CLSA Europe B.V. RTS 28 Top 5 Venue 2022
CLSA Europe B.V. (‘CLSA’) RTS 28: Best Execution Disclosure Report for year ending
31 December 2022
This RTS 28 Disclosure Report has been prepared by CLSA for the period starting 1 January 2022 to 31
December 2022. It should be read in conjunction with CLSA’s Order Execution Policy, as updated from time-totime. CLSA’s Order Execution Policy and this report are published on the Terms of Business section of CLSA’swebsite, clsa.com.

Equities – Shares and Depositary Receipts

1. Execution Factors ExplainedExplanation of the importance CLSA gave to the execution factors of price, costs, speed, and likelihood ofexecution or any other consideration including qualitative factors when making assessments of the quality ofexecution.
As specified in CLSA’s Order Execution Policy, CLSA considers the following execution factors: price;costs; speed; likelihood of execution and settlement; size of the transaction; nature of the transaction;or any other consideration relevant to execution. Under CLSA's policy, such other considerations caninclude (without limitation) the overall cost of the transaction (including any commissions received by
CLSA and/or its affiliates or any costs for executing the order on an execution venue); timely execution
availability of price improvement; the potential impact of the transaction on price; importance ofretaining commercial confidentiality in relation to trading activities or intentions; liquidity of the market(which may make it difficult to execute an order); order information leakage; trading conflict; market
conduct; market impact; venue liquidity and counterparty risk. The relative importance of these factors
shall be determined by reference to the "execution factors" being: (1) the characteristics of the client
including the categorisation of the client as a professional client; (2) the characteristics of the client
order; (3) the characteristics of the financial instrument that is subject to the order; and (4) thecharacteristics of the Brokers and/or Execution Venues to which that order can be directed.
To ensure that we are consistently able to deliver best execution to our clients, we monitor on an
ongoing basis the quality of execution obtained from the execution venues and brokers used to executeclient orders. Our monitoring consist both of trade by trade monitoring and overall trend monitoring of
the performance of the execution factors. For a detailed description of how we carry out client orders,application of execution factors and how we prioritise the factors, please refer to our Order Execution
Policy.

2. Disclosure of Close Links, Conflicts of Interest and Common Ownership of Execution
VenuesDescription of any close links, conflicts of interests, and common ownerships with respect to any execution
venues used to execute orders.
CLSA is wholly owned by CITIC Securities International Company Limited (‘CITIC Securities’). Through
CITIC Securities, CLSA has regional affiliate relationships in the United Kingdom, United States andAPAC. CLSA uses its regional affiliates for execution of orders. CLSA looks to ensure that affiliates
provide a global execution capability to CLSA’s clients where required. In addition, CLSA requires its
affiliates to ensure clients have access to liquidity in exchanges, alternative trading systems and bank /broker liquidity where relevant. CLSA measures the performance of these executions to identify
outliers and help ensure appropriate standards of execution which are consistent with our Order
Execution Policy requirements.

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CLSA Europe B.V. RTS 28 Top 5 Venue 2022
3. Specific Arrangements with Trading Venues
Specific arrangements with any execution venues regarding payments made or received, discounts, rebates ornon-monetary benefits received.
CLSA does not have any specific arrangements with any external execution venues or brokers used to
execute client orders in shares & depositary receipts regarding payments made or received, discounts,rebates or non-monetary benefits received.

4. Reviewing Execution Venues
Explanation of the factors that led to a change in the list of execution venues listed in the Firm’s execution
policy, if such a change occurred.
The assessment to add, remove or vary venue and broker routing and connectivity is done on an
ongoing basis by CLSA’s Order Execution Committee. During the period this report covers there wereno changes to the execution venues used by CLSA.

