NEWTON
ORDER
EXECUTIONPOLICY
Version 5.0 January 2024

Effective January 2024

CONTENTS
I.

Purpose and scopeII.

Exclusions

III.

How will orders be executed for the client?

IV.

Best execution obligation and relevant factors (including relative importance)V.

Execution venues

VI.

Factors affecting the choice of execution venue (including relative importance)VII.

Selection and monitoring process for execution venues

VIII.

Executing orders outside a trading venue

IX.

Specific instructions

X.

Aggregation and allocation

XI.

Monitoring and review

XII.

ReportingAppendix A: List of execution venues

2

I.

PURPOSE AND SCOPEPURPOSEThis document sets out the execution policy and approach to providing best execution for clients of Newton
Investment Management (‘Newton’1 or ‘we’), as required by the Markets in Financial Instruments Directive
2014/65/EU (‘MiFID’).
Newton places and executes orders across multiple asset classes, including equities, derivatives, fixed income,collective investments and currencies.
When we execute orders, MiFID requires us to take all sufficient steps to obtain the best possible result for our clients,
taking into account price, costs, speed, likelihood of execution and settlement, size, nature, or any other consideration
relevant to the execution of the order. This applies whether we are executing orders on behalf of clients or placing
orders with/passing orders to others for execution.
The obligation to take all sufficient steps to obtain the best possible result for clients is referred to as our obligation ofbest execution.

SCOPE
This policy applies only to trades executed by Newton on behalf of its clients, acting as their agent, and only todealings in financial instruments (each as defined in MiFID).
This policy only applies to those clients of Newton that have been categorised as professional clients under MiFID.

II.

EXCLUSIONS

Newton’s order execution policy does not treat different categories of clients differently. We do not undertake direct
execution; all execution decisions are made by a central desk within Newton which executes according to a single
policy. We may be limited to the extent to which we are able to achieve the best possible result for our clients in cases
where we are following a specific instruction from our clients in placing an order with a counterparty for execution (seealso section ix ‘Specific Instructions’).

III. HOW WILL ORDERS BE EXECUTED FOR THE CLIENT?
When executing orders on behalf of our clients we take all sufficient steps to obtain the best possible result (‘best
execution’) for our clients taking into account all relevant factors, including: price costs (implicit and explicit)
 size speed likelihood of execution
 likelihood of settlement
 any other factor relevant to the execution of the order.
The relative importance of each of these factors within our dealing process will vary depending upon a number ofcriteria, namely:1.

the investment intent of the portfolio manager who created the order;2.

the characteristics of financial instruments that are the subject of that order; and3.

the characteristics of the execution venues to which that order can be directed.

1 The term ‘Newton’ is used in this document to refer to: Newton Investment Management Limited (NIM)3

We state the relative importance of these factors in general situations in the asset class-specific sections below.

IV. BEST EXECUTION OBLIGATION AND RELEVANT FACTORS
When executing orders, we will take all sufficient steps to achieve best execution. The factors that we will consider
when executing orders are as follows:Price

The price at which a financial instrument is executed

Speed

The time it takes to execute a transaction

Costs

The implicit costs such as the possible market impact, and explicit external costs (e.g.
trading commissions or financial transaction taxes such as UK stamp duty)

Size

The size of the transaction executed for a client accounting for how this affects theprice of execution

Settlement and execution

Likely to be relevant where certainty that a particular trade will be settled efficiently
and without problem takes precedence over other factors, for example in response toan urgent client-driven request

Nature of the transaction
and/or market

The particular characteristics of a client transaction can affect how best execution
is received

Relative execution factor importance:

Best execution does not demand that firms achieve the best possible results with every trade but stipulates that thefocus is on taking all sufficient steps for obtaining the best possible result on a consistent overall basis via a clearly
defined process of policy, execution, review and refinement. Below we describe the key features of our approach to
the execution of orders across different asset classes:

