Best Ex & Order Placement Policy

1. Background
The purpose of this document is to explain GIDEX Execution and Order Placement Policy (‘the Policy’), as required under the recast Markets in Financial Instruments Directive 2014/65/EU (MiFID) and Markets in Financial Instruments Regulation EU 600/2014 (MiFIR) (the Directive and Regulation together “MiFID II”) and the UK version of the regulation EU 600/2014, which is part of UK Law by virtue of the European Union (Withdrawal) Act 2018 UK (Onshoring of MiFID II in the UK).
Under such rules, GIDEX is required to take all sufficient steps to obtain the best possible result when executing clients’ orders. This is an obligation referred to as “best execution.”
This Policy sets out how GIDEX complies with its obligation to act in the best interests of its clients when directly executing orders on behalf of clients and additionally when placing orders with entities (such as brokers and dealers) for execution, pursuant to applicable regulation. References in this Policy to the execution of client orders include the execution of clients’ orders, and/or GIDEX decisions to execute orders on behalf of its clients.
All terms used in this document are defined in accordance with MiFID II and the Onshoring of MiFID II in the UK. Additionally, a Glossary of key terms can be found in Appendix 1.
2. Scope
This document applies to:

GIDEX entities regulated by MiFID II and the Onshoring of MiFID II by the United Kingdom which execute client orders, place orders with, or transmit orders to, other entities for execution (listed below).
GIDEX Investment Management (UK) Limited (“BIM”)
GIDEX Advisors (UK) Limited (“BAL”)
GIDEX International Limited (“BIL”)
GIDEX (Netherlands) B.V. (“BNBV”)
GIDEX Institutional Trust Company N.A, UK Branch (“BTC”)
GIDEX Asset Management Deutschland AG (“BAMDE”)
GIDEX France SAS (“BFS”)
GIDEX Fund Managers Limited (“BFM”), a UCITS Management Company and Alternative Investment Fund Manager located in the United Kingdom, (only those sections of the policy required by relevant regulation) Orders executed for Professional Clients in relation to financial instruments defined by MiFID II.

3. GIDEX Trade Execution Model
GIDEX trade execution model that involves the centralisation of its trading platform, whereby orders are routed to specialised trading desks. Maintaining a centralized execution model allows GIDEX to create a separation of duties between trading and portfolio management for most trading activity. It also allows GIDEX to seek to optimize trade execution which is beneficial to GIDEX clients, through a globally consistent operating model for order communication to facilitate Global Order Routing.
GIDEX centralized trading desks are separate from GIDEX portfolio management function, with certain exceptions due to the uniqueness of particular investment strategies and financial instruments and are operated by GIDEX regulated entities in each jurisdiction.
Dealing desks outside the European Economic Area (the “EEA”) and the United Kingdom follow similar policies, processes and procedures. However, the counterparties and trading methods used may vary from those used in the EEA and the United Kingdom given country specific practices.
GIDEX may match and cross orders received in opposite directions in the same financial instrument where permitted by applicable laws, regulations, and client agreements, and when GIDEX believes this is in the best interest of both clients. When this occurs, it is done in accordance with GIDEX Global Crossing Policy and related procedures, which set out provisions and controls designed to manage potential conflicts of interests between clients participating in such cross trades. In the EEA and the United Kingdom, GIDEX typically identifies a crossing opportunity and executes the cross trade on a trading venue which facilitates that type of trade.
4. Order Handling Protocol
Client orders are typically executed in the order in which they are received by the trading desk unless the characteristics of the order or prevailing market conditions make this impractical, and not in the best interest of the client.
Subject to local regulatory requirements, and consistent with GIDEX duty to seek best execution, GIDEX may find it efficient and beneficial to aggregate contemporaneous orders for multiple clients. GIDEX Global Investment and Trading Allocation Policy sets out how GIDEX handles the aggregation of client orders and the fair allocation of financial instruments executed as part of an aggregated order over time.

5. Brokers/Counterparties & Execution Venues
In seeking best execution for its clients, GIDEX may use a variety of execution venues and methods including, but not limited to, brokers acting in an agency or principal capacity, block dealing, Request for Quote (“RFQ”) platforms, swap execution facilities, and sponsored access to the order books of major execution venues).
GIDEX will either:

Execute an order for a client on an execution venue, or with brokers acting as market makers, liquidity providers or in a principal capacity, or
Place orders with brokers for them to execute on the execution venue.

A current list of Execution Venues and brokers used by GIDEX can be found in Appendix 2. This list is subject to change and may be revised from time to time.
With our clients’ consent and unless there is a regulatory obligation to trade certain financial instruments on Trading Venues, we may execute trades in financial instruments traded on Trading Venues outside such venues. This enables us to access a wider range of sources of liquidity and it is particularly desirable when trading illiquid financial instruments and/or large sizes, where we would likely aim to minimize the risk of information leakage or signalling to the market, to avoid a poor execution outcome. In these cases, we may find it more desirable to trade with a broker acting as a systematic internaliser or in a principal capacity.
Although there are benefits to executing trades outside of a trading venue, it should be noted that there is a risk that a broker will fail to meet its obligations in relation to the transaction (‘Counterparty Risk’). While contractual remedies would be available in these circumstances, protections which may be available when trading on venues (such as buy-in procedures) may not be available. Clients can request additional information from GIDEX about the consequences of transactions being executed outside a Trading Venue.
6. Broker/Counterparty Approval Process
All prospective and existing counterparties require the approval of GIDEX Counterparty Risk Group (“CRG”), which operates under GIDEX independent risk management function, Risk & Quantitative Analysis Department (“RQA”).
The CRG is independent from the trading and investment functions, and is responsible for developing, implementing and updating, firmwide counterparty credit policies and procedures (collectively the “Counterparty Credit Risk Policy”) that are designed to identify and evaluate counterparty credit risks and establish appropriate practices to manage these risks. All employees responsible for trade execution are required to comply with the Counterparty Credit Risk Policy.
The Global Trading and Investment Teams are required to submit all prospective trading counterparty requests to the CRG for an independence credit assessment. These views are undertaken at the legal entity level and consider the intrinsic credit quality of the trading counterparty, together with the expected transaction activities.
7. Ongoing Monitoring of Brokers/Counterparties
The CRG maintains a list of approved trading counterparties and reviews the list on an on-going basis via a number of sources including but not limited to audited and interim financial reports, rating agency reports and bulletins where available, various databases and news media and, if covered, output from the GIDEX Credit Research Group. All trading counterparties undergo a cyclical formal review and renewal on a 12 to 18-month basis. Additional interim trading counterparty reviews may be completed in accordance with local regulatory requirements. Periodic updates are presented to the relevant best execution governance forums on counterparty risk matters, as appropriate.
8. Best Execution Obligation and Relevant Factors
GIDEX performs its best execution obligation to take all sufficient steps to obtain consistently over time the best possible results for our clients when executing or placing, or transmitting, client orders by assessing the relative weight and importance of various execution factors and other relevant considerations under the particular circumstances.
A. Execution Factors
GIDEX may consider any one or more of the following execution factors, as relevant:

price of the relevant financial instrument net of brokers’ commissions, Execution Venues’ fees and other applicable execution costs;
costs incurred in execution of the transaction;
speed of execution;
likelihood of execution and settlement;
market conditions
instrument liquidity
size of the order;
nature of the order; and
any other relevant factors.

The relative importance of the execution factors for individual orders varies depending on the characteristics of the order, the financial instrument, the Execution Venues available for execution or placement of that order and the specific market conditions at the time of the trade, such as signals (e.g., indications of interest or axes) about the availability of natural liquidity.
B. Execution Factors and Characteristics of the Order
When generating an order, GIDEX PMs specify instructions relating to the strategy they are pursuing on behalf of clients and for the nature of the order that they are generating. For example, their instructions may vary depending on whether the order was driven by cash inflows or outflows or by changes in the PM’s view regarding a particular investment or type of exposure. Such instructions help influence the prioritization of the execution factors by GIDEX traders. The instructions of PMs typically fall into one of the following categories:
Forward Benchmarks
These orders target execution at a price specified by reference to a point in time in the future (such as “market on close” for stocks or WMR Benchmark Rate for currencies) when the calculation of the price will take place, often by way of an auction mechanism.
This type of benchmark is widely used by index sponsors for index calculation and it is also generally used by managers when executing orders for passive strategies in order to minimize their tracking error. Trading is typically concentrated around the specified future point in time, unless a trader believes there will be insufficient liquidity in the auction or at the close of the market; in such cases a trader may extend the trading window to execute outside of the auction while still seeking to manage tracking error appropriately.
Market-on-close orders typically prioritize the execution factors of likelihood and speed of execution at the required time.
Explicit Price Benchmarks
These orders (such as limit or stop orders) specify a price point at which (or at a more advantageous price than which) to buy or sell the relevant amount of a financial instrument. An explicit price benchmark can be used by active investment strategies to help mitigate total expenses. It can also be used by passive strategies, which, for similar reasons, may choose to participate in end-of-day auctions subject to a limit.
Explicit price benchmarks orders inherently prioritise price as the primary execution factor for consideration. If the explicit price benchmark can be satisfied for the order, a trader may prioritise additional execution factors that will most likely lead to complete execution of the order based on prevailing market conditions.
Best Efforts Benchmarks
For orders that are made available to trade immediately, with benchmarks such as arrival price, price at the time of execution or market price at the point in time when the PM assigns the order to the trading desk, are used where available and unless otherwise specified.
PMs may assign a higher degree of importance to one factor over another. For example, for orders where fulfilment of the entire trade is of highest importance, the likelihood of execution is prioritized. This is more often the case when executing orders for active strategies when the PM has a particularly strong view (whether as a result of fundamental analysis or strong quantitative signals) and tends to be less price sensitive to achieve fast execution.
Where the trader has full discretion in the execution of the order, all execution factors are considered and prioritization varies depending on prevailing market conditions, with total consideration and likelihood of execution typically having higher importance.
Contingent Orders
Contingent orders consider the interdependency of two or more financial instruments on one another, such as the roll of futures contracts or the hedging of a credit instrument. In these cases, it is the collective benchmark of the package that drives the execution factors for consideration, rather than the application of the execution factors to the individual financial instruments that form part of the package or contingent order.
Similarly, traders may also need to consider the impact an order imparts on the overall investment outcome. For example, the execution of an order, which is part of larger basket of orders, may result in a particular investment outcome in the absence of the other orders in the basket also being executed. In such a situation, the calibration of execution timing with regard to the other orders that form the larger basket of orders may drive the consideration of execution factors, so as to minimize or eliminate unwanted market exposure. Further, investment objectives and constraints may limit PMs’ and traders’ ability to prioritise the execution factors.
C.Execution Factors and Characteristics of Financial Instruments
The hierarchy of execution factors that is expressed by a particular type of instruction is complemented by consideration of the characteristics of the financial instrument, as well as consideration of the size of the order, the market conditions at the time of execution of the order, and other relevant facts and circumstances, such that the execution strategy employed for a particular order may differ significantly from executions effected in the same class of financial instruments (and even in the same security) but for different trade sizes and/or in different market conditions at the time of execution.
Listed Financial Instruments
Financial instruments listed on or executed on regulated markets or execution venues that display bids and offers, including both securities and listed derivatives, are typically subject to a high degree of price transparency, which typically limits the need for extensive price discovery. This allows traders to focus more on the execution mechanisms that are available from brokers and whether they can easily facilitate prompt execution while mitigating the impact on the market.
When the order size is considered large relative to the average daily trading volume of the relevant financial instrument, traders will have to manage the risk of signalling to the market the existence of a large trading interest to avoid the potential detrimental impact that this may have on the execution price. Traders may therefore prioritize the use of block trading channels that manage large order sizes.
For illiquid financial instruments (or financial instruments for which liquidity is not concentrated on regulated markets or venues that display bid and offers), the need for price discovery is evaluated against the risk that information leakage might impact the overall execution outcome negatively, which may result in traders requesting quotes from market participants known to offer liquidity in the specific financial instrument to be traded.
Over the Counter (‘OTC’) Financial Instruments
OTC financial instruments that trade in a decentralized market, including both unlisted securities and OTC derivatives, have varying degrees of price transparency. For liquid financial instruments within a reasonable range of tradeable market sizes, traders prioritize trading venues that facilitate price discovery through requests for quotes from multiple market participants. Alternatively, traders may rely on the pricing information contained in alternative pricing sources when selecting a single broker to request a quote for the relevant financial instrument.
For less liquid financial instruments or when the order size is considered large, traders may choose their counterparty based on its perceived ability to reduce the market impact of the execution.
For the execution of trades in illiquid financial instruments, brokers who trade in the same securities or securities with similar characteristics may be prioritized.
For more complex or less liquid OTC products, where prices are not directly observable (e.g. convertible bonds or option packages), traders use available internal and external data or tools to assess the fairness of price, and the expected cost of trading, as accurately as possible under such circumstances.
D. Application of Execution Factors to Individual Classes of Financial Instruments
Listed Financial Instruments and Contracts for Difference