5. Client categorization and execution
Explanation of how order execution differs according to client categorisation, where the Firm treats such
category of client differently and where it may affect order execution arrangements.
CLSA only deals with Professional clients and Eligible Counterparties. The obligation to take all
sufficient steps to obtain the best possible result for clients does not apply where CLSA has categorised
its clients as “eligible counterparties” for the purposes of the AFM’s Rules (except where CLSA has
agreed with an eligible counterparty that it will take all sufficient steps to obtain the best possible
result). In relation to its dealings with eligible counterparties, however, CLSA will strive to act in suchclients’ best interests and will take reasonable steps to prevent or manage any conflicts of interest thatit may have in accordance with its obligations under the AFM’s Rules. For a detailed description of how
we carry out client orders in shares & depositary receipts, please refer to our Order Execution Policy.

6. Tools utilized to generate RTS 28 disclosures
Explanation of how the investment firm has used any data or tools relating to the quality of execution,
including any data published under RTS 28.
For the purpose of monitoring and measuring execution quality, CLSA monitors the quality of execution
provided by the execution venues and brokers used to execute client orders in shares & depositary
receipts on a consistent basis, using automated monitoring reports. In such monitoring we always strive
to use external and independent market data against which to compare our execution quality, including
the use of Transaction Cost Analysis reports.

7. Consolidated tape provider
Explanation of how the investment firm has used output of a consolidated tape provider established underArticle 65 of Directive 2014/65/EU.
Currently not applicable as no such data have yet been published in accordance with Article 65 ofDirective 2014/65/EU (MiFID II Directive).

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CLSA Europe B.V. RTS 28 Top 5 Venue 2022
Class of instrument

EquityNotification if <1 average trade perbusiness day in the previous yearN

Top five execution venues ranked interms of trading volumes (descendingorder)LEI

CLSA (UK)213800VZMAGVIU2IJA72

Proportion of Proportion of Percentage ofvolume traded orders executed passive orders
as a percentage as percentageof total in that of total in thatclassclass100.00

100.00100.00Percentage ofaggressiveorders

Percentage ofdirected orders

0.00

Disclosuresa)b)c)

CLSA or its affiliate acting as executing broker will take into account a range of execution factors. The usual order of priority will be as follows:
Price, speed, likelihood of execution, size, costs, and any other relevant execution factor.
CLSA Europe B.V. uses its regional affiliates for execution of orders.

No specific financial arrangements are in place with execution venues.
There were no changes in venue usage in 2022.
e) CLSA Europe B.V. takes all sufficient steps to obtain the best possible results for its professional clients. Although this obligation does not
apply to eligible counterparties, CLSA will always strive to act in such clients’ best interest. This RTS 28 report contains professional client
trade data only.
f) Our policy for executing client orders is set out in our order execution policy, and whilst price and cost are primary considerations there
can be situations where other factors such as size and liquidity become significant in achieving best execution for our clients.
g) RTS 27 does not apply to CLSA Europe B.V.
h) CTP was not utilized when making execution decisions.
d)Please see Terms and Conditions of Use: www.clsa.com/terms-and-conditions-of-use/
For Past RTS 28 reports, please contact: compliance.EMEA@clsa.com

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0.00

CLSA Europe B.V. RTS 28 Top 5 Venue 2022
Debt Instruments – Bonds
1.

Execution Factors Explained
Explanation of the importance CLSA gave to the execution factors of price, costs, speed, and likelihood ofexecution or any other consideration including qualitative factors when making assessments of the quality ofexecution.
As specified in CLSA’s Order Execution Policy, CLSA’s Fixed Income department operates on a purely
Request fort Quote (RFQ) basis whereby clients are not legitimately relying on CLSA in relation to theexecution of transaction on the basis that the nature of the market is that a client will generally request
quotes from a number of different dealers from which the client will have transparency and choice ofthe prices at which transactions can be effected in the market. In accordance with the FCA Rules, RFQ
markets are not subject to the general provisions of the FCA’s Best Execution requirements andtherefore do not apply.

2.