A. EQUITIESNewton selects from the range of available equity execution strategies to connect with major or desirable execution
venues and counterparties and to maximise access to liquidity or, where relevant, to minimise the impact on price ofan order.
Equity orders are placed electronically via an execution management system or directly to the counterparties using the
Financial Information Exchange (FIX) connectivity messaging protocol in order to allow access to counterpartyprovided proprietary trading algorithms and multiple venues or exchanges, as well as minimise the risk of transactional
error. Alternatively, equity orders are placed via telephone or over the Bloomberg messaging service.
Accessing counterparty-provided algorithms is a key component of Newton’s execution capabilities as these tools
proffer control, anonymity and customisation potential, leading to better execution outcomes for Newton’s clients.
Newton employs a risk, competency and control framework over these trading tools to mitigate the risks associatedwith automated execution and this is available to our clients for inspection on request.
Where appropriate, for example where there is a significant number of orders appropriate for a simultaneoustransaction, Newton may use commoditised (‘program’) trades that can be executed to optimise trading efficiency andreduce the cost to the client. In this instance Newton can use a preferred pre‐trade analysis tool to review generalliquidity parameters to guide the execution strategy. Examples of where Newton may use program trading include newmoney from clients (‘inflows’), dealing with client outflows or implementing asset allocation changes.
4Subject to Newton’s aggregation and allocation policy, multiple client equity orders are aggregated for efficiency and inorder to achieve a better execution result overall.
The diagram below shows the relative importance that Newton generally places on the execution factors when
executing an equity trade. These can vary according to liquidity, urgency and volatility but we will generally use priceas our leading execution factor for this asset class.

B. FIXED INCOME
The fixed-income markets are not centrally traded in the same way that equities generally are and, for many non‐government debt issues and in certain regions, are significantly less liquid.
For those relevant financial instruments for which there is an observable market price, under standard market
conditions we will research a variety of different execution venues or counterparties. We will seek to trade an orderwith the execution venue or counterparty that provides the most attractive price and is also able to address any otheraspects of the transaction that are material to it.
Newton may trade via electronic trading platforms and voice/telephone auctions. Trades will typically be executed
electronically but larger trades may be undertaken directly with a market maker or broker. Newton will use electronic
dealing platforms which have a ‘request for quote’ model that electronically recreates an auction process andautomatically generates an audit trail of the quotes received from counterparties including brokers.
Quotes are generally obtained from more than one counterparty where there are multiple potential counterparties for atransaction that can be contacted without adversely affecting the relevant market and inadvertently compromising theability of Newton to obtain the best price available. However, such an approach is not always possible or desirable, forexample in certain less liquid markets or prevailing market conditions or where there is only one counterparty forlarge-size orders.
If only one counterparty offers a quote, for example in less liquid markets or where we believe the size of the order
may have an adverse effect on the market and inadvertently compromise the ability of Newton to obtain the best priceavailable, we will make a judgement on whether the price is fair and achieves best execution for the client. Examplesof the factors that Newton considers in making this judgement include, but are not limited to, historical comparison to
pricing of bonds of similar maturity, credit quality, size of issue, urgency of completing the trade, third-party vendor
pricing if available, and external or internal pricing models or tools.
Subject to Newton’s aggregation and allocation policy, multiple-client fixed-income orders are aggregated for
efficiency and in order to achieve a better execution result overall.
The diagram below shows the relative importance that Newton generally places on the execution factors when
executing a fixed-income trade. These can vary according to liquidity, urgency and volatility but we will generally use
price as our leading execution factor for this asset class.

5

C. FOREIGN EXCHANGE (FX)
Foreign exchange (FX) trades are conducted either through a client’s appointed custodian bank or through a thirdparty bank on Newton’s list of approved counterparties. Newton undertakes an active negotiation process with regard
to those direct FX transactions it undertakes for clients.
Where Newton does retain responsibility for FX trading, all dealing is executed via the FXall and FX Connect
multilateral trading facilities (MTFs), which allow electronic routing and execution of trades. Prior to trading, and wherepermitted, currency exposure will be netted as much as possible to ensure we are trading in the most efficient manner.
All rates offered by our banks are collated through the relevant MTF platform; should the rates quoted beunsatisfactory, they will be challenged to ensure we are achieving the best execution.
All FX spot trading undertaken by Newton is actively negotiated. Trades are either executed with the client’s custodianbank or with a bank from our approved list of third-party counterparties. For certain transactions we would put banks incompetition with each other. This decision to initiate a competition would depend on currency pair, size of deal andmarket conditions at the time, but typically we would ask up to 10 banks to quote on each FX trade, using thefunctionality within FXall and FX Connect where appropriate.
Subject to Newton’s aggregation and allocation policy, multiple client FX orders may be aggregated for efficiency andin order to achieve a better execution result overall. Transactions in the same currency pair can also be netted off
against each other, resulting in one side of the trade receiving a better price than that which would have been received
if traded separately.
However, in certain circumstances, Newton may execute FX transactions with a client’s custodian, which may not be
an approved counterparty. The circumstances in which Newton may execute an FX transaction with a client’s
custodian are as follows:i.