Shares & Depositary Receipts
Exchange Traded Products (Exchange Traded Funds, Exchange Traded Notes and Exchange Traded Commodities) (“ETP”)
Contracts For Difference
Securitized Derivatives – Listed Warrants & Certificates

In addition to best execution, all general Portfolio Management (“PM”) instructions and considerations based on the nature of the order apply to trades in listed instruments.
Orders for listed instruments with forward benchmarks are typically executed in the closing auction for markets where such a mechanism exists. If there is not sufficient liquidity in the auction, then trading might also take place earlier or later to mitigate market impact.
For orders with a best-efforts benchmark, GIDEX typically choose an execution method most suitable for balancing price and likelihood of execution.
Where the size of an order is significant relative to available liquidity in the secondary market, traders may prioritize execution channels which provide supplemental or surrogate sources of liquidity, such as broker capital or primary ETP markets.
Listed Futures and Options

Interest Rate Derivatives – Listed Futures & Options
Credit Derivatives – Listed Futures & Options
Equity Derivatives – Listed Futures & Options
Commodities Derivatives – Listed Futures & Options

In addition to best execution, all general PM instructions and considerations based on the nature of the order apply to trades in futures and listed options.
Orders for listed instruments with forward benchmarks are typically executed in the closing auction for markets where such a mechanism exists. If there is not sufficient liquidity in the auction, then trading might also take place earlier or later to mitigate market impact.
For orders with a best-efforts benchmark, GIDEX typically choose an execution method most suitable for balancing price and likelihood of execution.
Where the size of an order is significant relative to available liquidity in the secondary market, traders may prioritize execution channels which provide supplemental or surrogate sources of liquidity, such as broker capital markets.
For liquid options within a reasonable range of tradeable market sizes, traders will prioritize trading platforms that facilitate price discovery through requests for quotes from multiple market participants.
Debt Instruments

Bonds
Structured Finance Instruments

While some debt instruments are listed, they are commonly traded in a decentralized OTC manner.
All general PM instructions and considerations based on the nature of the order apply to trades in debt instruments.
Orders for debt instruments with forward benchmarks typically are executed around the point in time specified by the PM, since there is not an official closing auction in these markets. If sufficient liquidity is not available at that time, then trading might also take place earlier or later to mitigate market impact.
For orders with a best-efforts benchmark, GIDEX applies a variety of execution methods most suitable for balancing price and the impact of order size on transaction costs.
Money Market Instruments
The execution factors and criteria that GIDEX considers for money market instruments reflect the nature of these orders. Similar to the general considerations, the orders are primarily characterized by PM motivation.
For overnight funding transactions, such as time deposits, completion of the order is of highest importance. As such, likelihood of execution is prioritized, with consideration given to the number of available counterparties and capacity.
For orders where completion is at the trader’s discretion, price and the impact of order size on transaction costs are considered. (See Best Efforts Benchmarks)
OTC Derivatives

OTC Derivatives
Equity Derivatives
Credit Derivatives
Interest Rate Derivatives
Currency Derivatives
Commodity Derivatives
Securitized Derivatives

While most derivative instruments are primarily traded in a decentralized OTC manner, some products may be to traded on a centralised trading venue.
In addition to best execution, all general PM instructions and considerations based on the nature of the order apply to trades in derivative instruments.
Orders for derivative instruments with forward benchmarks are typically executed at a point in time specified by the PM, because there is not an official closing mechanism in these markets. If sufficient liquidity is not available, then trading might also take place earlier or later to mitigate market impact.
For orders with a best-efforts benchmark, GIDEX applies a variety of execution methods suitable for balancing price and the impact of order size on transaction costs. Further, due to the OTC nature of these instruments, there is a varying degree of price transparency, so traders also need to reduce information leakage, signalling and market impact.
Different regulations could mandate that some of these instruments are required to be executed on a centralised traded on venue. Instruments that have a mandatory clearing mandate are centrally cleared with a central counterparty.
Other Structured Financial Instruments
From time to time, GIDEX may decide to enter into bespoke structured transactions. When it does so, it seeks to gather structuring proposals and pricing from one or more brokers, depending on their expertise and subject to GIDEX requirement to diversify its counterparty exposure. Typically, such transactions comprise different components and, to satisfy itself on the fairness of the price proposed by the counterparty, GIDEX may request quotes from more than one counterparty before entering into the transaction or, alternatively, may break the transactions down into their individual components and analyse the implied pricing of each component based on historical data.
Securities Finance Transactions

Securities Lending
Repurchase Agreements
Physical & Synthetic Securities Financing

For securities finance transactions including securities lending, repurchase agreements and physical/synthetic financing, the execution factors and criteria that GIDEX considers include the supply and demand characteristics for the securities in question and additional considerations such as:

current market pricing to lend or finance the specific security
price discovery will follow a similar process to other OTC markets in that traders will prioritize Trading Venues that facilitate ‘requests for price and capacity’ from multiple market participants
liquidity of the lending, financing and cash market for the relevant security
current utilisation/availability of the security and the size of supply or demand relative to the lending or financing market will be considered when determining the likelihood of execution
overall utilization of a broker’s balance sheet; and
other factors that may include, but are not limited to:
collateral type proposed (e.g., cash or non-cash)
proposed duration of the securities finance transaction
transaction costs levied by providers such as custodians, triparty banks, or broker; and
specific or idiosyncratic factors (e.g., a pending corporate action, or expected stability of financing).

9. Broker/Counterparty & Execution Venue SelectionGeneral Considerations
After prioritizing the execution factors based on the characteristics of the order and the financial instruments, if GIDEX has a choice of a number of brokers or Execution Venues that could equally fulfil a given order, it selects the individual broker or Execution Venue by considering further qualitative and quantitative factors. These further factors are often specific to individual financial instruments or classes of financial instruments as the applicable market structure determines the instrument’s liquidity. These additional factors include, but are not limited to:

trade confirmation and settlement capabilities
ability to avoid information leakage
breadth of liquidity access across markets, currencies and products
execution quality
operational resilience and responsiveness to errors
pre- and post-trade execution insights
personnel coverage of the venue or broker
product offering and customizations
research provided, where permitted under applicable regulation
liquidity sourcing capabilities (such as the ability to source natural liquidity)
willingness to commit capital
risk concentration

Further Considerations, by Instrument, in the Selection of Execution Venues
Listed Instruments
Listed financial instruments that trade on an exchange may also be traded electronically. Specific factors for consideration of Execution Venue selection may include:

types, quality and breadth of brokers’ traded financial instruments and functionalities
quality of execution measured against benchmark exchange prices
availability of algorithms and ability to adapt products to GIDEX workflows
access to liquidity

OTC Instruments
Venue considerations for OTC instruments vary depending upon overall liquidity and the manner in which they trade:

for liquid OTC instruments that trade electronically, consideration is given to the type, quality and breadth of Execution Venues; and
for instruments that do no trade electronically, consideration is given to venue liquidity, coverage of instruments and sectors and competitive quoting

Securities Finance Transactions

GIDEX will transact only with approved counterparties, up to any applicable credit limit determined by GIDEX CRG.
Securities lending does not involve the execution of orders to trade but rather the allocation of loan requests submitted by brokers, GIDEX agrees and settles a requested loan allocation provided the broker has been approved, the value of the proposed transaction does not exceed the aggregate value of loans permitted, and the other execution factor considerations have been met.

Money Market Instruments
Specific factors for consideration of venue selection may include:

liquidity and availability of instruments offered by the counterparty
willingness of counterparties to bid back on paper;
product availability, as some issuers will limit the size of issuances available for certain maturities.

