It further considered whether additional capital was required to meet the risks that North of South faces including, as required by the FCA rules, the potential cost of closing North of South down in the unlikely event that such action was necessary. North of South ’s Pillar 1 capital requirement is the higher of the base capital requirement of EUR 125,000, the sum of the credit risk and market risk requirements and the fixed overhead requirement. Currently the fixed overhead requirement is the highest of these three requirements and the capital requirement amounts to £130,000. North of South have assessed that there is no additional capital requirement under Pillar 2 requirement as there are enough funds held until the Pillar 1 requirements which total £175,000.

Risk Management

North of South is an asset manager and does not risk its own capital in the financial markets. North of South does not have regulatory permission to take proprietary trading risk and does not take such risk. Accordingly, the risks that North of South faces are more limited in scope than for other types of regulated firms. The risks and controls detailed below are, in accordance with the BIPRU rules, risks that North of South faces in respect of its own activities. The risk management processes and controls for monies managed by North of South are not part of these disclosures.

Capital

The capital of North of South is in the form of eligible members’ capital plus retained earnings. All of the capital of the company is Tier 1 capital. As at 31 December 2020 North of South had Tier 1 capital of £326,000.

Approach to risk

North of South has identified and performed an assessment of the key risks that may impact its business. North of South is an investment manager and does not undertake proprietary trading. The material risks to North of South largely fall within the “Business Risk” and “Operational Risk” categories.

Principal risks and uncertainties

Market risk

For the purposes of these disclosures, market risk is the risk value of, or income arising from, North of South ‘s assets and liabilities varying as a result of changes in the market price of financial assets, changes in exchange rates or changes in interest rates.
North of South does not take proprietary trading risk. North of South ‘s risk management activities are on behalf of clients and North of South ‘s own money is not at risk. The only market risks that North of South potentially face is currency risk due to the mismatch of the currencies in which income is earned and the currencies in which costs are incurred. Currently this risk does not exist.

Credit risk

Credit risk refers to the potential risk that North of South ’s bankers or customers fail to meet their obligations as they fall due.
North of South has appropriate policies to monitor this exposure on an ongoing basis.

Liquidity risk

North of South ‘s liquidity policy is to maintain sufficient liquid resources to cover cash flow imbalances and fluctuations in fees received/receivable. North of South maintains cash balances at its bankers to cover liquidity risk.

Operational risk

Operational risk is the risk of loss arising from failed or inadequate internal processes or systems, human error or other factors. The risk is managed by the members who have responsibility for putting in place appropriate controls for the business. North of South documents the risks that it is exposed to and the compensating controls in its ICAAP.

Business risk

Business risk is the risk that North of South may not be able to carry out its business plan and could therefore suffer losses if its income falls. This is a risk that all businesses face. The members continuously monitor income and expenditure levels and adjust their plans accordingly.

Concentration risk

Concentration risk is the risk that North of South is overly dependent upon any one customer or any one group of connected customers either in terms of income dependency or in terms of credit risk. North of South has a diversified income source and is not subject to concentration risk.

Pension obligation risk

North of South has no defined benefit schemes and thus has no pension obligation risk.

Interest rate risk

North of South is not exposed to interest rate risk.

Residual risk

Residual risk is any risk not covered by the specific risk categories outlined above.
The members do not consider that there are any residual risks that require the Company to maintain any additional capital.

Remuneration disclosures

Under the Remuneration Code (the “Remuneration Code”), North of South, as is standard for an investment management firm, is classified as a Proportionality Level three firm. Proportionality Level three firms are permitted to disapply many of the technical requirements of the Remuneration Code and proportionately apply the Remuneration Code’s rules and principles in establishing North of South ’s policy.
As at 31 December 2019 North of South had 3 code Staff. North of South has only one business area which is its investment management business.

The Decision-Making Process

North of South has concluded that, on the basis of its size, the nature, scale and complexity of its legal structure and business and the nature of the risks that it takes on behalf of clients, it does not need to appoint a remuneration committee. North of South believes that its Remuneration Policy appropriately addresses potential conflicts of interest and that North of South ’s authorised persons are not rewarded for taking inappropriate levels of risk. The policy is reviewed at least annually and will be amended, as and when required due to changes in regulation as well as North of South ’s own decision making process.