Disclosure of Close Links, Conflicts of Interest and Common Ownership of Execution Venues
Description of any close links, conflicts of interests, and common ownerships with respect to any execution
venues used to execute orders.
CLSA is wholly owned by CITIC Securities International Company Limited. Through CITIC Securities,
CLSA has regional affiliate relationships in the United Kingdom, United States and APAC. CLSA uses its
regional affiliates for execution of orders and in the case of bonds during the period covered used CLSA
(UK). CLSA looks to ensure that affiliates provide a global execution capability to CLSA clients whererequired. In addition, CLSA requires its affiliates to ensure clients have access to liquidity in exchanges,
alternative trading systems and bank / broker liquidity where relevant. CLSA ensures appropriate
standards of execution which are consistent with our Order Execution Policy requirements.

3.

Specific Arrangements with Trading Venues
Specific arrangements with any execution venues regarding payments made or received, discounts, rebates or
non-monetary benefits received.
CLSA does not have any specific arrangements with any external execution venues or brokers used toexecute client orders in bonds regarding payments made or received, discounts, rebates or nonmonetary benefits received.

4.

Reviewing Execution Venues
Explanation of the factors that led to a change in the list of execution venues listed in the Firm’s execution
policy, if such a change occurred.
The assessment to add, remove or vary venue and broker routing and connectivity is done on an
ongoing basis by CLSA’s Order Execution Committee. During the period this report covers there wereno changes to any execution venues used by CLSA.

5.

Client categorization and execution
Explanation of how order execution differs according to client categorisation, where the Firm treats such
category of client differently and where it may affect order execution arrangements.
As specified in CLSA’s Order Execution Policy, CLSA’s Fixed Income department operates on a purely
RFQ basis whereby clients are not legitimately relying on CLSA in relation to the execution oftransaction on the basis that the nature of the market is that a client will generally request quotes froma number of different dealers from which the client will have transparency and choice of the prices atwhich transactions can be effected in the market. In accordance with the Mifid rules, RFQ markets are
not subject to the general provisions of the Best Execution requirements and therefore do not apply.

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CLSA Europe B.V. RTS 28 Top 5 Venue 2022
6.

Tools utilized to generate RTS 28 disclosures
Explanation of how the investment firm has used any data or tools relating to the quality of execution,
including any data published under RTS 28.
As specified in CLSA’s Order Execution Policy, CLSA’s Fixed Income department operates on a purely
RFQ basis whereby clients are not legitimately relying on CLSA in relation to the execution oftransaction on the basis that the nature of the market is that a client will generally request quotes froma number of different dealers from which the client will have transparency and choice of the prices atwhich transactions can be effected in the market.
For information on our best execution monitoring, please refer to our Order Execution Policy.

7.

Consolidated tape provider
Explanation of how the investment firm has used output of a consolidated tape provider established underArticle 65 of Directive 2014/65/EU.
Currently not applicable as no such data have yet been published in accordance with Article 65 ofDirective 2014/65/EU (MiFID II Directive).

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CLSA Europe B.V. RTS 28 Top 5 Venue 2022
Class of instrument

Bonds

Notification if <1 average trade per N
business day in the previous year
Top five execution venues ranked in LEI
terms of trading volumes(descending order)

Proportion of Proportion ofvolume traded ordersas a
executed aspercentage of percentage of
total in that
total in thatclassclass

CLSA (UK)100.00%213800VZMAGVIU2IJA72

100.00%Disclosuresa)b)c)d)e)f)g)h)

For debit instruments, CLSA or its affiliate acting as executing broker operates on a purely RFQ basis in line with our Order Execution Policy.
CLSA Europe B.V. does not have any close links, conflicts of interests, or common ownerships with respect to any external execution venues orbrokers used to execute client orders in debt instruments.
No specific financial arrangements are in place with execution venues.
There were no changes in venue usage in 2022.
CLSA’s Fixed Income department operates on a purely RFQ basis and in line with Order Execution Policy.
Our policy for executing client orders is set out in our order execution policy.
RTS 27 does not apply to CLSA Europe B.V.
CTP was not utilized when making execution decisions.

Please see Terms and Conditions of Use: www.clsa.com/terms-and-conditions-of-use/

30th April 2023