Availability of venues which may be limited by the issuer in certain instances, such as asset backed commercial paper. Where certain financial instruments are only available directly from the issuer or a small group of brokers, this informs the selection of the Execution Venue.
10. Prohibited Considerations in Selecting Broker/Counterparties & Execution Venues
GIDEX employees are prohibited from considering the following factors when selecting a broker or Execution Venue:

a counterparty’s placement of, or purchase of, any GIDEX products or GIDEX managed funds;
any personal relationships, including former employment relationships;
any personal benefit for any person associated with the employee, including but not limited to members of the employee’s family or household in addition to close associates and significant others;
any gifts or entertainment received;
a broker-dealer’s historical initial public offering or new issue allocations to GIDEX ;
a broker-dealer’s willingness to accommodate GIDEX trading errors.

11. Services and Benefits Received from Execution Venues
GIDEX from time to time may receive the following services and/or benefits from brokers and Execution Venues:

information or documentation relating to financial instruments or investment services that is generic in nature or personalized to reflect GIDEX circumstances;
issuer commissioned research coverage;
participation in conferences, seminars or trading events on the benefits and features of specific financial instruments or investment services;
hospitality of de minimis value during meetings or those events specified in clause iii above;
connected research on an issuer in the context of an issuer capital raising;
research provided for a trial period; and
such other services and/or benefits that can be considered minor non-monetary benefits under Applicable Law from time to time.

12. Receiving a Specific Client Instruction
In instances where a client has provided a specific order instruction, GIDEX will be deemed to have complied with its best execution obligation for the specific part of the trade to which the instruction relates. However, GIDEX will continue to apply this Policy to those aspects of the order not covered by the specific instruction.
13. Directed Brokerage
From time to time, a client may instruct GIDEX to execute its trades with a particular counterparty or venue or otherwise place limitations on GIDEX discretion to determine counterparty, venue or commission. Directed brokerage arrangements are typically documented in a client’s Investment Management Agreement with GIDEX , or a side letter. Subject to applicable regional regulations, such arrangements may involve the receipt of brokerage commissions from the client transactions in exchange for the provision of services directly to the client or the payment of certain expenses on behalf of the client. The execution timing, levels and/or trading costs may be compromised when entering into directed brokerage arrangements.
Alternatively, a client may direct GIDEX to execute a certain proportion of their overall trading to a broker that meets specific criteria set by the client (e.g., an emerging broker). GIDEX traders use their judgment to decide which trades to execute with such directed brokers and balance a client’s directed brokerage requirements with trying to obtain the best overall result for the client.
Implications on Commission Rates
In directed brokerage arrangements, GIDEX may not be able to freely negotiate commission rates or spreads, obtain volume discounts on aggregated orders or select counterparties on the basis of best price and execution. As a result, directed brokerage transactions may result in higher commissions, greater spreads, or less favourable execution, than would normally be the case if GIDEX were able to choose the broker.
In certain instances where GIDEX is instructed by a client to execute transactions with a specific broker or dealer, GIDEX may “step out” part of an aggregated order in order to have the directed broker or dealer clear and settle that portion of the trade.
14. Monitoring
GIDEX performs multiple types of monitoring to help ensure its order execution arrangements remain suitable for the purpose of seeking to deliver the best client outcomes. Some aspects of monitoring include transaction cost analysis (TCA), senior management oversight in governance committees (Trading Oversight Committees) and compliance and risk monitoring activities. The specific scope and content of monitoring may vary depending on the data that is available, for the relevant asset class, in the market. As new data sources and pricing models become available, they are assessed for potential inclusion in our monitoring.
Transaction Cost Analytics (TCA)
GIDEX utilizes in-house TCA systems, to assess whether trading costs are in line with GIDEX expectations.
GIDEX TCA platform quantifies the full cost of trading, which includes cost contributions from commissions, spreads, market impact, and the opportunity costs that arise from not executing a trade. The total impact from order handling and routing decisions is captured by these measures. Transactions are evaluated against a range of pre-trade, intra-day, and post-trade benchmarks to holistically assess trading performance against the market context. Trading results can be examined in a TCA tool taking into account a broad array of attributes, such as by counterparty, trader, benchmark, or market, allowing for a focused evaluation of each category.
Governance
GIDEX performs reviews of its trading activity in regular Trading Oversight Committees which review execution quality, the effectiveness of execution arrangements and the effectiveness of this Policy. The Trading Oversight committees are also charged with making enhancements to GIDEX execution arrangements and this Policy, where deemed appropriate. The oversight committees are global in nature and cover all asset classes. Trading, Investments, Risk, and Legal & Compliance are represented on each Committee.
Compliance Monitoring
The Global Trade Surveillance and Forensic Testing team, within Legal & Compliance, is responsible for post trade, second line monitoring. The team conducts ongoing, routine, sample based and risk-based tests for adherence to the Policy, currently with a focus on pricing, timeliness of execution and broker selection criteria. Any deficiencies identified are escalated to the relevant Trading Oversight Committee.
RQA Oversight
Where applicable, RQA meets regularly with the relevant business to review and examine execution outlier patterns. The key objectives are to evaluate that execution decisions made by the business over time appear consistent with policy requirements, and ensuring adequate records are kept when point-in-time analysis is undertaken on outlier trades.

15. Periodic Review of the Policy and Order Execution Arrangements
GIDEX is required, under applicable regulations, to review this Policy and its order execution arrangements at least on an annual basis for its adequacy and the effectiveness of implementation. It is also required to review this policy whenever a material change occurs that affects GIDEX ability to continue to obtain the best possible result for its clients.
A material change means a significant event of an internal or external nature, that could materially impact the relevant best execution factors listed in this Policy or the execution venues or entities to which GIDEX transmits client orders for execution, on which GIDEX places significant reliance in meeting its overarching best execution requirement. Any of the following events may, but will not necessarily in all circumstances, amount to such a material change: regulatory changes that materially alter the market structure for certain classes of financial instruments or that otherwise require changes to GIDEX arrangements and processes; GIDEX observation of a significant and consistent deterioration in the liquidity offered and in the quality of execution achieved on a trading venue or from a broker or dealer.
As part of Global Trading and RQA’s continuous framework for evaluating execution quality and governance, along with oversight processes related to monitoring best execution, on an ongoing basis, GIDEX will consider whether it could consistently obtain better execution results if it were to:

include additional or different Execution Venues or entities;
remove any existing Execution Venues or entities;
assign a different relative importance to the best execution factors;
or modify any other aspects of this Policy and/or execution arrangements.

The effectiveness of GIDEX order execution arrangements is tested and monitored by Global Trading and any identified deficiencies are escalated to the relevant Oversight Committees. As new data sources and pricing models become available, they are assessed for potential inclusion in our monitoring. GIDEX tests both the effectiveness of the execution venues that it selects when executing client orders and the execution quality of the entities where it places orders for clients.
16. Conflicts of Interest
GIDEX Global Conflicts of Interest Policy (the “Conflicts Policy”) governs GIDEX responsibility to place its clients’ interests first and identify and manage any conflicts of interest inherent to GIDEX business. The Conflicts Policy requires that GIDEX employees report any actual or potential conflicts of interest to their supervisor and to Legal & Compliance. Amongst other things the Conflicts Policy also requires employees to act solely in the best interests of clients and avoid or otherwise mitigate conflicts of interest, which may involve curtailing or terminating an activity or seeking client consent.
17. Information Provided to Clients
In accordance with relevant regulatory requirements, GIDEX is required to disclose certain information to clients regarding this Policy, including appropriate information about GIDEX and its services, and in some jurisdictions, additional information about the consequences of executing outside a trading venue and the entities chosen for execution.
Appendix 1 – Glossary of Terms
Bid/Ask Spread
The difference between the market price quotations, for buying and for selling particular securities.
Directed Brokerage
The process whereby a client directs a manager to place trades for his account through a specific broker, in exchange for which the client will receive a rebate of a portion of the total commission in addition to execution services. The arrangement can be managed by a third party, such as an investment consultant, or managed by the client’s investment manager.
Crossing Network
An electronic execution venue that enables the matching of orders directly between buyers and sellers. Commissions are typically lower while market impact and bid/ask spreads are removed altogether. Liquidity is often a constraint to order completion.
Direct Market Access (“DMA”)
Direct access to the market floor by managers who wish to deal anonymously in the market, without the use of execution services provided by a broker.
Electronic Communication Network (“ECNs”)
An electronic system that connects major brokerages and individual traders so that they can trade financial products outside of stock exchanges, directly between themselves. The primary products that are traded on ECNs are stocks and currencies.
Execution Services
Those services related to trade execution that meet the criteria laid down by the FCA for payment out of commission.
Execution Venue
A Regulated Market, a Multilateral Trading Facility (MTF), an organized Trading Facility (OTF), a Systematic Internaliser, or a Market Maker or other Liquidity Provider or an entity that performs a similar function in a third country to the functions performed by any of the foregoing.
Liquidity
The degree to which an asset or security can be bought or sold in the market without affecting the asset's price. Liquidity is characterized by a high level of trading activity. 2) The ability to convert an asset to cash quickly. Investing in illiquid assets is riskier because there might not be a way for you to get your money out of the investment. Examples of assets with good liquidity include blue chip common stock and those assets in the money market. A fund with good liquidity would be characterized by having enough units outstanding to allow large transactions without a substantial change in price.
Market Impact
The effect a market participant has when it buys or sells an asset and the extent to which the buy or sell moves the price against the buyer or seller.
Market Maker
A person who holds himself out on the financial markets on continuous basis as being willing to deal on own account by buying and selling financial instruments against the person’s proprietary capital at prices defined by that person.
Multilateral System
Any system or facility in which multiple third-party buying and selling trading interests in financial instruments are able to interact in the system.
Multilateral Trading Facility (MTF)
A multilateral system, operated by an investment firm or a market operator, which brings together multiple third-party buying and selling interests in financial instruments – in the system and in accordance with non-discretionary rules – in a way that results in a contract in accordance with Title II of MIFID II.
Organized Trading Facility
A multilateral system which is not a regulated market or an MTF and in which multiple third-party buying and selling interests in bonds, structured finance products, emission allowances or derivatives are able to interact in the system in a way that results in a contract in accordance with Title II of MIFID II.
Other Liquidity Provider
A firm that holds themselves out as being willing to deal on own account, and which provides liquidity as part of their normal business activity, whether or not they have formal agreements in place or commit to providing liquidity on a continuous basis
Onshoring of MiFID II
Statutory Instrument No 2018/1403 The Markets in Financial Instruments (Amendment) (EU Exit) Regulations 2018 makes amendments to MiFIR, the tertiary legislation made under MiFID II and the UK legislation which implemented MiFID.
Programme Trades
Trades for a basket of securities placed through a single broker and priced as a portfolio and not by reference to the individual constituents of the basked.
Professional Client
A client who possesses the experience, knowledge and expertise to make its own investment decisions and properly assess the risks that it incurs. A client meeting the criteria laid out in Annex II of MIFID II is considered to be a Professional Client.
Regulated Market
A multilateral system operated and/or managed by a market operator, which brings together or facilitates the bringing together of multiple third-party buying and selling interests in financial instruments – in the system and in accordance with its non-discretionary rules – in a way that results in a contract, in respect of the financial instruments admitted to trading under its rules and/or systems, and which is authorised and functions regularly and in accordance with Title III of MIFID II.
Securities Lending
The process by which securities are transferred to a counterparty, subject to an obligation for return of the equivalent securities at a future date. The lender is remunerated by way of a fee.
Systematic Internaliser
An investment firm which, on an organized, frequent systematic and substantial basis, deals on own account when executing client orders outside a regulated market, an MTF or an OTF without operating a multilateral system.
Trading Venue
A regulated market, an MTF or an OTF. After the Transition Period ends, UK trading venues will become third-country trading venues. Similarly, EEA venues will become third-country venues under UK law.
Volatility
The relative rate at which the price of a security or fund moves up and down. Volatility is found by calculating the annualised standard deviation of daily change in price. If the price of a stock moves up and down rapidly over short time periods, it has high volatility. If the price almost never changes, it has low volatility.

ANNEX 1 – Execution Venues and Brokers (as of 30 June 2024)
This list is subject to change and may vary from time to time. Arrangements may vary depending on contractual arrangements with clients.
EQUITIES - Shares & Depositary Receipts

ABG SUNDAL COLLIER ASA
AXIS BANK LTD
BAIRD FINANCIAL CORPORATION
BANCROFT CAPITAL LLC
BANK OF AMERICA CORP
BANK OF MONTREAL
BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BARCLAYS PLC
BARRENJOEY MARKETS PTY LIMITED
BERNSTEIN AUTONOMOUS LLP
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
BRADESCO SECURITIES INC
BTG PACTUAL US CAPITAL, LLC
BTIG LIMITED
BTIG, LLC
CABRERA CAPITAL MARKETS LLC
CANACCORD GENUITY (AUSTRALIA) LTD
CANACCORD GENUITY CORP.
CANACCORD GENUITY GROUP INC
CANACCORD GENUITY LIMITED
CANACCORD GENUITY LLC
CANTOR FITZGERALD & COMPANY
CANTOR FITZGERALD EUROPE
CANTOR FITZGERALD L.P.
CARNEGIE INVESTMENT BANK AB
CASA DE BOLSA FINAMEX SAB DE CV
CASA DE BOLSA SANTANDER SA
CASTLEOAK SECURITIES, L.P.
CAVENDISH FINANCIAL PLC
CAVENDISH SECURITIES PLC
CGS INTL SECS SINGAPORE PTE. LTD
CHINA INTL CAPITAL CORPORATION
CIBC WORLD MARKETS CORP.
CITADEL SECURITIES LLC
CITIBANAMEX CASA DE BOLSA SA DE CV CASA DE BOLSA INTEGRANTE DEL GRUPO FINANCIERO
CITIC SECURITIES COMPANY LIMITED
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP GLOBAL MARKETS TAIWAN SECURITIES CO LTD
CITIGROUP INC
CLSA AMERICAS, LLC
CLSA LIMITED
CORMARK SECURITIES
COWEN & COMPANY LLC
COWEN EXECUTION SERVICES LIMITED
CRAIGS INVESTMENT PARTNERS LTD
DAIWA CAPITAL MARKETS EUROPE LTD
DAIWA SECURITIES CAPITAL MARKETS KOREA CO LTD
DAIWA SECURITIES GROUP INC
DANSKE BANK A/S
DNB BANK ASA
DREXEL HAMILTON LLC
EFG HOLDING
FINANCIAL BROKERAGE GROUP S.A.E.
FLEXTRADER
FLOW TRADERS B.V.
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
GOLDMAN SACHS MEXICO CASA DE BOLSA SA DE CV
GOODBODY STOCKBROKERS
GREAT PACIFIC SECURITIES
GRUPO BURSATIL MEXICANO CASA BOLSA
GUZMAN & COMPANY
HAITONG INTERNATIONAL SECURITIES CO
HONGKONG AND SHANGHAI BANKING CORPORATION LTD
HSBC BANK PLC
HSBC HOLDINGS PLC
HSBC SECURITIES (TAIWAN) CO., LTD.
HSBC SECURITIES (USA) INC
ICAP SECURITIES LIMITED
ICICI BANK LIMITED
IIFL SECURITIES LIMITED
INSTINET EUROPE LIMITED
INSTINET LLC
INVESTEC BANK PLC
ITAU BBA USA SECURITIES, INC.
JANE STREET CAPITAL, LLC
JANE STREET EXECUTION SERVICES, LLC
JARDEN SECURITIES LTD
J & E DAVY
JEFFERIES FINANCIAL GROUP INC
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
JM FINANCIAL SERVICES LIMITED
JOH. BERENBERG, GOSSLER & CO. KG
JONESTRADING INSTITUTIONAL SERVICES LLC
J.P. MORGAN CASA DE BOLSA, S.A. DE
J.P. MORGAN CHASE & CO
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES (TAIWAN) LTD.
J.P. MORGAN SECURITIES PLC
KBC SECURITIES NV
KEPLER CHEUVREUX S.A.
KEYBANC CAPITAL MARKETS INC.
KEZAR TRADING, LLC
KOREA INVESTMENT & SECURITIES CO LTD
KOREA INVESTMENT CORPORATION
KOTAK MAH BK
KOTAK SECURITIES LIMITED
LEERINK PARTNERS LLC
LIBERUM CAPITAL LIMITED
LIQUIDNET ASIA LTD
LIQUIDNET EUROPE LIMITED
LIQUIDNET INC
LOOP CAPITAL MARKETS, LLC
MACQUARIE CAPITAL (EUROPE) LIMITED
MACQUARIE CAPITAL (USA) INC.
MACQUARIE GROUP LTD
MERRILL LYNCH INTERNATIONAL
MERRILL LYNCH MEXICO SA DE CV CASA DE BOLSA
MERRILL LYNCH SECURITIES (TAIWAN) LTD
MIB SECURITIES (HONG KONG) LIMITED
MIRAE ASSET SECURITIES CO LTD
MISCHLER FINANCIAL GROUP, INC.
MIZUHO FINANCIAL GROUP INC
MIZUHO INTERNATIONAL PLC
MIZUHO SECURITIES USA LLC
MOELIS AUSTRALIA SECURITIES P/L
MORGAN STANLEY
MORGAN STANLEY & CO LLC
MORGAN STANLEY & CO. INTERNATIONAL
MORGAN STANLEY MEXICO CASA DE BOLSA SA DE CV
MORGAN STANLEY TAIWAN LIMITED
MORGANS FINANCIAL LTD
NATIONAL BANK FINANCIAL INC.
NOMURA HOLDINGS INC
NOMURA INT HK LTD (TAIPEI BRANCH)
NOMURA SECURITIES INTERNATIONAL INC
NORDEA BANK ABP
NORTHERN TRUST SECURITIES LLP
NPLUS1 SINGER CAPITAL MARKETS LIMITED
NUMIS SECURITIES LTD
NUVAMA WEALTH MANAGEMENT LIMITED
ODDO BHF SCA
ODEON CAPITAL GROUP LLC
OPPENHEIMER & CO. INC.
OPTIVER V.O.F.
PANMURE GORDON (UK) LIMITED
PEEL HUNT LLP
PENSERRA SECURITIES LLC
PIPER SANDLER & CO.
PIPER SANDLER COMPANIES
RAYMOND JAMES & ASSOCIATES INC
RAYMOND JAMES LTD.
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
REDBURN (EUROPE) LIMITED
ROBERT W BAIRD & CO INC
ROTH CAPITAL PARTNERS, LLC
ROYAL BANK OF CANADA
SAMSUNG SECURITIES CO., LTD
SAMUEL A. RAMIREZ & CO., INC
SANFORD C. BERNSTEIN LIMITED
SANTANDER US CAPITAL MARKETS LLC
SCOTIA CAPITAL (USA), INC
SHORE CAPITAL STOCKBROKERS LIMITED
SIEBERT WILLIAMS SHANK & CO. LLC
SKANDINAVISKA ENSKILDA BANKEN AB
SMBC NIKKO SECURITIES INC.
SOCIETE GENERALE
STANDARD BANK OF SOUTH AFRICA LTD
STERN BROTHERS & CO.
STIFEL NICOLAUS EUROPE LIMITED
STUART FRANKEL & CO. INC.
SUMITOMO MITSUI FIN GRP INC
SUSQUEHANNA FINANCIAL GROUP LLLP
TD SECURITIES INC
TIGRESS FINANCIAL PARTNERS LLC
TOURMALINE PARTNERS, LLC
TRADEWEB MARKETS LLC
TRUIST FINANCIAL CORP
TRUIST SECURITIES, INC.
UBS AG
UBS GROUP AG
UBS SECURITIES LLC
UBS SECURITIES PTE LTD, TAIPEI BRAN
VAN LANSCHOT KEMPEN N.V.
VIRTU AMERICAS LLC
VIRTU EUROPE TRADING LIMITED
VIRTU ITG HONG KONG LIMITED
WELLS FARGO & COMPANY
WELLS FARGO SECURITIES LLC
WILSONS ADVISORY AND STOCKBROKING LIMITED
WINTERFLOOD SECURITIES LIMITED
XP INVESTMENTS US, LLC
YUANTA SECURITIES CO., LTD.
ZEUS CAPITAL LIMITED
ZKB SECURITIES UK LTD

DEBT INSTRUMENTS – Bonds

ABN AMRO BANK NV
ACADEMY SECURITIES INC
ADVISORS ASSET MANAGEMENT, INC.
AGRICULTURAL BANK OF CHINA LIMITED
ALLEN & COMPANY LLC
AMERICAN VETERANS GROUP PBC
ANZ SECURITIES INC.
ASL CAPITAL MARKETS INC
AUREL BGC
AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD
BANCO BILBAO VIZCAYA ARGENTARIA S.A
BANCO BRADESCO S.A.
BANCO HSBC S.A.
BANCO JP MORGAN SA INSTITUCION DE BANCA MULTIPLE JP MORGAN GRUPO FINANCIERO
BANCO NACIONAL DE MEXICO SA
BANCO SANTANDER (MEXICO), S.A., INS
BANCO SANTANDER SA
BANCOLOMBIA S.A.
BANK HAPOALIM B.M.
BANK OF AMERICA CORP
BANK OF AMERICA MEXICO SA INSTITUCION DE BANCA MULTIPLE
BANK OF AMERICA, N.A., SHANGHAI BRANCH
BANK OF CHINA (HONG KONG) LIMITED
BANK OF COMMUNICATIONS CO., LTD
BANK OF MONTREAL
BANK OF NOVA SCOTIA
BARCLAYS BANK IRELAND PLC
BARCLAYS BANK MEXICO SA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BARCLAYS PLC
BARCLAYS SECURITIES JAPAN LIMITED
BARRENJOEY MARKETS PTY LIMITED
BAYERISCHE LANDESBANKEN
BBVA MEXICO, S.A.
BBVA SECURITIES INC.
BC ZIEGLER & CO.
BCP SECURITIES, INC
BLAYLOCK VAN, LLC
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BMO NESBITT BURNS INC
BNP PARIBAS
BNP PARIBAS (CHINA) LIMITED
BNP PARIBAS SECURITIES CORPORATION
BNP PARIBAS SECURITIES JAPAN LTD
BNY MELLON CAPITAL MARKETS LLC
BOFA SECURITIES INC.
BOFA SECURITIES JAPAN CO., LTD
BPCE SA
BRADESCO SECURITIES INC
BREAN CAPITAL, LLC
BROWNSTONE INVESTMENT GROUP, LLC
BTG PACTUAL US CAPITAL, LLC
BTIG LIMITED
BTIG, LLC
C.L. KING & ASSOCIATES, INC
CABRERA CAPITAL MARKETS LLC
CAIXABANK, SA
CANACCORD GENUITY LIMITED
CANADIAN IMPERIAL BANK OF COMMERCE
CANTOR FITZGERALD & COMPANY
CANTOR FITZGERALD EUROPE
CASA DE BOLSA FINAMEX SAB DE CV
CASGRAIN & COMPANY (USA) LIMITED
CASTLEOAK SECURITIES, L.P.
CHINA CITIC BANK INTERNATIONAL LTD
CHINA INTERNATIONAL CAPITAL CORP HONG KONG SECURITIES LTD
CHINA INTL CAPITAL CORPORATION
CHINA MERCHANTS SECURITIES CO., LTD
CHINA SECURITIES LTD
CIBC WORLD MARKETS CORP.
CIBC WORLD MARKETS INC
CIMB BANK BERHAD
CITADEL SECURITIES (EUROPE) LIMITED
CITADEL SECURITIES INSTITUTIONAL LLC
CITIBANK (CHINA) COMPANY LIMITED
CITIBANK NA
CITIC SEC INTL GLOBAL MARKETS LTD
CITIC SECURITIES COMPANY LIMITED
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS JAPAN INC
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
CITIZENS CAPITAL MARKETS INC
CLSA AMERICAS, LLC
CMB INTERNATIONAL GLOBAL MARKETS LTD
COMMERZ MARKETS LLC
COMMERZBANK AG
COMMONWEALTH BANK OF AUSTRALIA
COOPERATIEVE RABOBANK U.A.
CREDICORP CAPITAL, LLC
CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SA
CREDIT AGRICOLE SECURITIES (USA) IN
CREDIT INDUSTRIEL ET COMMERCIAL
DA DAVIDSON & COMPANY
DAIWA CAPITAL MARKETS AMERICA INC.
DAIWA CAPITAL MARKETS EUROPE LTD
DAIWA SECURITIES CAPITAL MARKETS KOREA CO LTD
DAIWA SECURITIES CO LTD
DAIWA SECURITIES GROUP INC
DANSKE BANK A/S
DAVENPORT & COMPANY LLC
DBS BANK LTD (SINGAPORE BRANCH)
DESJARDINS SECURITIES INC
DESJARDINS SECURITIES INTERNATIONAL
DEUTSCHE BANK (CHINA) CO., LTD
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
DEUTSCHE CAPITAL MARKETS AUSTRALIA
DEUTSCHE SECURITIES INC.
DNB BANK ASA
DREXEL HAMILTON LLC
DUNCAN WILLIAMS
DZ BANK AG DEUTSCHE ZENTRAL GENOSSENSCHAFTSBANK FRANKFURT AM MAIN
ERSTE GROUP BANK AG
FHN FINANCIAL SECURITIES CORP.
FIDELITY CAPITAL MARKETS, DIV. OF NATIONAL FINANCIAL SERVICES LLC
FIFTH THIRD SECURITIES, INC.
FIRST ABU DHABI BANK PJSC
FIRST HORIZON BANK, N.A.
FIRST TRYON SECURITIES, LLC
FIRSTRAND BANK LIMITED
FLEXTRADER
FLOW TRADERS B.V.
FLOW TRADERS U.S. INSTITUTIONAL TRADING LLC
FMSBONDS, INC.
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
GOLDMAN SACHS JAPAN CO. LTD.
GOLDMAN SACHS MEXICO CASA DE BOLSA SA DE CV
GOODBODY STOCKBROKERS
GREAT PACIFIC SECURITIES
GUOTAI JUNAN SECURITIES (HONG KONG)
GUOTAI JUNAN SECURITIES CO., LTD
HAITONG INTERNATIONAL SECURITIES CO
HERBERT J SIMS & CO., INC
HILLTOP SECURITIES INC.
HONGKONG AND SHANGHAI BANKING CORPORATION LTD
HSBC BANK (CHINA) COMPANY LIMITED
HSBC BANK PLC
HSBC HOLDINGS PLC
HSBC MEXICO SA INSTITUCION DE BANCA MULTIPLE GRUPO FINANCIERO HSBC
HSBC SECURITIES (USA) INC
HUATAI FINANCIAL HOLDINGS (HONG KONG) LTD
HUATAI SECURITIES CO LTD
HUNTINGTON SECURITIES, INC.
ICBC STANDARD BANK PLC.
ICICI BANK LIMITED
IMPERIAL CAPITAL (INTERNATIONAL) LLP
IMPERIAL CAPITAL LLC
INDUSTRIAL AND COMMERCIAL BANK OF CHINA LTD
ING BANK NV
ING FINANCIAL MARKETS LLC
INSPEREX LLC
INTESA SANPAOLO IMI SECURITIES CORP
INTESA SANPAOLO SPA
ITAU BBA USA SECURITIES, INC.
JANE STREET EXECUTION SERVICES, LLC
JANE STREET FINANCIAL LIMITED
JANNEY MONTGOMERY SCOTT LLC
J & E DAVY
JEFFERIES FINANCIAL GROUP INC
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
J.P. MORGAN CHASE BANK (CHINA) COMPANY
J.P. MORGAN CHASE & CO
J.P. MORGAN SECURITIES JAPAN CO LTD
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
J.V.B. FINANCIAL GROUP, LLC
KBC BANK N.V.
KEYBANC CAPITAL MARKETS INC.
KEYCORP
KOTAK MAHINDRA (UK) LIMITED
LANDESBANK BADEN WUERTTENBERG
LANDESBANK HESSEN THUERINGEN GIROZENTRALE
LARRAIN VIAL SA CORREDORA DE BOLSA
LAURENTIAN BANK SECURITIES INC.
LIQUIDITY FINANCE LLP
LIQUIDNET EUROPE LIMITED
LIQUIDNET INC
LLOYDS BANK CORPORATE MARKETS PLC
LLOYDS SECURITIES INC
LOOP CAPITAL MARKETS LLC
MALAYAN BANKING BERHAD
MARKETAXESS CAPITAL LIMITED
MARKETAXESS CORPORATION
MARKETAXESS EUROPE LTD
MERRILL LYNCH INTERNATIONAL
MESIROW FINANCIAL INC
MIDDLEGATE SECURITIES LTD.
MILLENNIUM ADVISORS, LLC
MILLENNIUM EUROPE LIMITED
MIRAE ASSET SECURITIES CO LTD.
MISCHLER FINANCIAL GROUP, INC.
MITSUBISHI UFJ FINANCIAL GROUP
MITSUBISHI UFJ MORGAN STANLEY SECURITIES CO LTD
MIZUHO FINANCIAL GROUP INC
MIZUHO INTERNATIONAL PLC
MIZUHO SECURITIES ASIA LIMITED
MIZUHO SECURITIES CO.,LTD
MIZUHO SECURITIES USA LLC
MOELIS AUSTRALIA SECURITIES P/L
MORGAN STANLEY
MORGAN STANLEY & CO LLC
MORGAN STANLEY & CO. INTERNATIONAL
MORGAN STANLEY MEXICO CASA DE BOLSA SA DE CV
MTS BONDVISION
MUFG SECURITIES AMERICAS INC
MUFG SECURITIES EMEA PLC
MULTI-BANK SECURITIES, INC
NATIONAL AUSTRALIA BANK LIMITED
NATIONAL BANK FINANCIAL INC.
NATIONAL BANK OF CANADA
NATIONAL BANK OF CANADA FINANCIAL INC
NATIXIS S.A.
NATWEST GROUP PLC
NATWEST MARKETS PLC
NATWEST MARKETS SECURITIES INC
NEDBANK LIMITED
NOMURA FIXED INCOME SECURITIES LTD
NOMURA HOLDINGS INC
NOMURA INTERNATIONAL PLC
NOMURA SECURITIES COMPANY LIMITED
NOMURA SECURITIES INTERNATIONAL INC
NORDDEUTSCHE LANDESBANK
NORDEA BANK ABP
NYKREDIT BANK A/S
ODDO BHF SCA
OKASAN SECURITIES CO LTD
OLD MISSION EUROPE LLP
OLD MISSION MARKETS LLC
OP CORPORATE BANK PLC
OPPENHEIMER & CO. INC.
ORIENT SECURITIES COMPANY LIMITED
OVERSEA-CHINESE BANKING CORPORATION LTD
PENSERRA SECURITIES LLC
PERFORMANCE TRUST CAPITAL PARTNERS LLC
PING AN BANK CO LTD
PING AN SECURITIES COMPANY LTD
PIPER SANDLER & CO.
PNC CAPITAL MARKETS INC
RAYMOND JAMES & ASSOCIATES INC
RAYMOND JAMES FINANCIAL INC.
RAYMOND JAMES LTD.
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
SEELAUS & CO., LLC.ROBERT W BAIRD & CO INC
ROYAL BANK OF CANADA
RUE LA BOETIE SAS
R.W. PRESSPRICH & CO SAMUEL A. RAMIREZ & CO., INC
SANTANDER US CAPITAL MARKETS LLC
SC LOWY FINANCIAL (HK) LIMITED
SCOTIA CAPITAL (USA), INC
SCOTIA CAPITAL INC
SCOTIABANK CHILE
SCOTIABANK INVERLAT SA
SEAPORT GLOBAL SECURITIES LLC
SECUREVEST FINANCIAL GROUP INC.
SG AMERICAS SECURITIES LLC
SHANXI SECURITIES CO LTD
SHINKIN SECURITIES CO., LTD
SIEBERT WILLIAMS SHANK & CO. LLC
SKANDINAVISKA ENSKILDA BANKEN AB
SMBC NIKKO CAPITAL MARKETS LTD
SMBC NIKKO SECURITIES AMERICA, INC.
SMBC NIKKO SECURITIES INC.
SOCIETE GENERALE
STANDARD CHARTERED BANK
STANDARD CHARTERED BANK (CHINA) LTD
STANDARD CHARTERED PLC
STATE STREET GLOBAL MARKETS, LLC
STEPHENS INC
STERN BROTHERS & CO.
STIFEL FINL CORP
STIFEL NICOLAUS AND CO INC
STIFEL NICOLAUS EUROPE LIMITED
STONEX FINANCIAL INC
STONEX FINANCIAL LTD
SUMITOMO MITSUI FIN GRP INC
SUMRIDGE PARTNERS, LLC
SUSQUEHANNA FINANCIAL GROUP LLLP
SUSQUEHANNA INTERNATIONAL SECURITIES LIMITED
SVENSKA HANDELSBANKEN AB
SWBC INVESTMENT SERVICES, LLC
SWEDBANK
TD SECURITIES (USA) LLC
TD SECURITIES AUTOMATED TRADING LLC
TD SECURITIES INC
THE SEAPORT GROUP EUROPE LLP
THE TORONTO DOMINION BANK
TIGRESS FINANCIAL PARTNERS LLC
TMC BONDS L.L.C.
TRADEWEB DIRECT LLC
TRADEWEB EUROPE LIMITED
TRADEWEB EXECUTION SERVICES LTD
TRADEWEB MARKETS LLC
TRUIST FINANCIAL CORP
TRUIST SECURITIES, INC.
TRUMID
UBS AG
UBS FINANCIAL SERVICES INC
UBS GROUP AG
UBS SECURITIES LLC
UMB BANK, N.A.
UNICREDIT BANK AG
U.S. BANCORP INVESTMENTS, INC.
VIRTU AMERICAS LLC
WALL STREET ACCESS CORP
WELLS FARGO & COMPANY
WELLS FARGO BANK NA
WELLS FARGO SECURITIES INTERNATIONAL LTD
WELLS FARGO SECURITIES LLC
WESTPAC BANKING CORP ABN
XP INVESTMENTS US, LLC
YIELDBROKER
ZUERCHER KANTONALBANK

