Information according to the Commission Delegated Regulation (EU) 2017/576

ASSESSMENT OF EXECUTION QUALITY FOR 2018

1.    Quality of Execution

Quality of execution has been in line with expectations for all asset classes. Monitoring is performed using a software and the results are send to the brokers and internal compliance for checking.

Lenno Global Advisory JSC works on quotation basis (request for quote). This means that when we receive a quote, we send price requests simultaneously to a number of counterparties (if applicable) and we execute the order at the best price available at the time when the price is the most important factor for executing the trade.

2.    Important Factors related to order execution

The execution factors of orders are shown below in a descending order according to their importance:

•    Price
•    Speed of execution
•    Size of the order and available market liquidity
•    Execution costs
•    Likelihood of execution and settlement
•    Nature of the order
•    Any other consideration relevant to the execution of the order, such as potential market impact

In determining the relative importance of the execution factors, we use our commercial judgment and experience in light of the market information available and take into account the characteristics of the client, the order type, the financial instruments that are subject of the order and the execution venues to which the order can be directed.

For most liquid securities, price and cost tend to be the dominant factors, however, there are occasions where we will change the priorities given to the execution factors and other factors will take precedent to achieve the best possible outcome for the client.

3.    Closed Links, Conflicts of Interest and Common Ownerships

Lenno Global Advisory JSC has no closed links, conflicts of interest or common ownerships to declare.

4.    Special arrangements with execution venues

Lenno Global Advisory JSC has no arrangements with execution venues regarding payments made or received, discounts or non-monetary benefits received.

5.    Factors which led to changes in the execution venues

The Board of Directors of Lenno Global Advisory JSC meets every quarter to assess and review the quality of execution and to agree on any changes relating to the Best execution policy and the approved execution venues.

In 2018 no changes to the execution venues have been made.

6.    Client Categorisation

Lenno Global Advisory JSC categorises its clients as retail, professional and eligible counterparties.

In 2018 the clients have been categorised as retail clients and professional clients, as Lenno Global Advisory JSC treats equally its clients regardless of their categorisation.

When executing an order given by a retail client, the best possible performance of such order shall be determined by the total amount of the transaction, including the price of the financial instrument and the expenses related to the performance. The expenses related to the performance shall include all expenses that are directly related to the execution of the order, including fees for the execution venue, clearing and settlement fees, as well as other fees and remunerations payable to third parties, bound with the execution of the order.

To achieve best possible performance, in the cases where there is more than one competitive execution venues of an order in relation to financial instruments and in making assessment and comparison of the results that may be achieved for a retail client where executing the order on each of the execution venues, which are suitable for its execution, the intermediary’s commission fees and the expenses incurred in connection with the execution of the order on each of the possible venues shall be taken into consideration.

During the period considered, Lenno Global Advisory JSC did not use another criterion to determine the best result for the reporting period, which was preferred to the immediate price of the instrument and the cost of executing the order, regardless of the customer categorisation.

7.    Execution Analysis

During the period considered, Lenno Global Advisory JSC has not established deviations from the best execution principles under the Policy for execution of clients’ orders.

When performing the analysis of the reviewed period, relevant data regarding the quality of execution of client orders, published according to the requirements of the Delegated Regulation (EU) 2017/575 have also been used.

8.    Consolidated Tape Provider

At the time of this report there is no consolidated tape showing comprehensive list of transactions across all venues, as a result of which Lenno Global Advisory JSC did not make use of any consolidated tape providers.

April 2019

Information in accordance with art. 3, para. 1 and 2 of Regulation (EU) 2017/576 for 2018

ASSESSMENT OF EXECUTION QUALITY FOR 2017

1.    Quality of Execution

Quality of execution has been in line with expectations for all asset classes. Monitoring is performed using a software and the results are send to the brokers and internal compliance for checking.

Lenno Global Advisory JSC works on quotation basis (request for quote). This means that when we receive a quote, we send price requests simultaneously to a number of counterparties (if applicable) and we execute the order at the best price available at the time when the price is the most important factor for executing the trade.

2.    Important Factors related to order execution

The execution factors of orders are shown below in a descending order according to their importance:

•    Price
•    Speed of execution
•    Size of the order and available market liquidity
•    Execution costs
•    Likelihood of execution and settlement
•    Nature of the order
•    Any other consideration relevant to the execution of the order, such as potential market impact

In determining the relative importance of the execution factors, we use our commercial judgment and experience in light of the market information available and take into account the characteristics of the client, the order type, the financial instruments that are subject of the order and the execution venues to which the order can be directed.

For most liquid securities, price and cost tend to be the dominant factors, however, there are occasions where we will change the priorities given to the execution factors and other factors will take precedent to achieve the best possible outcome for the client.

3.    Closed Links, Conflicts of Interest and Common Ownerships

Lenno Global Advisory JSC has no closed links, conflicts of interest or common ownerships to declare.

4.    Special arrangements with execution venues

Lenno Global Advisory JSC has no arrangements with execution venues regarding payments made or received, discounts or non-monetary benefits received.

5.    Factors which led to changes in the execution venues

The Board of Directors of Lenno Global Advisory JSC meets every quarter to assess and review the quality of execution and to agree on any changes relating to the Best execution policy and the approved execution venues.

In 2017 no changes to the execution venues have been made.

6.    Client Categorisation

Lenno Global Advisory JSC categorises its clients as retail, professional and eligible counterparties.

In 2017 all clients have been categorised as retail.

7.    Execution Analysis

In assessing the quality of the data, executed for 2017, relevant data on the quality of the execution transaction venues were not taken into consideration as execution venues are still to begin the publication of such reports. As the execution venues begin publishing the reports; this data will be considered into our Assessment of Execution reports.

8.    Consolidated Tape Provider
At the time of this report there is no consolidated tape showing comprehensive list of transactions across all venues, as a result of which Lenno Global Advisory JSC did not make use of any consolidated tape providers.

April 2018

Information in accordance with art. 3, para. 1 and 2 of Regulation (EU) 2017/576 for 2017

Trade Responsibly: CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. 79.17% of retail investor accounts lose money when trading CFDs with this provider. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.

Coming soon

13 days until the new lending, investing, and insurance.