the client has authorised Newton to execute FX transactions with the client’s custodian only; or theclient has not authorised Newton to execute FX transactions with any approved counterparty other than theclient’s custodian;ii.

the transaction relates to a restricted currency, in which case it is typically affected through a standing
instruction arrangement;iii.

Newton has given standing instructions to the client’s custodian for the purposes of operational efficiency,
typically where the transaction relates to the repatriation of income;iv.

transacting with the client’s custodian is appropriate having regard to the best execution factors listed above; orv.

the client’s custodian is an approved counterparty.

Please note that Newton may not obtain competitive quotes or monitor the rates obtained in cases (i), (ii), (iii) or (iv)above.
(Please also note that Newton does not perform an assessment of counterparty risk or any similar due diligence inrespect of a client’s custodian, unless it is also an approved counterparty.)
The diagram below shows the relative importance that Newton generally places on the execution factors when
executing an FX trade. These can vary according to liquidity, urgency and volatility but we will generally use price as
our leading execution factor for this asset class:6

D. EXCHANGE-TRADED DERIVATIVES
When undertaking transactions in this asset class Newton considers all execution factors other than price to generate
a selection of potential counterparties appropriate for a particular order. In certain cases, this process can result in
there only being one counterparty deemed appropriate for a particular order. This process is followed to ensure
aspects such as counterparty risk or the risk of settlement failure are minimised. Price is then used as the execution
factor across the chosen subset of counterparties to select the particular execution venue or counterparty for eachtrade. Orders can be placed electronically to the counterparties, potentially using a ‘request for quotes’ process, orover the phone. Exchange-traded derivatives may also be traded on exchange through counterparties at prevailingmarket prices if liquidity permits.
Listed futures in both equity and bond contracts are placed with an approved trading counterparty which will then tradethese on a trading venue. UBS and JP Morgan act as our futures clearing members.
The diagram below shows the relative importance that Newton generally places on the execution factors when
executing an exchange-traded derivative trade. These can vary according to liquidity, urgency and volatility but we will
generally use settlement and execution, followed by price, as our leading execution factors for this asset class.

E. OTC DERIVATIVESAll over-the-counter (OTC) derivative products must be traded under industry legal documentation. This means our
choice of counterparty for trading currency forward contracts OTC derivatives is generally limited to thosecounterparties where the required documentation is in place. As with the process for bond trading detailed above, how
we execute an OTC derivative trade will be very much dependent on the nature of the instrument, the size of thetransaction and the liquidity available. Generally, Newton’s exposure to OTC derivatives is limited to forward FX,
custom basket TRS and US/Euro Index CDS. All counterparties in this asset class will be required to have theappropriate legal documentation in place before we trade with them.
Forward Foreign Exchange Contracts (FFX)
Deliverable and non-deliverable forward FX trades are typically traded with one counterparty from our approved
counterparty list, selected by our trader based on a number of factors including previous execution quality, urgency
and whether shorter settlement is required. Should there be a need to close out a forward or roll to a future date, thiswould typically be done with the same bank, subject to any execution quality concern or counterparty credit concern.
These trades may also be dealt through one counterparty.
The diagram below shows the relative importance that Newton generally places on the execution factors when
executing a Deliverable and non-deliverable forward FX trade. These can vary according to liquidity, urgency andvolatility but we will generally use price as our leading execution factor for this asset class.