The link between pay and performance

As the only code staff are members of the LLP this is not applicable.

Quantitative Remuneration Data

North of South has concluded that it is not required to publish quantitative remuneration data relating to code staff on the grounds of proportionality, there only being 3 code staff.

ANNUAL BEST EXECUTION DISCLOSURE 2020 – RTS28

NORTH OF SOUTH CAPITAL LLP

February 2021

  1. Introduction

In accordance with the requirements of the Regulatory Technical Standard 28 (RTS 28) supplementing Directive 2014/65/EU (MiFID II), North of South Capital LLP (NOS) is required to provide additional disclosures around the identity of its top five execution venues and counterparties utilised for each asset class and certain additional information on the quality of execution. This report covers the period 1 January 2020 to 31 December 2020.

NOS trades as a professional client and in an institutional capacity on behalf of its clients and therefore does not deal as principal. NOS primarily transmits orders to counterparties, but in some cases will also directly execute orders. NOS will only execute orders directly in relation to FX for non-restricted currencies and underlying collective investment funds (UCITS). All other asset classes are transmitted to brokers for execution. Whilst retail investors may invest in the funds managed by NOS, NOS does not execute retail client orders directly.

NOS is permitted to rely on a single venue or counterparty to execute client orders if it is satisfied that its reliance on this single venue or counterparty provides the best possible result for its clients on a consistent basis, and that the results are at least as good as could be obtained from relying on other entities.

This disclosure does not include trading activity relating to clients for which NOS is the appointed Alternative Investment Fund Manager (AIFM).

