MiFID II RTS 28 Report

Class of Instrument
 Equities and Contracts for Difference
Notification if <1
average trade per
business day in the
previous year



 No

Top 5 venues ranked
in terms of volume
(descending order)
Proportion of
volume traded as a
percentage of total
in that class
Proportion of orders
executed as
percentage of total
in that class
Percentage of
passive orders
Percentage of
aggressive orders
Percentage of
directed orders
Citigroup Global Markets (International)
25.89%
6.49%
n/a
n/a
n/a
Goldman Sachs International
6.60%
1.71%
n/a
n/a
n/a
Merrill Lynch Europe (International)
5.95%
2.51%
n/a
n/a
n/a
UBS Securities LLC – Pinpoint
5.44%
20.56%
n/a
n/a
n/a
Credit Suisse First Boston, London
5.36%
2.38%
n/a
n/a
n/a




Class of Instrument
Exchange Traded Products 
Notification if <1
average trade per
business day in the
previous year


 No
Top 5 venues ranked
in terms of volume
(descending order)
Proportion of
volume traded as a
percentage of total
in that class
Proportion of orders
executed as
percentage of total
in that class
Percentage of
passive orders
Percentage of
aggressive orders
Percentage of
directed orders
UBS Securities LLC – Pinpoint
20.27%
32.46%
n/a
n/a
n/a
Peel Hunt
17.73%
10.73%
n/a
n/a
n/a
Caixabank
11.69%
14.40%
n/a
n/a
n/a
United First Partners
10.55%
10.21
n/a
n/a
n/a
UBS (International)
9.96%
9.42%
n/a
n/a
n/a




Class of Instrument
Equity Derivatives 
Notification if <1
average trade per
business day in the
previous year



 No

Top 5 venues ranked
in terms of volume
(descending order)
Proportion of
volume traded as a
percentage of total
in that class
Proportion of orders
executed as
percentage of total
in that class
Percentage of
passive orders
Percentage of
aggressive orders
Percentage of
directed orders
Goldman Sachs International
63.00%
58.52%
n/a
n/a
n/a
Merrill Lynch Europe (International)
22.97%
25.93%
n/a
n/a
n/a
UBS (International)
14.03
15.56%
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a



Best Execution Qualitative Information

A summary of the analysis and conclusions the firm draws from its detailed monitoring of the quality of execution obtained on the execution venues where it executed all client orders in the previous year (a) Equities - Shares & Depositary Receipts
As part of the analysis of best execution carried out by Pentwater Capital Management Europe LLP (“PCME”) in relation to equities, the Firm analysed the performance and commission spend with applicable counterparties with analysis conducted with the support of a third party vendor.

The monitoring completed supported that best execution was obtained consistently on the approved execution venues throughout the year.
 
(g) Equity Derivatives (i) Options and Futures admitted to trading on a trading venue
As part of PCME’s analysis of best execution in relation to equity derivatives, the Firm reviewed and considered the performance and commission spend from trading over the period with applicable counterparties with analysis conducted with the support of a third party vendor.

The monitoring completed supported that best execution was obtained consistently on the approved execution venues throughout the year.

(g) Equity Derivatives (ii) Swaps and other equity derivatives
As part of PCME’s analysis of best execution in relation to equity derivatives, the Firm reviewed and considered the performance and commission spend from trading over the period with applicable counterparties with analysis conducted with the support of a third party vendor.

The monitoring completed supported that best execution was obtained consistently on the approved execution venues throughout the year.

(j) Contracts for Difference
As part of PCME’s analysis of best execution in relation to CFDs, the Firm reviewed and considered the performance and commission spend from trading over the period with applicable counterparties with analysis conducted with the support of a third party vendor.

The monitoring completed supported that best execution was obtained consistently on the approved execution venues throughout the year.

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 PCME’s delivery of best execution is a key element in its commitment to act in the best interests of its clients, as well as being a regulatory requirement. The Firm prioritises ensuring that all sufficient steps are taken to obtain the best possible result for its clients when it executes, places or transmits orders on their behalf. This means taking into account the ‘execution factors’ such as price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.

The relative importance of the execution factors is judged on an order-by-order basis in line with the Firm’s industry experience and prevailing market conditions. In addition, common key factors for relevant asset classes have been identified as follows:

(a) Equities - Shares & Depositary Receipts
For small indirect orders over a short period of time, the key factors are generally price, speed and costs. For larger or less liquid orders executed across a period of time, which may be executed directly or indirectly, the Firm additionally takes into account confidentiality, expected impact on the market, and slippage historically achieved on each venue.

The impact of implicit costs is taken into account when considering the execution strategy of orders to ensure that they are managed and do not result in an undue impact to total costs.

(g) Equity Derivatives (i) Options and Futures admitted to trading on a trading venue
Due to the nature of the orders the Firm will typically place price and speed of execution is usually of primary importance along with likelihood of execution and settlement. Equity-related instruments traded are generally liquid.

(g) Equity Derivatives (ii) Swaps and other equity derivatives
Due to the nature of the orders the Firm will typically place size, price and cost is usually of primary importance.

(j) Contracts for Difference
Where the Firm is trading equity CFDs these are treated in much the same manner as cash equities, as a result the ranking of execution factors is the same, with price, speed and costs being the primary considerations.

A description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders Applies across all classes of financial instruments traded.

The Firm does not have any close links, conflicts of interests or common ownerships with respect to the execution venues it uses to execute orders.

A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received Applies across all classes of financial instruments traded.

PCME has not entered into any arrangements with its execution venues regarding payments made or received, discounts or non-monetary benefits that would compromise its ability to meet its obligations in regards to best execution, conflicts of interest or inducements.

The Firm has determined that it will pay for research from its Research Payment Account (“RPA”) and as such has arrangements in place to pay for the receipt of such research. Additionally, PCME may on occasion receive or provide minor non-monetary benefits from execution venues. They must be received/provided in accordance with the Firm’s Inducements policy.

When selecting execution venues for inclusion in the execution policy, the Firm does not take into account any non-monetary benefits that may be received from these third parties in connection with the services it provides to its client, but focuses on the potential of the venues to enable the Firm to obtain on a consistent basis the best possible result for the execution of its client orders / transactions.

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 Applies across all classes of financial instruments traded.

During the period under review, PCME’s list of execution venues changed. The Firm regularly reviews the effectiveness of its Best Execution Policy and its execution arrangements to identify and, where appropriate, incorporate any changes to enhance the quality of execution obtained. Following discussions with the front office and as part of the reviews carried out over the period it was determined that certain changes involving both addition and removal of certain counterparties were required to ensure that the Firm continues to obtain the best possible result for its clients. Factors considered included price, access to the market, counterparty risk and market liquidity.

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 Applies across all classes of financial instruments traded.

Whilst PCME does take the characteristics of its client into account when judging the relative importance of the execution factors, the Firm’s sole client (a Group affiliate) is a professional client.

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 Applies across all classes of financial instruments traded.

Not applicable. The Firm does not execute retail client orders.

An explanation of how the Firm has used any data or tools relating to the quality of execution, including any data published under Commission Delegated Regulation (EU) 2017/575 Applies across all classes of financial instruments traded.

PCME does not currently use data or tools relating to the quality of execution, but will utilise such data and tools as are made available in due course, particularly data published by trading venues under ‘RTS 27’.

Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU. Applies across all classes of financial instruments traded.

This is not currently applicable as the services of a Consolidated Tape Provider were not available during the period to which this disclosure relates.