7

Other OTC Derivatives
Due to their nature, OTC derivatives are usually traded on a principal (“risk”) basis rather than on a trading venue.
However, in some instances regulations require that certain derivatives will be traded on a Swap Execution Facility(“SEF”) where we are trading for a US client or with a US counterparty. We will utilise the SEF offered by one of themarket platform operators for these trades.
For bespoke OTC derivatives, such as risk premia strategies packaged as a TRS, Newton Dealers will work withthe portfolio manager who has agreed terms with the market maker and place the trade with that counterparty;
depending on liquidity, the trade will be executed over the following days and a final price provided, which is thenchecked as far as possible to its component terms and verified with the portfolio manager.
For more generic OTC derivatives, including (but not limited to) relative variance swap trades, and which are ofstandard market size, we will follow our customary trading process of asking at least two counterparties with whom
we have the required legal documentation in place to price the instruments in competition, and then selecting thecounterparty with the most favourable price, except where in our assessment working with a single counterparty
reduces the market impact and signalling risk in exposing our trading intentions more widely.
The diagram below shows the relative importance that Newton generally places on the execution factors when
executing other (i.e. non-FFX) OTC derivatives trades. These can vary according to liquidity, urgency and volatility
but we will generally use size followed by price and settlement and execution as our leading execution factors forthis asset class.

F. STRUCTURED FINANCE INSTRUMENTS
Due to the illiquid and OTC nature of these financial instruments, cost and nature of the order will be prioritisedalongside price as the primary criteria to obtain the best possible result. Structured Finance Instruments are fixed term
products with no secondary market. Given the restricted market, with one market maker for each product, Structured
Finance Instruments trading, by definition, takes place with the issuers’ market maker.
The assessment of price is a collaborative process through the portfolio manager and the Newton Dealer to check theprices provided by the market maker against the components of the product and market movements before execution.
Newton will challenge prices that fall outside this assessment. Where the market maker fails to make a price theinstruction will not be executed until a price is provided.
The diagram below shows the relative importance that Newton generally places on the execution factors when
executing a structured finance instrument trade. These can vary, but as above, we will generally use price and natureof the order as our leading execution factors for this asset class.

8

V.

EXECUTION VENUES

In transacting an order, we will only use a counterparty or market maker that has been approved in accordance withour counterparty approval process which governs the review, approval and monitoring of each counterparty or market
maker with whom we trade.
The performance of each approved counterparty or market maker is subject to periodic monitoring and review, which
includes consideration of a range of matters including execution and settlement capability, execution rates (whereapplicable), credit quality, and effectiveness of previous executions.
Eligible counterparties or market makers for the purposes of an order will be limited to those counterparties or market
makers that have been approved as described above and provided that, for OTC financial instruments, an appropriate
International Swaps and Derivatives Association Master Agreement, Global Master Repurchase Agreement or similar
legal agreement is in place.
This execution policy includes, for each class of financial instrument in which we execute orders on behalf of ourclients, information on the different venues where we execute orders. These venues are listed in Appendix A.

VI. FACTORS AFFECTING THE CHOICE OF EXECUTION VENUE
Subject to any specific instructions that may be given by clients, Newton will execute an order by one of the following
methods or combination of methods:
 on a regulated market, multilateral trading facility (MTF), an organised trading facility (OTF), or asystematic internaliser; outside of a regulated market or MTF where Newton has obtained the client’s prior express consent
The factors affecting the choice of execution venue will have due regard to the intent of the portfolio manager who has
initiated the order, and who may transmit certain parameters to the order for the Newton dealers (as a distinct function
from the portfolio managers) to observe. Portfolio managers may set a price limit on trades but are prohibited fromdirecting a dealer to use a particular venue. The Newton dealer’s choice of execution venue will be in the main
dictated by an assessment of prevailing market conditions allied with the knowledge of the portfolio manager’s intent
for the trade.
Generally, Newton’s dealers will look to minimise the transaction costs associated with any given trade in order topreserve the value of the investment decision.

VII. SELECTION AND MONITORING PROCESS FOR EXECUTION VENUES
Our policy is to maintain a choice of venues and counterparties that provide the basis for Newton to consistently
obtain the best possible result for the execution of client orders. Although ultimately owned by The Bank of New York
Mellon Corporation, Newton has full flexibility to select trading execution venues on the basis of best execution.
Our policy is to avail ourselves of an optimal number of trading venues and entities for equity trades and to select one
or more of these venues which we believe is appropriate to the trade, determined on a trade-by-trade basis.
Examples of venues or entities that we might access include: brokers which transact on our instruction on regulated markets, through their own MTF or as a systematicinternaliser (either on a principal basis, using their own capital to facilitate our orders, or on an agency basis,working the orders against market liquidity); other independent MTFs where trades can be executed away from the exchange order books; and other non-broking firms which act in the capacity of systematic internaliser and which can provide liquidity incircumstances where we need to consume it.
In order to keep trading costs to a minimum, we aim to identify venues which are sources of natural liquidity before
entering an order into the market. If natural liquidity does not exist for our order, we use market information and ourdealers’ experience to select a broker to execute the order for us on an agency basis, being careful not to expose toomuch of our order to the market in order to avoid impact costs. This is a general strategy adopted when speed is aless important factor than, say, price or the ability to retain anonymity.
9

VIII. EXECUTING ORDERS OUTSIDE A TRADING VENUE
On occasion Newton may execute an order outside a trading venue, for example bilaterally with a counterparty. Thesetransactions will be performed solely with counterparties which have passed the necessary requirements to reside on
the Newton approved counterparty list, where the attendant criteria include a careful and risk-based assessment ofcredit and counterparty risk.

IX.

SPECIFIC INSTRUCTIONS

Our ability to achieve the best possible result, and hence our obligation to do so, will be limited in cases where we arefollowing a specific instruction from our clients when placing an order with another entity for execution. Specific client
instructions may prevent Newton from taking the steps it has designed and implemented to obtain the best possible
result for execution.
Where we receive specific instructions from a client in relation to every aspect of a transaction, such that we have nodiscretion over how an order is executed, we will execute so far as reasonably possible the transaction in accordancewith those instructions.
Where we receive specific instructions from a client in relation to any aspect of a transaction (for example, where theclient instructs us to execute the order on a particular venue, at a particular time or at a particular price), Newton must
execute the transaction in accordance with such instructions. By doing so, we will satisfy our obligation to provide best
execution in relation to that aspect of the order.

X.

ORDER AGGREGATION AND ALLOCATIONAGGREGATION.
Recognising that Newton has a team-based approach for significant investment ideas, we operate a Material Change
Notification process, where all portfolio managers are immediately sent an alert in the investment management
system about any order that arrives with the Newton Dealers containing a change in portfolio positioning, for any funds
contained within the order, above a defined threshold. All orders, regardless of their materiality, follow the aggregation
protocol outlined below. To minimise the potential for any order participants to be disadvantaged by aggregation,
instructions received for the same security in the same direction are aggregated into a single order unless any of thefollowing criteria are met:
 local market or regulatory requirements mean that aggregation is not possible;
 the original order has been fully executed;
 the order is for spot FX and the order participant’s custodian is not a Newton-approved counterparty; or the orders do not follow the same trading strategy (for example limit orders cannot be combined with
non-limit orders).
 small trades are submitted which are to meet cash flow requirements, under certain pre-defined criteria
If an instruction is to be aggregated with an order that has already been initiated and has been partially executed, theproceeds or securities from the partial execution are first allocated to the original order participant(s) promptly prior to
the aggregation of the subsequent instruction with the residual balance. This ensures that any subsequent orders
cannot benefit from, or be disadvantaged by, any market movements that may have occurred since the original order
was received.
Each order participant receives the average price obtained during the time in which they were part of the aggregatedorder.

TRADE CO-ORDINATION
Newton operates a global internal research policy with its US affiliate which allows for internally generated research to
be shared with its US affiliate, Newton Investment Management North America (NIMNA). Due to its different operating
10

models, all trades placed by NIMNA will continue to be executed by its trading team independently from Newton’s
trading team for the foreseeable future.
Newton recognises that although each firm acts independently in the execution of trades, both firms and theirinvestment teams will leverage the same research recommendations and capabilities. As a result, there is a possibility
that the same trade could be executed simultaneously by Newton and NIMNA. In highly liquid securities, such
independent simultaneous trades are unlikely to materially detriment the outcome for clients of Newton and NIMNA.
However, this may not be the case for highly illiquid securities.
All client trades will be subject to each of their firm’s Trading and best execution policies and oversight procedures toensure that potential and actual conflicts of interest and risks are appropriate managed. However, Newton haveadopted a synthetic trade co-ordination approach as a pre-trade control which notifies Newton dealers in London andits affiliate NIMNA dealers in the US when they are trading in the same stock in the same direction above a preagreed combined liquidity threshold.
All dealers will then take all steps necessary to co-ordinate execution between them to optimise the market
participation of the trades to avoid price impact and ensure fair allocation between both sets of client executions.

ALLOCATION
A. Allocation of fully completed orders
Once an order has been fully completed (fully executed in the market), the proceeds or securities are promptly
allocated in full to all order participants. Typically, this would occur within two hours of the order completion or ‘open
period’ finishing, if during normal office hours, or promptly the following morning if completed outside of normal officehours.

B. Allocation of partially completed orders
Where it has not been possible to fully complete an order by the end of the trading day, the partial execution isallocated promptly to each order participant (a ‘partial allocation’). Typically, this would occur within two hours of theclose of the relevant market if during normal office hours, or promptly the following morning if completed outside ofnormal office hours. The residual balance of the order is held over for the next trading day. Allocations are made on a
pro-rata basis for equities, derivatives, collective investments, and currencies.
For fixed income, in relation to both buy and sell orders, allocations are made on a pro-rata basis unless this would
leave a participant with a position which does not meet the minimum piece size. Where this occurs, the balance formsa ‘residual allocation balance’ which is allocated to order participant(s) (selected on a random basis) which did meetthe minimum piece size based on their pro-rata allocation.

XI. MONITORING AND REVIEWThe Head of Dealing (HoD) (or, where appropriate, senior designate) is responsible for the ‘first line of defence’
controls in relation to the dealing function at Newton, and in particular for day-to-day monitoring of execution quality.
In practical terms and for the most part this comprises examination of transaction cost analysis data provided by
Newton’s independent third-party analytics providers for equities, spot and forward FX transactions, derivatives andfixed income.
The HoD receives a daily report which comprises a headline summary of the previous day’s trading, broken down by
region, last day, quarter-to-date and year-to-date statistics.
Any significant outliers against pre-defined benchmarks are reviewed daily by the HoD and, where necessary, raisedwith the Newton dealer in question if the information explaining the deviation is not already available from theinformation in the system.
For trades where a nominally adverse result is obtained, and no explanation is readily put forward, this is reviewed
with the Newton dealer in question to establish potential improvements to the Newton dealer’s strategy choice, andtactical choices, where appropriate.
Newton’s Dealing Oversight Group monitors the effectiveness of execution arrangements that are described in thisdocument (including the order execution policy itself) and the scope of the best execution obligation. It also assesses
11whether the execution venues that we have selected provide the best possible result for client transactions that are
subject to best execution
We will review this order execution policy and our order execution arrangements at least annually. We will monitor theeffectiveness of our order execution arrangements at least annually and assess on a regular basis whether the
execution venues we have selected provide for the best possible result for orders we execute. We will also review andmake any modifications required to this policy, including the relative importance of the best execution factors.
Changes to this policy may be communicated via our website newtonim.com and we will also periodically notify you of
any material changes to our order execution arrangements or this order execution policy. (The addition or removal of abroker from our approved counterparty list would not typically be deemed a material change.)

XII. REPORTING
Newton historically made available annually via its website newtonim.com the top five execution venues and top fiveexecution counterparties it uses for each class of financial instrument traded. This additionally provided information on
the volume and number of orders executed on each execution venue.
This requirement was removed by the Financial Conduct Authority (FCA) in 2021; however, this information willremain on Newton’s website until further notice. Information regarding Newton’s executing venues and counterparties
is available to clients on request.

