Best Execution top 5 Venue report 2020

Section 11 of the Conduct of Business Sourcebook (COBS 11) in the FCA’s Handbook sets out various requirements for firms when they undertake investment transactions on behalf of its clients. These rules include requiring firms to take all sufficient steps to ensure that the best possible results are achieved for its clients on a consistent basis; this is known as “Best Execution”.

In accordance with COBS 11 Annex1EU Regulatory Technical Standard 28 (RTS 28), Alpha Bank London Ltd (ABL) is required to publish the RTS 28 Disclosure in order to make information available in relation to the venues which we have used for the execution of orders and on the analysis undertaken and the conclusions we have drawn from the monitoring of the quality of execution obtained from these venues.

  • In line with the requirements, the information within this disclosure in terms of trading volumes (value of trades) and number of trades per class of Financial Instrument in scope for ABL have been distinguished for the calendar year of 2020 are as follows: Bonds – Issue of government or corporate debt.
  • Equities – Units of shares of ownership in a company

ABLs Top 5 Execution Venues reports will display the:

  • Class of Financial Instrument;
  • Execution venue name;
  • Information on the percentage of total volume (value of trades) executed in that class;
  • Number of trades as a percentage of all client orders executed in that class;
  • Confirmation of whether we have executed an average of less than one trade per business day in the previous year;
  • Percentage of Passive and Aggressive Orders; and
  • Percentage of Directed Orders.

ABL provides portfolio management services to Professional and Retail clients on an execution only basis. In executing orders on behalf of clients no distinction is made between client types and therefore all clients are treated equally, and orders may be aggregated.

ABL places all orders with approved counterparties. This may either be directly on a platform such as BMTF, or via third parties (i.e. brokers) for execution.

ABL does not receive any payments, discount, rebates, or non-monetary benefits as a result of trading relationships when trading in equities and bonds.

ABL considers the following Execution Factors when executing trades:

  1. Price
  2. Costs
  3. Speed of Execution
  4. Likelihood of Execution and Settlement
  5. Size and nature of the order
  6. Any other considerations

Other considerations will include the following:

  • Client characteristics and classification – For example whether the client has been classified as a retail or professional client and whether they are a natural person or professional investor. The level of sophistication, trading frequency and size of portfolio may also be relevant; ABL will classify clients as either retail or professional, but regardless of classification ABL will treat all clients as retail for the purposes of achieving Best Execution or getting the best possible results for you when carrying out trades.
  • The characteristics of the financial instruments that are the subject of the order.
  • The characteristics of the execution venues to which that order can be directed.

ABL does trade with Alpha Group companies but only where it believes that this will result in the best possible outcome for the client order, all trades are monitored and reviewed for best execution.

During 2020 ABL regularly monitored the quality of execution obtained from the execution venues used to place orders for execution, with the use of internal data on executed trades. Further details regarding ABLs Best Execution for Client Deals Policy can be found on our website


Class of InstrumentBonds
Tick size liquidity bands 1
Notification if <1 average trade per business day in the previous year (Y/N)Y
Top five execution venues ranked in terms of trading volumes (descending order)Proportion of volume traded as a percentage of total in that classProportion of orders executed as percentage of total in that classPercentage of passive orders
(Limit Order)
Percentage of aggressive orders
(Market Price)
Percentage of directed orders
Alpha Bank
BMTF (Platform trades including above brokers)3130N/AN/AN/A


Class of InstrumentEquities

Tick size liquidity bands 1
Notification if <1 average trade per business day in the previous year (Y/N)N
Top five execution venues ranked in terms of trading volumes (descending order)Proportion of volume traded as a percentage of total in that classProportion of orders executed as percentage of total in that classPercentage of passive ordersPercentage of aggressive ordersPercentage of directed orders
Alpha Finance
82 75N/AN/AN/A


Aggressive Order ‘Aggressive order’ means an order entered into the order book that took liquidity.

Broker Means street-side counterparties or intermediary through which ABL executes or transmits orders.

Client Order Client Order is a verbal, electronic, or written agreement to execute a transaction on behalf of a client regardless of whether ABL is acting in a principal, riskless principal or agency capacity in any of the Financial Instruments listed in Schedule 1 of the ABL Best Execution Policy.

Eligible Counterparty Eligible Counterparties are Investment Firms; credit institutions; insurance companies; UCITS and their management companies; pension funds and their management companies; other financial institutions authorized or regulated under community legislation or the national law of a Member State; undertakings exempted from the application of this Directive under Article 2(1)(k) and (l); national governments and their corresponding offices including public bodies that deal with public debt; central banks; and supranational organizations (Definition Directive 2004/39/EC, art. 24 (2)).

Execution Venue Execution Venue refers to Regulated Markets, MTFs or OTFs and other liquidity providers or entities that perform a similar function.

Investment Firm Investment Firm means any legal person whose regular occupation or business is the provision of one or more investment services to third parties and/or the performance of one or more investment activities on a professional basis.

MiFID II Markets in Financial Instruments Directive 2014/65/EU of 15 May 2014 (“MiFID II”).

Passive Order ‘Passive order’ means an order entered into the order book that provided liquidity.

Professional Client Professional Client means a client who possesses the experience, knowledge and expertise to be able to appropriately assess the risks associated with their own investment decisions (e.g. financial institutions, other authorized or regulated institutions, collective investment schemes and management companies of such schemes, pension funds, and other institutional investors). Retail Clients who fulfil two out of three criteria set up to demonstrate their knowledge and experience might also be considered Professional Clients upon their own request.

Retail Client Retail Client means a client who is not a Professional Client.

Total Consideration Price of the Financial Instrument and the costs relating to execution, which shall include all expenses incurred by the client that are directly relating to the execution of the order, including Execution Venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.

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Alpha Bank London Limited. Registered office: 85 King William Street, London EC4N 7BL. Registered in England and Wales No.185070. Alpha Bank London Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority under registration number 135327. Authorisation can be checked on the Financial Services Register at: