Information on the RBCCM Europe
Best Execution Policy

RBC Capital Markets, Europe
November 2023

Information on the RBCCM Europe Best Execution Policy

TABLE OF CONTENTS
1.0

PURPOSE OF THIS DOCUMENT .................................................................................................. 3

2.0

SCOPE OF THE POLICY ............................................................................................................... 3

3.0

WHAT IS THE “BEST EXECUTION” OBLIGATION? ................................................................... 3

4.0

WHEN DOES THE BEST EXECUTION OBLIGATION APPLY? .................................................. 3

5.0

WHEN DOES THE BEST EXECUTION OBLIGATION NOT APPLY? .......................................... 4

6.0

SPECIFIC INSTRUCTIONS FROM CLIENTS ................................................................................ 4

7.0

APPLICATION OF BEST EXECUTION ACROSS CLASSES OF INSTRUMENTS ...................... 4

8.0

EXECUTION VENUES AND BROKERS ........................................................................................ 5

9.0

OVER-THE-COUNTER (“OTC”) TRANSACTIONS ....................................................................... 5

10.0

DATA PUBLISHING REQUIREMENTS ......................................................................................... 5

11.0

MATTERS OUTSIDE OF OUR CONTROL .................................................................................... 5

12.0

MONITORING ................................................................................................................................. 6

13.0

OWNERSHIP AND RESPONSIBILITY FOR THE POLICY ........................................................... 6

14.0

POLICY REVIEW ............................................................................................................................ 6

15.0

FURTHER INFORMATION ON HOW WE HANDLE YOUR ORDERS ......................................... 6

16.0

CLIENT ENQUIRIES ....................................................................................................................... 6

ANNEX 1 - FINANCIAL INSTRUMENTS AS DEFINED UNDER MiFID II .................................................... 7
ANNEX 2 - OVERVIEW OF BEST EXECUTION BY CLASS OF FINANCIAL INSTRUMENT .................... 8
ANNEX 2.1 - FIXED INCOME .................................................................................................................. 9
ANNEX 2.2 - FOREIGN EXCHANGE .................................................................................................... 10
ANNEX 2.3 - EQUITIES ......................................................................................................................... 11
ANNEX 2.4 - STRUCTURED PRODUCTS............................................................................................ 12
ANNEX 2.5 - EXCHANGE TRADED DERIVATIVES (“ETD”) AND COMMODITIES .......................... 13
ANNEX 2.6 - SECURITIES FINANCING TRANSACTIONS (“SFT”) ................................................... 14

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Information on the RBCCM Europe Best Execution Policy

1.0

PURPOSE OF THIS DOCUMENT
This document sets out information on the Best Execution Policy (“the Policy”) and approach to providing
best execution for the following legal and their entities operating in the United Kingdom and European
Economic Area (“EEA”): RBC Europe Limited, RBC Capital Markets (Europe) GmbH and Royal Bank of
Canada1 together referred to as “RBCCM”, “we” or “us”.
This document is published and updated as necessary on our website at:https://www.rbccm.com/assets/rbccm/docs/legal/information-on-the-rbccm-best-execution-policy.pdf

2.0

SCOPE OF THE POLICYThe Policy applies to business conducted with Professional Clients (“Clients”) (as classified by us)2 andapplies to “Financial instruments” (as outlined in Annex 1).
This Policy applies to transactions where the Client-facing activities (such as agreeing the terms of thetransaction) are carried out by European RBC entities or branches (including those established in the UK
and EEA). In circumstances where Client-facing activities are carried out by other non-European RBC
entities or branches, best execution duties, where applicable, will be owed by the non-European RBC entity.
Spot foreign exchange (“Spot FX”) and Spot Commodities transactions are not defined as “financial
instruments” however we will strive to apply equivalent standards to Spot FX and Spot Commodities.

WHAT IS THE “BEST EXECUTION” OBLIGATION?

3.0

Best execution is the requirement to take all sufficient steps to obtain the best possible result for you, taking
into account price, costs, speed, likelihood of execution and settlement, size, nature and/or any otherconsideration relevant to the execution of an order or any other scenario where you place legitimate relianceon us to protect your interests (“Execution Factors”).

4.0

WHEN DOES THE BEST EXECUTION OBLIGATION APPLY?
We owe you an obligation to take all sufficient steps to obtain best execution when executing orders on yourbehalf. We regard ourselves to typically be in receipt of an order and acting on your behalf where you
legitimately rely on us to protect your interests in relation to the Execution Factors relevant to that transaction
and to act on your behalf. This will include but is not limited to the following situations where we are:▪

executing an order by dealing as your agent;▪

executing an order by dealing as a riskless principal on your behalf; and▪

“working an order” on your behalf.

In all other circumstances, for example when we deal on our own account in response to a request for quote(“RFQ”), we will assess whether you are placing legitimate reliance on us to protect your interest in relation
to the Execution Factors relevant to that transaction. In order to make this assessment the following four
factors (the “four-fold test”) will be considered. These factors will be considered collectively and not in
isolation; any one factor, or a combination thereof, may require us to apply best execution:i.

which party initiated or solicited the transaction - it is more likely that you will be placing relianceon us where we propose the transaction to you;ii.

whether there is a market practice and the existence of a convention to “shop around” – it ismore likely that you will be placing reliance on us in markets where there is not a convention for you
to “shop-around” for a quote;

1 Royal Bank of Canada, London Branch; and Royal Bank of Canada, Paris Branch
2 We do not deal with Retail clients. Services provided by us to Eligible Counterparties are out-of-scope of the Policy;

however where we deal with you as an Eligible Counterparty we will manage any potential conflict of interest fairly in linewith our Conflicts Management Policy.

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Information on the RBCCM Europe Best Execution Policyiii.

the relative levels of price transparency within a market - it is more likely that you will be placing
reliance upon us where the level of price transparency available to you is not the same or similar tothat available to us;

iv.

information provided by RBCCM and any agreement reached - it is more likely that you will be
placing reliance on us where there are arrangements or agreements in place which state we will
provide best execution and indicates or suggest a relationship of reliance.

We do not guarantee that we will be able to achieve best execution for every transaction received from you,
however, in all cases we will comply with the Policy.

5.0

WHEN DOES THE BEST EXECUTION OBLIGATION NOT APPLY?
The best execution obligation will not apply in circumstances in which we are transacting with you as
counterparty on the basis of a own account risk price and you do not place legitimate reliance on us to protect
your interest in relation to the Execution Factors relevant to that transaction (taking into account the “fourfold test” outlined above).

6.0

SPECIFIC INSTRUCTIONS FROM CLIENTS
Where you provide us with specific instructions in relation to one or more Execution Factors, we will executethe order in accordance with those instructions so far as reasonably possible. Where your instructions relate
to only part of the order, in following those instructions we will be deemed to have taken all sufficient steps
to provide best execution in respect of that part of the order. In respect of those aspects of the order notcovered by your specific instructions or where it is not possible to follow your instructions, we will apply the
Policy accordingly.
Please be advised that where you provide us with a specific instruction this may prevent us from taking someor all of the steps in the Policy that are designed to obtain the best possible result for the execution of yourorders in respect of the elements covered by those instructions.

7.0

APPLICATION OF BEST EXECUTION ACROSS CLASSES OF INSTRUMENTS
While the requirement to provide best execution applies to all financial instruments, the differences in market
structures or the structure of financial instruments means that it is necessary to apply the best execution
obligations in a manner that takes into account the different circumstances associated with the execution oforders related to particular types of financial instruments.
Determining the relative importance of the Execution Factors is a dynamic process and may depend upon
several variables and characteristics. In determining the relative importance of the Execution Factors we will
apply our commercial judgement and expertise, in light of the prevailing market conditions, as well as taking
into account:▪

your characteristics;▪

the characteristics of your transaction;▪

the characteristics of the financial instruments that are the subject of your transaction; and▪

the characteristics of the Execution Venues3 to which your transaction can be directed.

In many circumstances price will merit a high relative importance in obtaining best execution. However, insome circumstances we may judge that other Execution Factors will be more important than price inobtaining the best possible result for you.
Additional guidance in relation to the following asset classes is set out in Annex 2:▪

Fixed Income;▪

Foreign Exchange;

3 The term “Execution Venue” includes regulated markets, multi-lateral trading facilities (“MTFs”), organised trading

facilities (“OTFs”), systematic internalisers (“SIs”), market makers, and other liquidity providers.

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Information on the RBCCM Europe Best Execution Policy

8.0▪

Equities;▪

Structured Products;▪

Exchange Traded Derivatives and Commodities; and▪

Securities Financing Transactions.

EXECUTION VENUES AND BROKERS
The list of Execution Venues that RBCCM utilises in respect of each asset class may be found on the
RBCCM website at https://www.rbccm.com/assets/rbccm/docs/legal/execution-venues-under-the-bestexecution-policy.pdf.
This list represents those Execution Venues that should enable us to obtain on a consistent basis the best
possible result for the execution of your transactions. This list may, from time to time, be updated and any
new Execution Venue will be selected in accordance with the Policy.
The factors that have been considered in determining the list of Execution Venues may include the depth ofliquidity a particular Execution Venue is able to offer, the likelihood of execution, speed of execution, thecosts, if any, to execute on such Execution Venues, reliability and system availability, historical trading
activity, and the robustness of the clearing arrangements.
When RBCCM is the Execution Venue, consideration will be given to various sources of reasonably available
information, so as to obtain the best possible result for your transaction.
We may also transmit your order to another broker, which could include an RBCCM affiliate, for execution,in which case we will determine the Execution Venue ourselves in accordance with the Policy and instruct
the broker to deal accordingly.
In cases, where the broker is located outside of the UK or EEA, orders will be required to be executed inaccordance with the local rules and regulations. We will give consideration to such local rules and regulations
when selecting an Execution Venue outside of the UK or EEA as those requirements may be more or lessstringent than the Policy, or may require the broker to apply different criteria to the assessment of execution
quality.
We will not structure or charge commissions in a way as to discriminate unfairly between Execution Venues.

OVER-THE-COUNTER (“OTC”) TRANSACTIONS

9.0

For transactions involving OTC financial instruments 4 where it has been determined that we have a best
execution obligation, we shall gather relevant market data in order to check whether the price offered to you
is fair.

10.0

DATA PUBLISHING REQUIREMENTS

EEA entities of RBC are required to make available to you periodic reports (“RTS 28 Reports”) containing
details of:▪

the top five Execution Venues for Client orders; and▪

the quality of the execution obtained on the Execution Venues where we executed all Client orders
in the previous year.

This information will be published on the rbccm.com website.

11.0

MATTERS OUTSIDE OF OUR CONTROL

4 A financial instrument is considered “OTC” when it is not (i) admitted to trading or (ii) traded on a Regulated Market,

MTF, or OTF.

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Information on the RBCCM Europe Best Execution Policy

In some cases, whether as a result of system failures, disrupted markets or otherwise, it may be necessary
to execute your orders in a different manner to that documented in the Policy for the financial instrument inquestion.
In such circumstances we will still seek to achieve the best possible result available for you in the prevailingcircumstances.

12.0

MONITORING

We will monitor the effectiveness of our execution arrangements, and when appropriate, implement
corrective actions to address any deficiencies that may be identified. If this were to result in a material change
to our execution arrangements, you will be notified accordingly

13.0

OWNERSHIP AND RESPONSIBILITY FOR THE POLICYThe Policy is co-owned by the RBCCM Europe Best Execution Committee and Compliance.

14.0

POLICY REVIEW

We conduct an annual review of the Policy, as well as our order execution arrangements. The objective of
this review is to assess whether there is any scope to improve the quality of the order execution delivered toyou, by for example, including additional/different Execution Venues, considering whether the relative
importance of the execution factors in different circumstances could be adjusted, or by modifying any otheraspects of the Policy.
Such a review will be undertaken on a more frequent basis, if there is a material change that affects ourability to obtain the best possible result for the execution of your orders on a consistent basis using the
Execution Venues listed on the rbccm.com website.

15.0

FURTHER INFORMATION ON HOW WE HANDLE YOUR ORDERS

We have further policies and procedures in place to ensure we execute and allocate your orders promptly
and fairly, taking into account the need to manage any potential conflicts of interest that may exist between
you, ourselves, and our other clients.
We will execute your order in line with other comparable client orders sequentially and promptly, unless (i)the characteristics of your order or prevailing market conditions make this impracticable5; or (ii) your interests
require otherwise.
Where you do not provide specific instructions, we will execute and allocate your order as soon as reasonably
practicable, unless we reasonably consider that delaying the execution of your order is in your best interests.
When executing your order we may decide to aggregate your order with a transaction for our own accountor that of another client. Such aggregation will be taken, for example, to provide a better price to you or to
reduce transaction costs by allowing us to execute in larger size. We will only aggregate your order if it isunlikely that the aggregation will work overall to your disadvantage. Where we are unable to fill an aggregatedorder in full, we will allocate the executed notional on a fair and equitable basis.
We will endeavor to communicate the order execution and allocation status of your order to you soon asreasonably practicable.

16.0

CLIENT ENQUIRIES

Should you have any enquiries in relation to this document or the Policy please contact your usual businesscontact.

5 For example, it may not be practical for client orders that are received by different means (e.g. voice versus electronic)

to be carried out sequentially.

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Information on the RBCCM Europe Best Execution Policy

ANNEX 1 - FINANCIAL INSTRUMENTS AS DEFINED UNDER MiFID II
1. Transferable securities;
2. Money-market instruments;
3. Units in collective investment undertakings;
4. Options, futures, swaps, forward rate agreements and any other derivative contracts relating tosecurities, currencies, interest rates or yields, or other derivatives instruments, financial indices orfinancial measures which may be settled physically or in cash;
5. Options, futures, swaps, forward rate agreements and any other derivative contracts relating tocommodities that must be settled in cash or may be settled in cash at the option of one of the parties
otherwise than by reason of a default or other termination event;
6. Options, futures, swaps, and any other derivative contract relating to commodities that can bephysically settled provided that they are traded on a regulated market and/or an MTF, or an OTF,
except for wholesale energy products traded on an OTF that must be physically settled;
7. Options, futures, swaps, forwards and any other derivative contracts relating to commodities, thatcan be physically settled not otherwise mentioned in 6. and not being for commercial purposes,
which have the characteristics of other derivative financial instruments, having regard to whether,inter alia, they are cleared and settled through recognized clearing houses or are subject to regularmargin calls;
8. Derivative instruments for the transfer of credit risk;
9. Financial contracts for differences;
10. Options, futures, swaps, forward rate agreements and any other derivative contracts relating toclimatic variables, freight rates, or other official economic statistics that must be settled in cash or
may be settled in cash at the option of one of the parties (other than by reason of a default or othertermination event), as well as any other derivative contracts relating to assets, rights, obligations,indices and measures not otherwise mentioned in this Annex, which have the characteristics of otherderivative financial instruments, having regard to whether, inter alia, they are traded on a regulated
market, OTF, or an MTF; and11. Emission allowances consisting of any units recognized for compliance with the requirements of the
Emissions Trading Scheme.

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Information on the RBCCM Europe Best Execution Policy

ANNEX 2 - OVERVIEW OF BEST EXECUTION BY ASSET CLASSThe following sections provide an overview of when and how we will provide you with best execution acrossdifferent asset classes.
Included in each section is the relative importance RBCCM places on the different Execution Factors in
obtaining the best possible result for you.
Each section provides the general position of RBCCM in relation to each asset class. Our approach
may differ, to that outlined, depending upon the particular circumstances of individual transactions.
As outlined in Section 8.0, the list of Execution Venues that RBCCM utilises in respect of each asset class
may be found on the RBCCM website at:https://www.rbccm.com/assets/rbccm/docs/legal/execution-venues-under-the-best-execution-policy.pdf.

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Information on the RBCCM Europe Best Execution Policy

ANNEX 2.1 - FIXED INCOME
The types of Fixed Income products traded by us encompass cash bonds (including Government, Corporate,
Supra-Sovereign and inflation-linked), vanilla OTC derivatives (including interest rate swaps, cross-currency
swaps, basis swaps, asset swaps, inflation swaps, Asset-Backed Securities (“ABS”), Residential MortgageBacked Securities (“RMBS”), Collateralized Loan Obligations (“CLO”)) and Loans.
In line with Sections 4.0 and 6.0, where we execute Fixed Income orders (including Limit orders, At-Close
orders, Specified price/spread orders, and At-best orders) on your behalf, we will owe a duty of best
execution to you unless you have not afforded us any discretion in the execution of those orders.
Where we transact with you as principal on the basis of a published quote, or one provided in response to
an RFQ enquiry, we will consider whether best execution is owed; generally, we consider that best execution
is not owed under the four-fold test. Our rationale for this is that such transactions are initiated by you, there
is a convention for Clients to “shop around” by approaching several dealers for a quote, and there is also
generally a high level of price transparency. In cases where the level of price transparency is limited, forexample, there is no other observable price or clients are unable to obtain comparable pricing from anotherdealer, we may consider that you place reliance on us and therefore we will owe a duty of best execution.
In general, we will consider the most important Execution Factors to be Price, Size, and Speed of execution.
Where no instructions are provided by you, we will typically use the following order of priority: Price, Size,and Speed.

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Information on the RBCCM Europe Best Execution Policy

ANNEX 2.2 - FOREIGN EXCHANGE
The types of Foreign Exchange (“FX”) products traded by us encompass Spot FX, FX Forwards, FX Swaps,
and OTC Derivatives.
Spot FX is not defined as a “financial instrument”; however, we have chosen to apply equivalent standards
to Spot FX and, as such, an assessment regarding our best execution obligations will be made in relation to
all Spot FX trading.
In line with Sections 4.0 and 6.0, where we execute FX orders (including Limit Orders, At-Best Orders, At
Worst Orders, No Worse Than Orders, Level or Better Orders, Time-sliced Orders, Stop Loss Orders, Fixing
Orders, and for OTC Derivatives Spot-Firm Orders, Premium-Firm Orders, and Implied-Volatility Orders) on
your behalf, we will owe a duty of best execution to you. Where you provide specific instructions for some or
all Execution Factors, rather than instructing us to use our discretion to execute, we will execute those orders
according to those instructions and will therefore meet best execution standards with regards to those
Execution Factors subject to your instructions.
When determining the relative importance of the Execution Factors in relation to your order, we may utilise
our Smart Order routing System (“SOR”).
Where we execute orders subject to specific instructions or execute discretionary orders with no risk
component (e.g. At-Best Orders) a fair, reasonable and justifiable mark-up may be added. Where we executea discretionary order with a risk component (e.g. At Worst Orders, No worse than Orders, Level or Better
Orders, Spot-Firm Orders, Premium-Firm Orders, and Implied-Volatility Orders) a fair, reasonable andjustifiable risk premium may also be included in the all-in-price provided to you.
We will owe a duty of best execution with regard to any algorithmic execution functionality we may use inachieving a certain benchmark or execution strategy. Where you are provided with access to algorithmic
execution functionality, we will satisfy our duty of best execution in so far as we follow any specificinstructions provided by you.
If you are provided with Direct Market Access (“DMA”), you will provide specific instructions for all Execution
Factors and we will execute these orders accordingly. We will satisfy our best execution obligation byfollowing those instructions.
Where we transact with you as principal on the basis of a published quote, or one provided in response to
an RFQ enquiry, we will consider whether best execution is owed; generally, we consider that best execution
is not owed under the four-fold test. Our rationale for this is that such transactions are initiated by you, there
is a convention for Clients to “shop around” by approaching several dealers for a quote, and a high level ofprice transparency exists across FX markets.
In general, we will consider the most important Execution Factors to be Price, Size, and Speed of execution.
Where no instructions are provided by you, we will typically use the following order of priority: Price, Size,and Speed of execution.

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Information on the RBCCM Europe Best Execution Policy

ANNEX 2.3 - EQUITIESThe types of Equity products traded by us encompass cash equities and exchange-traded funds.
In line with Sections 4.0 and 6.0, where we execute Equity orders (including Limit Orders, Market Orders
and At-Close Orders) on your behalf, we will owe a duty of best execution to you unless you have not allowed
us any discretion in the execution of those orders. In applying our duty of best execution, we will when
executing your orders consider any specific instructions and the relative importance of the Execution Factors
in accordance with the Policy.
When determining the relative importance of the Execution Factors in relation to your order, we may utilise
our Smart Order Routing System (“SOR”) to initiate a Price-Sensitive strategy (prioritising Price as an
Execution Factor). For those limited number of UK or EEA exchanges in the Policy for which we do not haveaccess to price and volume data, your orders in financial instruments listed on those exchanges may berouted to a third party broker, who may also utilise Smart Order Routing technology.
We will owe a duty of best execution in regard to any algorithmic execution functionality we may use inachieving a certain benchmark or execution strategy. If you are provided with access to algorithmic executionfunctionality, we will satisfy our duty of best execution in so far as we follow any specific instructions provided
by you.
Where we transact with you as principal on the basis of a published quote, or one provided in response to
an RFQ enquiry, we will consider whether best execution is owed; generally, we consider that best execution
is not owed under the four-fold test. Our rationale for this is that such transactions are initiated by you, there
is a convention for Clients to “shop around” by approaching several dealers for a quote and a high level ofprice transparency exists across Equity markets.
In general, we will consider the most important Execution Factors to be Price, Likelihood of execution, andSpeed of execution. Where no instructions are provided by you, we will typically use the following order ofpriority: Price, Likelihood of execution, and Speed of execution.

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Information on the RBCCM Europe Best Execution Policy

ANNEX 2.4 - STRUCTURED PRODUCTS
The types of Structured Products traded by us encompass Structured Notes, Deposits, Certificates, Warrants
and bespoke OTC derivatives.
Where we deal with you as issuer and counterpart, we negotiate with you the terms of a transaction for the
purposes of structuring a bespoke security that reflects your specific instructions. In these circumstances,
we deal with you as principal for our own account in accordance with your specific instructions, and therefore
there is generally no expectation that we will be providing best execution. Further, the bespoke nature of the
instrument means that it is not likely that there will be any comparable products available.
Where we transact with you as principal on the basis of a published quote, or one provided in response to
an RFQ enquiry, we will consider whether best execution is owed; generally, we consider that best execution
is not owed under the four-fold test. Our rationale for this is that such transactions are initiated by you andthere is a convention for Clients to “shop around” by approaching several dealers for a quote.
With regard to notes, for any secondary market activity including buy-backs and taps during the subscription
period from already invested clients, best execution obligations will be owed as you may be considered to
be a “captive client”, i.e. you will not be in a position to “shop around” as you can only unwind your position
with us.
In general, we will consider the most important Execution Factors to be Price, Likelihood of execution, andSpeed of execution. Where no instructions are provided by you, we will typically use the following order ofpriority: Price, Likelihood of execution, and Speed.

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ANNEX 2.5 - EXCHANGE TRADED DERIVATIVES (“ETD”) AND
COMMODITIESThe types of products traded by us encompass fixed income, index, equity, and commodity futures andoptions.
Spot Commodities is not defined as a “financial instrument”; however, we have chosen to apply equivalent
standards to Spot Commodities and, as such, an assessment regarding our best execution obligations will
be made in relation to all Spot Commodities trading.
The business we conduct in relation to these products (with the exception of cross trades, block trades andExchange for Related Position (“EFRPs”)) is presently all executed on an agency style basis on the
Exchange’s order book. Where we execute on Exchange, we will be regarded as executing orders on yourbehalf and will owe best execution to you.
In respect of the business conducted by us across the London Metal Exchange, there are four possible waysby which we may execute your order: the telephone market; LME Select (the official exchange operated
electronic trading platform); across the Rings; or in the OTC market subsequently brought on-Exchange. We
will owe best execution and accordingly we shall make an assessment regarding the manner in which yourorder is to be executed dependent on a variety of factors, for example, the potential price slippage or liquidity
available under each of the available methods.
In respect of ETD pre-negotiated orders (i.e. the options call-around market) where liquidity on the Exchangeorder-book is limited, we may approach market makers with whom we have existing relationships to secure
the best possible result for you. In this context you will be reliant upon us and a duty of best execution is
owed.
We will owe a duty of best execution in regard to any algorithmic execution functionality we may use inachieving a certain benchmark or execution strategy. If you are provided with access to algorithmic executionfunctionality, we will satisfy our duty of best execution in so far as we follow any specific instructions provided
by you.
If you have been provided with Direct Market Access (“DMA”), you will provide specific instructions for all
Execution Factors and we will execute these orders accordingly. We will satisfy our best execution obligation
by following those instructions.
In respect of crosses, block trades, EFRP and OTC Commodity derivatives, where we transact with you as
principal on the basis of a published quote, or one provided in response to a RFQ enquiry, we will consider
whether best execution is owed; generally, we consider that best execution is not owed under the four-foldtest. Our rationale for this is that such transactions are initiated by you, there is a convention for Clients to“shop around” by approaching several dealers for a quote and a high level of price transparency exists
across the relevant markets.
In general, we will consider the most important Execution Factors to be Price, Size, and Speed of execution.
Where no instructions are provided by you, we will typically use the following order of priority: Price, Size,and Speed.

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ANNEX 2.6 - SECURITIES FINANCING TRANSACTIONS (“SFT”)
RBCCM transacts as principal in the capacity of a Securities Lender/Borrower with Securities
Borrowers/Lenders in products encompassing cash bonds (including Government, Corporate, SupraSovereign and Agency, Asset-Backed Securities (“ABS”), Residential Mortgage-Backed Securities (“RMBS”)
and Collateralized Loan Obligations (“CLOs”)) and equities instruments (including Common Stock, American
Depositary Receipts (“ADRs”), Global Depositary Receipts (“GDRs”), Exchange Traded Funds (“ETFs”), andMaster Limited Partnerships (“MLPs”)).
Where we transact with you as principal on the basis of a published quote, or one provided in response to
an RFQ enquiry, we will consider whether best execution is owed; generally, we consider that best execution
is not owed under the four-fold test. Our rationale for this is that such transactions are initiated by you, there
is a convention for Clients to “shop around” by approaching several dealers for a quote, and a high level ofprice transparency exists in the market.

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