DEBT INSTRUMENTS – Money Market Instruments

ABN AMRO BANK NV
ACADEMY SECURITIES INC
ASL CAPITAL MARKETS INC
AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD
BANCO BILBAO VIZCAYA ARGENTARIA S.A
BANCO JP MORGAN SA INSTITUCION DE BANCA MULTIPLE JP MORGAN GRUPO FINANCIERO
BANCO NACIONAL DE MEXICO SA
BANCO SANTANDER (MEXICO), S.A., INS
BANCO SANTANDER SA
BANK OF AMERICA MEXICO SA INSTITUCION DE BANCA MULTIPLE
BANK OF MONTREAL
BANK OF NOVA SCOTIA
BARCLAYS BANK MEXICO SA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BBVA MEXICO, S.A.
BBVA SECURITIES INC.
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BMO NESBITT BURNS INC
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BNP PARIBAS SECURITIES JAPAN LTD
BNY MELLON CAPITAL MARKETS LLC
BOFA SECURITIES INC.
BOFA SECURITIES JAPAN CO., LTD
CABRERA CAPITAL MARKETS LLC
CASA DE BOLSA FINAMEX SAB DE CV
CASTLEOAK SECURITIES, L.P.
CHINA CONSTRUCTION BANK CORPORATION
CHINA SECURITIES LTD
CIBC WORLD MARKETS CORP.
CITADEL SECURITIES INSTITUTIONAL LLC
CITIC SECURITIES COMPANY LIMITED
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS JAPAN INC
CITIGROUP GLOBAL MARKETS LIMITED
COMMERZBANK AG
COMMONWEALTH BANK OF AUSTRALIA
COOPERATIEVE RABOBANK U.A.
CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SA
DAIWA CAPITAL MARKETS AMERICA INC.
DAIWA CAPITAL MARKETS EUROPE LTD
DAIWA SECURITIES CO LTD
DANSKE BANK A/S
DBS BANK LTD (SINGAPORE BRANCH)
DESJARDINS SECURITIES INC
DESJARDINS SECURITIES INTERNATIONAL
DEUTSCHE BANK (CHINA) CO., LTD
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
DEUTSCHE SECURITIES INC.
DZ BANK AG DEUTSCHE ZENTRAL GENOSSENSCHAFTSBANK FRANKFURT AM MAIN
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
GOLDMAN SACHS JAPAN CO. LTD.
GOLDMAN SACHS MEXICO CASA DE BOLSA SA DE CV
GUOTAI JUNAN SECURITIES CO., LTD
HSBC BANK (CHINA) COMPANY LIMITED
HSBC BANK PLC
HSBC MEXICO SA INSTITUCION DE BANCA MULTIPLE GRUPO FINANCIERO HSBC
HSBC SECURITIES (USA) INC
ICBC STANDARD BANK PLC.
INDUSTRIAL AND COMMERCIAL BANK OF CHINA LTD
J.P. MORGAN SECURITIES JAPAN CO LTD
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
KBC BANK N.V.
LANDESBANK BADEN-WUERTTEMBERG GIROZ
LOOP CAPITAL MARKETS, LLC
MARKETAXESS CORPORATION
MARKETAXESS EUROPE LTD
MERRILL LYNCH INTERNATIONAL
MISCHLER FINANCIAL GROUP, INC.
MITSUBISHI UFJ MORGAN STANLEY SECURITIES CO LTD
MIZUHO INTERNATIONAL PLC
MIZUHO SECURITIES ASIA LIMITED
MIZUHO SECURITIES CO.,LTD
MIZUHO SECURITIES USA LLC
MORGAN STANLEY
MORGAN STANLEY & CO LLC
MORGAN STANLEY & CO. INTERNATIONAL
MORGAN STANLEY MUFG SECURITIES CO LTD
MTS BONDVISION
MUFG SECURITIES AMERICAS INC
MUFG SECURITIES EMEA PLC
NATIONAL BANK FINANCIAL INC.
NATIXIS S.A.
NATWEST MARKETS PLC
NOMURA INTERNATIONAL PLC
NOMURA SECURITIES COMPANY LIMITED
NOMURA SECURITIES INTERNATIONAL INC
NORDEA BANK ABP
OKASAN SECURITIES CO LTD
ORIENT SECURITIES COMPANY LIMITED
OVERSEA-CHINESE BANKING CORPORATION LTD
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
SANTANDER US CAPITAL MARKETS LLC
SCOTIA CAPITAL (USA), INC
SCOTIA CAPITAL INC
SCOTIABANK INVERLAT SA
SMBC NIKKO CAPITAL MARKETS LTD
SMBC NIKKO SECURITIES INC.
SOCIETE GENERALE (NY BRANCH)
STANDARD CHARTERED BANK
SUMITOMO MITSUI BANKING CORP (SYDNEY BRANCH)
SUMRIDGE PARTNERS, LLC
TD SECURITIES (USA) LLC
TD SECURITIES INC
TORONTO DOMINION BANK (LONDON BRANCH)
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
UBS AG
UNICREDIT BANK AG
WELLS FARGO SECURITIES INTERNATIONAL LTD
WELLS FARGO SECURITIES LLC
WESTPAC BANKING CORP ABN
YIELDBROKER

INTEREST RATE DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS BANK PLC
BARCLAYS CAPITAL INC
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC
CITIGROUP GLOBAL MARKETS LIMITED
DEUTSCHE BANK AG
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
HSBC SECURITIES (USA) INC
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
SG AMERICAS SECURITIES, LLC
SOCIETE GENERALE INTERNATIONAL LTD
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

INTEREST RATE DERIVATIVES – Swaps, forwards & other interest rates derivatives

ANZ GROUP HOLDINGS LTD
BANCO BILBAO VIZCAYA ARGENTARIA SA
BANCO SANTANDER SA
BANK OF AMERICA CORP
BANK OF MONTREAL
BANK OF NOVA SCOTIA
BARCLAYS PLC
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS SA
BPCE SA
CANADIAN IMPERIAL BANK OF COMMERCE
CITADEL SECURITIES SWAP DEALER LLC
CITIGROUP INC
COMMONWEALTH BANK OF AUSTRALIA
DANSKE BANK A/S
DEUTSCHE BANK AG
GOLDMAN SACHS GROUP INC/THE
HSBC HOLDINGS PLC
ING GROEP NV
JPMORGAN CHASE & CO
LLOYDS BANKING GROUP PLC
MORGAN STANLEY
NATWEST GROUP PLC
NOMURA HOLDINGS INC
NORDEA BANK ABP
ROYAL BANK OF CANADA
RUE LA BOETIE SAS
SKANDINAVISKA ENSKILDA BANKEN AB
SOCIETE GENERALE SA
STANDARD CHARTERED PLC
TORONTO-DOMINION BANK/THE
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
UBS GROUP AG
UNICREDIT SPA
WELLS FARGO & COMPANY
WESTPAC BANKING CORP

COMMODOTIES DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS CAPITAL INC
BARCLAYS CAPITAL,INVESTMENT BANKING
BNP PARIBAS SECURITIES CORP
BOFA SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC.
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
MA REX FINANCIAL LIMITED
MORGAN STANLEY & CO LLC
MORGAN STANLEY & CO. INTERNATIONAL
RBC CAPITAL MARKETS, LLC.
SG AMERICAS SECURITIES, LLC
SOCIETE GENERALE INTERNATIONAL LTD
UBS SECURITIES LLC

CREDIT DERIVATIVES – other credit derivatives

BANK OF AMERICA CORP
BANK OF AMERICA NA
BARCLAYS BANK PLC
BARCLAYS PLC
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS SA
CITIBANK NA
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
DEUTSCHE BANK AG
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
HSBC HOLDINGS PLC
J.P. MORGAN SECURITIES PLC
J.P. MORGAN CHASE BANK
J.P. MORGAN CHASE & CO
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY
MORGAN STANLEY & CO. INTERNATIONAL
MORGAN STANLEY CAPITAL SERVICES LLC
ROYAL BANK OF CANADA
SOCIETE GENERALE
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC

CURRENCY DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS CAPITAL INC.
CITIGROUP GLOBAL MARKETS INC.
DEUTSCHE BANK SECURITIES INC.
FLEXTRADER
FX ALLIANCE LLC
GOLDMAN SACHS & CO. LLC
HSBC SECURITIES (USA) INC
J.P. MORGAN SECURITIES LLC
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO LLC
MORGAN STANLEY & CO. INTERNATIONAL
UBS SECURITIES LLC

CURRENCY DERIVATIVES – Swaps, forwards & other currency derivatives

360T
AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD
BANK OF AMERICA NA
BANK OF AMERICA SECURITIES EUROPE SA
BANK OF MONTREAL
BANK OF NEW YORK MELLON
BANQUE PICTET ET CIE SA
BARCLAYS BANK IRELAND PLC
BARCLAYS BANK PLC
BNP PARIBAS
BROWN BROTHERS HARRIMAN & CO
CANADIAN IMPERIAL BANK OF COMMERCE
CITIBANK EUROPE PLC
CITIBANK NA
CITIGROUP GLOBAL MARKETS EUROPE AG
CITIGROUP GLOBAL MARKETS LIMITED
COINBASE
COINBASE, INC.
COMMONWEALTH BANK OF AUSTRALIA
CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SA
CUSTODY FX-JPM CHASE
DEUTSCHE BANK AG
DEUTSCHE SECURITIES INC.
FLEXTRADER
FX ALLIANCE LLC
FX CONNECT
GOLDMAN SACHS BANK EUROPE, SE
GOLDMAN SACHS BANK USA
GOLDMAN SACHS INTERNATIONAL
GOLDMAN SACHS JAPAN CO. LTD.
HONGKONG AND SHANGHAI BANKING CORPORATION LTD
HSBC BANK PLC
HSBC BANK USA, NA
HSBC CONTINENTAL EUROPE SA
INTEGRAL
J.P. MORGAN AG
J.P. MORGAN SECURITIES PLC
LLOYDS BANK CORPORATE MARKETS
MERRILL LYNCH INTERNATIONAL
MITSUBISHI UFJ TRUST AND BANKING CO
MORGAN STANLEY & CO. INTERNATIONAL
MORGAN STANLEY CAPITAL SERVICES LLC
MORGAN STANLEY EUROPE SE
MORGAN STANLEY MUFG SECURITIES CO.
MUFG BANK, LTD
NATIONAL AUSTRALIA BANK LIMITED
NATWEST MARKETS NV
NATWEST MARKETS PLC
NOMURA INTERNATIONAL PLC
ROYAL BANK OF CANADA
SKANDINAVISKA ENSKILDA BANKEN AB
SOCIETE GENERALE
STANDARD CHARTERED BANK
STATE STREET BANK AND TRUST COMPANY
THE NORTHERN TRUST COMPANY
THE TORONTO-DOMINION BANK
UBS AG
UBS EUROPE SE
WELLS FARGO BANK NA
WESTPAC BANKING CORP

STRUCTURED FINANCE INSTRUMENTS

BANCO SANTANDER SA
BANK OF AMERICA CORP
BANK OF MONTREAL
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BARCLAYS PLC
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BMO NESBITT BURNS INC
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BNY MELLON CAPITAL MARKETS LLC
BOFA SECURITIES INC.
BREAN CAPITAL, LLC
BRED BANQUE POPULAIRE
BROWNSTONE INVESTMENT GROUP, LLC
BTIG, LLC
C.L. KING & ASSOCIATES, INC
CANTOR FITZGERALD & COMPANY
CIBC WORLD MARKETS CORP.
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
DA DAVIDSON & COMPANY
DAIWA CAPITAL MARKETS AMERICA INC.
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
DZ BANK AG DEUTSCHE ZENTRAL GENOSSENSCHAFTSBANK FRANKFURT AM MAIN
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
GUGGENHEIM SECURITIES, LLC
HILLTOP SECURITIES INC.
HSBC BANK PLC
INTESA SANPAOLO SPA
JANE STREET FINANCIAL LIMITED
JANNEY MONTGOMERY SCOTT LLC
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
J.P. MORGAN CHASE & CO
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
KEYBANC CAPITAL MARKETS INC.
LLOYDS BANK CORPORATE MARKETS PLC
LLOYDS BANKING GROUP PLC
LLOYDS SECURITIES INC
LOOP CAPITAL MARKETS, LLC
MARKETAXESS CAPITAL LIMITED
MARKETAXESS CORPORATION
MARKETAXESS EUROPE LTD
MERRILL LYNCH INTERNATIONAL
MILLENNIUM ADVISORS, LLC
MISCHLER FINANCIAL GROUP, INC.
MIZUHO INTERNATIONAL PLC
MIZUHO SECURITIES USA LLC
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MUFG SECURITIES AMERICAS INC
NATIONAL BANK FINANCIAL INC.
NATIXIS S.A.
NATIXIS SECURITIES AMERICAS LLC
NOMURA SECURITIES INTERNATIONAL INC
OPPENHEIMER & CO. INC.
PERFORMANCE TRUST CAPITAL PARTNERS LLC
PIPER SANDLER & CO.
PNC CAPITAL MARKETS LLC
RAYMOND JAMES & ASSOCIATES INC
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
ROBERT W BAIRD & CO INC
SAMUEL A. RAMIREZ & CO., INC
SANTANDER US CAPITAL MARKETS LLC
SCOTIA CAPITAL (USA), INC
SCOTIA CAPITAL INC
SMBC NIKKO CAPITAL MARKETS LTD
SMBC NIKKO SECURITIES AMERICA, INC.
SOCIETE GENERALE (NY BRANCH)
STEPHENS INC
STIFEL NICOLAUS AND CO INC
STONEX FINANCIAL INC
SUSQUEHANNA FINANCIAL GROUP LLLP
TD SECURITIES (USA) LLC
TD SECURITIES INC
THE SEAPORT GROUP EUROPE LLP
TRADEWEB DIRECT LLC
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
U.S. BANCORP INVESTMENTS, INC.
UBS AG
UMB BANK, N.A.
WELLS FARGO SECURITIES INTERNATIONAL LTD
WELLS FARGO SECURITIES LLC
WESTPAC BANKING CORP ABN

EQUITY DERIVATIVES – Futures & Options admitted to trading on a trading venue

BANK OF AMERICA NA
BANK OF MONTREAL
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CITADEL SECURITIES LLC
CITIBANK NA
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
COWEN & COMPANY LLC
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
JANE STREET EXECUTION SERVICES, LLC
JEFFERIES LLC
J.P. MORGAN CHASE BANK
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
NOMURA SECURITIES INTERNATIONAL INC
OPPENHEIMER & CO. INC.
OPTIVER V.O.F.
RBC CAPITAL MARKETS, LLC.
RFQ HUB
ROYAL BANK OF CANADA
SANFORD C BERNSTEIN & CO LLC
SOCIETE GENERALE
SUSQUEHANNA FINANCIAL GROUP LLLP
TD SECURITIES INC
TRADEWEB MARKETS LLC
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