12

APPENDIX A: LIST OF EXECUTION VENUES (NON-EXHAUSTIVE AND
SUBJECT TO CHANGE):
Equity and fixed income
Venue

Primarily used for

ABG Sundal Collier Partners LLP

EquityANZ Bank (Europe) Ltd

Fixed income

Bank of America Merrill Lynch International Ltd

Equity and fixed income

Barclays Capital Securities Limited

Equity and fixed income

Berenberg, Gossler and Co

EquityBGC Partners Inc

Fixed income

BNP Paribas

Fixed income

Canaccord Genuity Limited

EquityCBA Europe

Fixed Income

Canadian Imperial Bank of Commerce London

Fixed income

Cantor Fitzgerald Europe

Equity and fixed income

Citigroup Global Markets Limited

Equity and fixed income

CLSA (UK)

EquityCowen Execution Services

EquityCredit Suisse Securities (Europe) Limited

Equity and fixed income

Daiwa

Equity and fixed income

Deutsche Bank AG

Fixed income

DNB Bank ASA

Fixed income

Flow Traders

EquityGoldman Sachs International

Equity and fixed income

Goodbody

EquityHSBC Bank Plc

Equity and fixed income

ING Bank N.V

Fixed income

Instinet Europe Ltd

EquityInvestec Bank PLC

EquityJ & E Davy

EquityJ P Morgan Markets Limited

Fixed income

J P Morgan Securities PLC

Equity and fixed income

Jane Street

Equity and fixed income

Jefferies International Ltd

Equity and fixed income

Liberum Capital

EquityLiquidnet Europe Limited

Equity and fixed income

Lloyds Bank PLC

Fixed income

Macquarie Capital (Europe) Limited

EquityMarketAxess Europe Limited

Fixed income
13

Mizuho International PLC

Equity and fixed income

Morgan Stanley & Co International Limited

Equity and fixed income

National Australia Bank Ltd London Branch

Fixed income

Nomura International Plc

Fixed income

Numis Securities Ltd

Equity and fixed income

Oppenheimer

Fixed income

Optiver

EquityPareto Securities

Fixed income

Peel Hunt LLP

EquityRBC Capital Markets Ltd

Equity and fixed income

Redburn (Europe Limited)

EquityRoyal Bank of Scotland Plc

Fixed income

Sanford C Bernstein Limited

EquitySociete Generale

Equity and fixed income

Shore Capital Stockbrokers Limited

EquitySinger Capital Markets Limited

EquitySkandinaviska Enskilda Banken

Fixed income

Stifel Financial Corp

Equity and fixed income

Sun Global Investments Limited

Fixed income

Susquehanna International Group

EquityToronto Dominion Bank

Fixed income

UBS Limited

Equity and fixed income

Unicredit

Fixed income

Virtu Financial

EquityWells Fargo Securities International Limited

Fixed income

Westpac Banking Corporation

Fixed income

Winterflood Securities Limited

EquityForeign exchange (FX)
Venue

Primarily used forBank of New York Mellon SA/NV Brussels

Third-party FX

Barclays

Spot and forward FX

Citibank N.A.

Spot and forward FXJP Morgan

Spot and forward FXRoyal Bank of Scotland

Spot and forward FXState Street Bank and Trust Company

Spot and forward FX

UBSSpot and forward FXMultilateral trading facilities (MTFs)
The following MTFs are used by Newton as at the date of this policy:
14

Bloomberg MTF

FXall

FX Connect

POSIT Alert

Liquidnet

MarketAxess

TradewebBIDS

Exchange-traded derivatives
Newton has dealing relationships with the following counterparties:(a)

Clearing

UBS Ltd
J. P. Morgan(b)

Execution

Bank of America Merrill Lynch
Barclays Bank
BGC
BNP Paribas
Citigroup
Goldman Sachs International
HSBC
J. P. Morgan
Morgan Stanley & Co International plc
Societe Generale
UBS Ltd

Over-the-counter (OTC) derivatives

These are counterparties with whom we have agreements in place to trade OTC Derivatives:

15

This page left intentionally blank.

This document is issued by Newton Investment Management (‘Newton’), The Bank of New York Mellon Centre, 160 Queen Victoria Street, London, EC4V 4LA.
Newton is incorporated in the United Kingdom (Registered in England no. 1371973) and is authorised and regulated by the Financial Conduct Authority in the conductof investment business. Newton is a subsidiary of The Bank of New York Mellon Corporation. Newton is registered with the SEC in the United States of America as aninvestment adviser under the Investment Advisers Act of 1940.

16