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RTS-28 Reporting Obligations 2020

Mackenzie Investments Europe Limited*
RTS-28/Art 65(6) Disclosure for the period from January 1 to December 31 2020

Published Under Article 65(6) of the Commission Delegated Regulation (EU) 2017/565 (Markets in Financial Instruments Directive II)

RTS-28 REPORTING OBLIGATIONS

As part of an investment firm's best execution processes, The Markets in Financial Instruments Directive (MiFID II) requires asset managers to report their top five brokers for all trading.

The 2020 calendar year report for Equities – Shares and Depositary Receipts (Tick Band 1 and 2) can be found by clicking here.

The 2020 calendar year report for Equities – Shares and Depositary Receipts (Tick Band 3 and 4) can be found by clicking here.

The 2020 calendar year report for Equities – Shares and Depositary Receipts (Tick Band 5 and 6) can be found by clicking here

The 2020 calendar year report for Exchange Traded Products can be found by clicking here.

The 2020 calendar year report for Other Instruments can be found by clicking here.

The full 2020 calendar year report containing all information can be found by clicking here

Professional Clients

Class of Instrument

Equity Liquidity Bands 1-2

<1 Average trade per business day

N

Counterparty

Volume Traded (%)

Proportion of Orders Executed

Directed Trade (% Volume

Sanford C. Bernstein

30.4%

18.4%

0.0%

Davy

20.5%

17.0%

0.0%

Instinet

12.0%

12.4%

0.0%

Hauck

9.7%

7.4%

0.0%

Kochbank

6.9%

1.8%

0.0%

Class of Instrument

Equity Liquidity Bands 3-4

<1 Average trade per business day

N

Counterparty

Volume Traded (%)

Proportion of Orders Executed

Directed Trade (% Volume

Citigroup

13.8%

5.6%

0.0%

JP Morgan

9.6%

13.2%

0.0%

Kepler

7.5%

7.8%

0.0%

Exane

7.4%

6.7%

0.0%

Baader

7.0%

2.9%

0.0%

Class of Instrument

Equity Liquidity Bands 5-6

<1 Average trade per business day

N

Counterparty

Volume Traded (%)

Proportion of Orders Executed

Directed Trade (% Volume

Kepler

13.8%

12.3%

0.0%

Exane

8.4%

10.5%

0.0%

JP Morgan

8.0%

10.3%

0.0%

Barclays

7.7%

9.8%

0.0%

Instinet

6.7%

9.2%

0.0%

Class of Instrument

Exchange Traded Products

<1 Average trade per business day

Y

Counterparty

Volume Traded (%)

Proportion of Orders Executed

Directed Trade (% Volume

GFIS

86.8%

8.9%

0.0%

Kepler

4.3%

41.1%

0.0%

Sanford C. Bernstein

2.3%

8.9%

0.0%

Virtu

1.6%

8.9%

0.0%

JP Morgan

1.4%

14.4%

0.0%

Class of Instrument

Other

<1 Average trade per business day

Y

Counterparty

Volume Traded (%)

Proportion of Orders Executed

Directed Trade (% Volume

Sanford C. Bernstein

100.0%

100.0%

0.0%

Qualitative Data for RTS 28 for period from January 1 to December 31 2020

Equities - Analysis and conclusions from monitoring the quality of execution in accordance with Commission Delegated Regulation (EU) 2017/576 Article 3(3)(a) to (f)

a) Our execution process is designed ensure the best possible execution on a consistent basis considering the following factors;

  • Price
  • Cost
  • Likelihood of execution
  • Speed
  • Confidentiality from our counterparty
  • Liquidity
  • Settlement

b) Mackenzie Investments Europe Limited has no close links, conflicts of interest or ownership with any brokers used to execute orders

c) The firm doesn't have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non‐ monetary benefits received

d) We continually assess execution venues to ensure they provide us the highest quality execution on a consistent basis

e) All our clients are professional

f) Not applicable as we do not execute retail client orders

g) All trades are monitored and reviewed to ensure the highest quality of execution

h) Not applicable as we have not used the output of a consolidated tape provider