  1. Top 5 Execution Venues and Counterparties
Table 1 Broker
Type Retail
Class of Instrument Equities – Shares and Depositary Receipts
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 2 Broker
Type Professional
Class of Instrument Equities – Shares and Depositary Receipts
Notification if <1 average trade per business day in the previous year N
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 orders Percentage of aggressive orders Percentage of directed orders
Sinopac LEI: 2549005YJM8ENGWSJR83 15.902726 6.914588 99.75096000000001 0.24904 0
CIMB LEI: 213800SKEP4JH8FNEL05 15.649874 32.762678 0 100 0
Macquarie LEI: 549300GX4FPMFF91RJ37 12.596397 0.248256 0 100 0
UOB KayHian LEI: 213800I6BGT38Q6V2G26 11.444427 0.089688 0 100 0
Daiwa LEI: MIM2K09LFYD4IB163W58 8.932162 13.591683 0 100 0
Table 3 Broker
Type SFT
Class of Instrument Equities – Shares and Depositary Receipts
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 1 Broker
Type Retail
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 1 and 2
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 2 Broker
Type Professional
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 1 and 2
Notification if <1 average trade per business day in the previous year N
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 orders Percentage of aggressive orders Percentage of directed orders
213800FZY2ZRXFI6H814 27.982263 15.805758 31.582487 68.417513 0
5493006QMFDDMYWIAM13 14.035985 43.002315 8.87171 91.12829000000001 0
213800STG3UV87MDGA96 13.289655 13.08132 0 100 0
213800SKEP4JH8FNEL05 9.835369999999999 8.322704999999999 0 100 0
Macquarie LEI: 549300GX4FPMFF91RJ37 7.344145 0.172418 0 100 0
Table 3 Broker
Type SFT
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 1 and 2
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 1 Broker
Type Retail
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 3 and 4
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 2 Broker
Type Professional
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 3 and 4
Notification if <1 average trade per business day in the previous year N
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 orders Percentage of aggressive orders Percentage of directed orders
CF Global LEI: 213800FZY2ZRXFI6H814 57.052102 31.539533 22.584208 77.415792 0
VTB LEI: 74OG4PIVJ3TT4O5NSN12 20.182817 54.266806 77.95250299999999 22.047497 0
UBS LEI: BFM8T61CT2L1QCEMIK50 16.542167 13.932428 0 100 0
Macquarie LEI: 549300GX4FPMFF91RJ37 6.222914 0.261233 0 100 0
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 3 Broker
Type SFT
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 3 and 4
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 1 Broker
Type Retail
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 5 and 6
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 2 Broker
Type Professional
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 5 and 6
Notification if <1 average trade per business day in the previous year N
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 orders Percentage of aggressive orders Percentage of directed orders
CIMB LEI:213800SKEP4JH8FNEL05 19.000176 10.296879 0 100 0
Macquarie LEI: 549300GX4FPMFF91RJ37 17.575869 9.147814 60.899316 39.100684 0
CF Global LEI: 213800FZY2ZRXFI6H814 16.534182 40.230707 28.450767 71.549233 0
CICC LEI: 213800STG3UV87MDGA96 14.489331 6.246088 0 100 0
DAIWA LEI: MIM2K09LFYD4IB163W58 13.977549 6.992757 0 100 0
Table 3 Broker
Type SFT
Class of Instrument Equities – Shares and Depositary Receipts: Tick size liquidity bands 5 and 6
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 1 Broker
Type Retail
Class of Instrument Equity Derivatives: Swaps and Other Equity Derivatives
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 2 Broker
Type Professional
Class of Instrument Equity Derivatives: Swaps and Other Equity Derivatives
Notification if <1 average trade per business day in the previous year Y
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 orders Percentage of aggressive orders Percentage of directed orders
JP Morgan LEI: K6Q0W1PS1L1O4IQL9C32 100 85.714286 0 100 0
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 3 Broker
Type SFT
Class of Instrument Equity Derivatives: Swaps and Other Equity Derivatives
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 1 Broker
Type Retail
Class of Instrument Other Instruments
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 2 Broker
Type Professional
Class of Instrument Other Instruments
Notification if <1 average trade per business day in the previous year N
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 orders Percentage of aggressive orders Percentage of directed orders
Santander LEI: 5493006QMFDDMYWIAM13 50.110016 48.378729 0 100 0
Actinver LEI: 549300089R7PP6M16N81 49.889984 51.621271 0 100 0
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Table 3 Broker
Type SFT
Class of Instrument Other Instruments
Notification if <1 average trade per business day in the previous year N/A
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 orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
  1. Execution Quality Analysis

This section of the report covers the following instrument classes:

NOS is required to ensure that the best possible result is obtained on a consistent basis when executing client orders and transmitting orders to third parties for execution. What constitutes the best possible result however varies depending on the specific execution factors relevant for each trade. Although the likelihood of settlement and price are deemed to be the most important factors when executing transactions, other factors were also considered for example: liquidity and size, costs, speed and the nature of the order.

NOS has no close links with, or common ownership of or by, any execution venue or counterparty. There were no conflicts of interest with any venue or counterparty which could impact on NOS’s ability to deliver best execution to its clients.

Venue universe is broadly agreed between NOS and its selected counterparties. The venues that are selected by NOS will be regularly monitored via a transaction cost analysis tool for impact and reversion costs. Venues are purely chosen on performance for the objective of achieving best execution.

This section of the report covers the following instrument classes:

NOS executed transactions in highly liquid FX instruments. A large number of counterparties are active and make markets in such instruments. Since the instruments in question are highly liquid, the prices of transactions were given the highest importance over other execution factors such as speed, likelihood of execution.

There are no close links, common ownerships, conflicts of interest or specific arrangements between our funds’ custodian FX platforms and NOS. NOS selects the counterparties used as custodian and their respective FX execution venues on the basis of their credit rating and their execution services.

FX transactions are monitored on a daily basis via reports provided by the funds’ respective custodians. The report allows NOS to monitor the best price selection within its counterparty universe.

Should you require further information in respect of the disclosure please address all enquiries to:

The Compliance Officer

North of South Capital LLP

7 Chesham Mews

London SW1X 8HS

United Kingdom

T: +44 20 7152 6060