EQUITY DERIVATIVES – Swap & other equity derivatives

ABG SUNDAL COLLIER ASA
BANK OF AMERICA CORP
BANK OF AMERICA NA
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC
BARCLAYS CAPITAL SECURITIES LTD
BARCLAYS PLC
BERNSTEIN AUTONOMOUS LLP
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS
BNP PARIBAS SECURITIES CORP
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
BTIG LIMITED
CABRERA CAPITAL MARKETS LLC
CANACCORD GENUITY LIMITED
CANTOR FITZGERALD EUROPE
CARNEGIE INVESTMENT BANK AB
CAVENDISH SECURITIES PLC
CITIBANK NA
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
CLSA LIMITED
COWEN EXECUTION SERVICES LIMITED
DAIWA CAPITAL MARKETS AMERICA INC.
DAIWA SECURITIES GROUP INC
DANSKE BANK A/S
DNB BANK ASA
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
GOODBODY STOCKBROKERS
HAITONG INTERNATIONAL SECURITIES CO
HONGKONG AND SHANGHAI BANKING CORPORATION LTD
HSBC BANK PLC
HSBC HOLDINGS PLC
HSBC SECURITIES (USA) INC
INSTINET EUROPE LIMITED
INSTINET LLC
INVESTEC BANK PLC
J & E DAVY
JEFFERIES FINANCIAL GROUP INC
JEFFERIES INTERNATIONAL LIMITED
JOH. BERENBERG, GOSSLER & CO. KG
J.P. MORGAN CHASE BANK
J.P. MORGAN CHASE & CO
J.P. MORGAN SECURITIES PLC
J.P. MORGAN SECURITIES LLC
KEPLER CHEUVREUX S.A.
LIBERUM CAPITAL LIMITED
LIQUIDNET EUROPE LIMITED
MACQUARIE CAPITAL (EUROPE) LIMITED
MACQUARIE CAPITAL (USA) INC.
MERRILL LYNCH INTERNATIONAL
MIZUHO INTERNATIONAL PLC
MORGAN STANLEY
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MORGAN STANLEY & CO. INTERNATIONAL
NORDEA BANK ABP
NORTHERN TRUST SECURITIES LLP
NPLUS1 SINGER CAPITAL MARKETS LIMITED
NUMIS SECURITIES LTD
ODDO BHF SCA
OPTIVER V.O.F.
PANMURE GORDON (UK) LIMITED
PEEL HUNT LLP
PENSERRA SECURITIES LLC
RBC EUROPE LTD
REDBURN (EUROPE) LIMITED
RFQ HUB
SG AMERICAS SECURITIES, LLC
SHORE CAPITAL STOCKBROKERS LIMITED
SKANDINAVISKA ENSKILDA BANKEN AB
SOCIETE GENERALE
SOCIETE GENERALE INTERNATIONAL LTD
STIFEL NICOLAUS EUROPE LIMITED
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
UBS AG
UBS GROUP AG
UBS SECURITIES LLC
VIRTU EUROPE TRADING LIMITED
WELLS FARGO SECURITIES LLC
WINTERFLOOD SECURITIES LIMITED
ZEUS CAPITAL LIMITED
ZKB SECURITIES UK LTD

SECURITIZED DERIVATIVES – Warrants & Certificate Derivatives

BARCLAYS CAPITAL SECURITIES LTD
BNP PARIBAS
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
BTG PACTUAL US CAPITAL, LLC
CARNEGIE INVESTMENT BANK AB
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CLSA LIMITED
DNB BANK ASA
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HONGKONG AND SHANGHAI BANKING CORPORATION LTD
HSBC SECURITIES (USA) INC
INSTINET LLC
JEFFERIES INTERNATIONAL LIMITED
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
MACQUARIE CAPITAL (USA) INC.
MERRILL LYNCH INTERNATIONAL
MISCHLER FINANCIAL GROUP, INC.
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
NORDEA BANK ABP
PIPER SANDLER & CO.
SOCIETE GENERALE PARIS
UBS SECURITIES LLC

SECURITIZED DERIVATIVES – Other Securitized Derivatives

N/A

CREDIT DERIVATIVES – Futures & Options admitted to trading on a trading venue
BARCLAYS BANK PLC
BARCLAYS CAPITAL INC
BARCLAYS CAPITAL SECURITIES LTD
BARCLAYS PLC
BLOOMBERG TRADEBOOK LLC
BNP PARIBAS
BNP PARIBAS SECURITIES CORP
BOFA SECURITIES INC.
CITADEL SECURITIES INSTITUTIONAL LLC
CITADEL SECURITIES LLC
CITIGROUP GLOBAL MARKETS INC
CITIGROUP GLOBAL MARKETS LIMITED
CITIGROUP INC
DEUTSCHE BANK AG
DEUTSCHE BANK SECURITIES INC.
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS GROUP INC/THE
GOLDMAN SACHS INTERNATIONAL
HONGKONG AND SHANGHAI BANKING CORPORATION LTD
HSBC BANK PLC
HSBC HOLDINGS PLC
HSBC SECURITIES (USA) INC
JB DRAX HONORE
J.P. MORGAN CHASE & CO
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
MERRILL LYNCH INTERNATIONAL
MIZUHO SECURITIES USA LLC
MORGAN STANLEY
MORGAN STANLEY & CO LLC
MORGAN STANLEY & CO. INTERNATIONAL
MORGAN STANLEY MUFG SECURITIES CO.
NATWEST MARKETS PLC
NOMURA INTERNATIONAL PLC
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
RFQ HUB
SG AMERICAS SECURITIES, LLC
SOCIETE GENERALE CAPITAL CANADA INC
SOCIETE GENERALE INTERNATIONAL LTD
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

COMMODITIES DERIVATIVES – Other commodities derivatives

BARCLAYS CAPITAL INC
BNP PARIBAS SA
BNP PARIBAS SECURITIES CORP
CITIBANK NA
CITIGROUP GLOBAL MARKETS INC.
FLEXTRADER
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
J.P. MORGAN CHASE BANK
J.P. MORGAN SECURITIES LLC
MACQUARIE BANK LIMITED
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO LLC
MORGAN STANLEY & CO. INTERNATIONAL
RBC CAPITAL MARKETS, LLC.
SG AMERICAS SECURITIES, LLC
SOCIETE GENERALE
UBS AG
UBS GROUP AG
UBS SECURITIES LLC

EXCHANGE TRADED PRODUCTS

BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BLOOMBERG TRADEBOOK LLC
BMO CAPITAL MARKETS CORP.
BNP PARIBAS
BNP PARIBAS SECURITIES (ASIA) LIMITED
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
RILEY SECURITIES, INC.
BTIG, LLC
CABRERA CAPITAL MARKETS LLC
CASA DE BOLSA FINAMEX SAB DE CV
CASA DE BOLSA SANTANDER SA
CASTLEOAK SECURITIES, L.P.
CIBC WORLD MARKETS CORP.
CITADEL SECURITIES LLC
CITIBANAMEX CASA DE BOLSA SA DE CV CASA DE BOLSA INTEGRANTE DEL GRUPO FINANCIERO
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CLSA LIMITED
COWEN & COMPANY LLC
DEUTSCHE BANK AG
DRW EUROPE B.V.
FLEXTRADER
FLOW TRADERS B.V.
FLOW TRADERS HONG KONG LTD
FLOW TRADERS U.S. INSTITUTIONAL TRADING LLC
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
GOLDMAN SACHS MEXICO CASA DE BOLSA SA DE CV
GREAT PACIFIC SECURITIES
GRUPO BURSATIL MEXICANO CASA BOLSA
GUZMAN & COMPANY
HSBC BANK PLC
HSBC SECURITIES (USA) INC
INSTINET LLC
JANE STREET EXECUTION SERVICES, LLC
JANE STREET FINANCIAL LIMITED
JEFFERIES INTERNATIONAL LIMITED
JEFFERIES LLC
JONESTRADING INSTITUTIONAL SERVICES LLC
J.P. MORGAN CASA DE BOLSA, S.A. DE
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
KEPLER CHEUVREUX S.A.
LOOP CAPITAL MARKETS, LLC
MACQUARIE CAPITAL (USA) INC.
MERRILL LYNCH INTERNATIONAL
MERRILL LYNCH MEXICO SA DE CV CASA DE BOLSA
MISCHLER FINANCIAL GROUP, INC.
MIZUHO SECURITIES USA LLC
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
MORGAN STANLEY MEXICO CASA DE BOLSA SA DE CV
NATIONAL BANK FINANCIAL INC.
ODEON CAPITAL GROUP LLC
OLD MISSION MARKETS LLC
OPPENHEIMER & CO. INC.
OPTIVER V.O.F.
PENSERRA SECURITIES LLC
RAYMOND JAMES & ASSOCIATES INC
RBC CAPITAL MARKETS, LLC.
RBC EUROPE LTD
ROTH CAPITAL PARTNERS, LLC
SAMUEL A. RAMIREZ & CO., INC
SANTANDER US CAPITAL MARKETS LLC
SCOTIA CAPITAL (USA), INC
SMBC NIKKO SECURITIES INC.
SOCIETE GENERALE PARIS
SUSQUEHANNA FINANCIAL GROUP LLLP
TD SECURITIES INC
TOURMALINE PARTNERS, LLC
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
UBS AG
UBS SECURITIES LLC
VIRTU AMERICAS LLC
VIRTU EUROPE TRADING LIMITED
WELLS FARGO SECURITIES LLC

EMISSION ALLOWANCES

N/A

OTHER INSTRUMENTS

BARCLAYS BANK PLC
BARCLAYS CAPITAL INC.
BARCLAYS CAPITAL SECURITIES LTD
BNP PARIBAS SA
BNP PARIBAS SECURITIES CORPORATION
BOFA SECURITIES INC.
CITIBANK NA
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CITIZENS CAPITAL MARKETS INC
DEUTSCHE BANK SECURITIES INC.
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
JEFFERIES LLC
J.P. MORGAN CHASE BANK
J.P. MORGAN SECURITIES PLC
MARKETAXESS CORPORATION
MERRILL LYNCH INTERNATIONAL
MORGAN STANLEY & CO INTERNATIONAL PLC
MORGAN STANLEY & CO LLC
NATIXIS SECURITIES AMERICAS LLC
NOMURA SECURITIES INTERNATIONAL INC
RBC CAPITAL MARKETS, LLC.
ROYAL BANK OF CANADA
SCOTIA CAPITAL (USA), INC
TD SECURITIES (USA) LLC
TRUIST SECURITIES, INC.
UBS AG
UBS SECURITIES LLC
WELLS FARGO SECURITIES LLC

SECURITIES FINANCING TRANSACTIONS

BANK OF AMERICA SECURITIES EUROPE SA
BANK OF MONTREAL
BANK OF NOVA SCOTIA
BARCLAYS BANK PLC
BNP PARIBAS
BOFA SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC.
CITIGROUP GLOBAL MARKETS LIMITED
CREDIT AGRICOLE CIB (NEW YORK)
CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SA
GLMX
GOLDMAN SACHS & CO. LLC
GOLDMAN SACHS INTERNATIONAL
HSBC BANK PLC
ING BANK NV
J.P. MORGAN SECURITIES LLC
J.P. MORGAN SECURITIES PLC
MIZUHO SECURITIES USA LLC
MUFG SECURITIES EMEA PLC
NATIONAL AUSTRALIA BANK LIMITED
NATIXIS S.A.
NATWEST MARKETS PLC
NOMURA SECURITIES INTERNATIONAL INC
ROYAL BANK OF CANADA (NEW YORK BRANCH)
SANTANDER UK PLC
SOCIETE GENERALE
TD SECURITIES (USA) LLC
TRADEWEB EUROPE LIMITED
TRADEWEB MARKETS LLC
WELLS FARGO SECURITIES LLC