RBCCM Europe Non-Equity
Systematic Internaliser Commercial
PolicyRBC Capital Markets, Europe
August 2024

Page 2TABLE OF CONTENTS
1.0

Summary Statement ................................................................................ 3

2.0

Scope ........................................................................................................ 3

2.1 Categories of financial instrument ....................................................... 3
2.2 Purpose of this Policy ............................................................................ 3
3.0

Requirements ........................................................................................... 3

3.1 Provision of Quotes ............................................................................... 3
3.2 Client Access to Quotes ........................................................................ 4
3.3 Execution Terms ..................................................................................... 4
3.4 Waivers .................................................................................................... 4
3.5 Quote Access and Identifiers ................................................................ 4
3.6 Updates, Errors and Withdrawing Quotes........................................... 5© RBC

Page 31.0

Summary Statement

This document forms the RBC Capital Markets1 (“RBCCM” or the “Firm”) Europe Non-Equity
Systematic Internaliser Commercial Policy (the “Policy”). This Policy applies in cases where RBCCM
acts as a Systematic Internaliser in respect of those financial instruments that fall into any of the asset
classes set out in Section 2.1. For avoidance of doubt, this Policy does not apply to RBC Paris Branch(“RBCPB”) whose Commercial Policy when acting as a systematic internaliser in non-equity
instruments is documented separately.
A “Systematic Internaliser” (“SI”) is a 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 OTFwithout operating a multilateral system" (see Article 4(1)(20) of the Second Markets in Financial Instruments
Directive 2014 (“MiFID II”).
Following the UK’s departure from the EU, all references in this document to MiFID II or MiFIR should beread as also referring to the corresponding provision in the UK requirements, including any amends as
made by the Markets in Financial Instruments (Amendment) (EU Exit) Regulations 2018, as they apply toRBCCM entities registered in the UK.

2.0

Scope

2.1

Categories of Financial Instrument

This Policy applies to all trading in non-equity financial instruments where RBCCM is designated as aSystematic Internaliser (“Non-Equity Transactions”). For the purposes of this Policy, Non-EquityTransactions comprise:Cash bonds (RBC Europe Limited, and Royal Bank of Canada, London Branch);FX Derivatives sub-asset classes excluding FX Futures (Royal Bank of Canada, LondonBranch); and

Interest Rate Derivatives sub-asset classes excluding Bond Futures/Forwards, Bond options
and Swaptions (Royal Bank of Canada, London Branch).

RBCCM is not designated as a Systematic Internaliser in Credit Derivatives.

2.2Purpose of this Policy

This Policy is designed to clarify the following matters:when RBCCM will make SI quotes available;how clients can access RBCCM’s SI quotes; and

RBCCM’s quoting hours, identifiers, and related matters.

3.0

Requirements

As of 28 March 2024, the obligation for SIs to make public firm quotes in respect of Non-Equity
transactions (Article 18) has been removed from MiFID II and Regulation (EU) No 600/2014 of theEuropean Parliament and of the Council (“EU MiFIR"). As a result, the obligations and arrangements
below apply to RBCCM UK legal entities in relation to Non-Equity Transactions under the UK onshoredversion of Regulation (EU) No 600/2014 of the European Parliament and of the Council (“UK MiFIR”)
only.
Article 18(5) of the UK MiFIR requires a SI to make the firm quotes that it publishes in accordance withparagraph 1 of UK MiFIR available to its other clients for execution. An SI may decide on the basis ofits commercial policy and in an objective non-discriminatory way, the clients to whom it gives access toits quotes. The commercial policy must lay out clear standards for governing access to its quotes,
which can take into account commercial considerations.

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3.1

Provision of Quotes

As a SI RBCCM may be required to publish SI quotes. RBCCM will make public firm SI quotes in non1 RBC CapitalMarkets is the trading name of the following legal entities that are registered in the UK: RBC
Europe Limited and Royal Bank of Canada, London Branch and the following legal entities that are registeredin the EEA: RBC Capital Markets (Europe) GmbH and its branches, and Royal Bank of Canada, ParisBranch.

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Page 5equity financial instruments that are traded on a 'trading venue' (as defined in MiFID II) and which areconsidered 'liquid'.
RBCCM is not obliged to make public firm SI quotes in non- equity instruments in sizes above the size
specific to the financial instrument (“SSTI”) or if a waiver applies to the relevant activity. Where the nonequity instrument is considered ‘illiquid’, RBCCM will only disclose its SI quote to the individual client
who requested the quote, subject to RBCCM agreeing to do so.
RBCCM will make SI quotes available through its Approved Publication Arrangement (“APA”) TRAX. All
SI quotes will be made available during normal trading hours.
RBCCM reserves the right to limit the amount of transactions that can be executed against any quote.
The SI quotes that RBCCM makes available for ‘liquid’ non-equity instruments will be deemed executablefor up to one second after publication.

3.2

Client Access to Quotes

Subject to applicable regulation, RBCCM will allow access to SI quotes to all clients who have:accepted and complied with RBCCM's terms of business and any related contractual
documentation;are not engaged in any attempt, in RBCCM's view, to create disorderly markets, (including, butnot limited to, any action that would breach the Market Abuse Regulation, Regulation (EU)596/2014); and

complied with any technical or connectivity specifications required to receive SI quotes (as setout below under paragraph, "Quote Access and Identifiers").

However RBCCM reserves the right to refuse to provide a client access to SI quotes for the following
reasons:

Credit Status: RBCCM will not provide access to SI quotes where it considers, based on internalor external benchmarks, that there is a "credit risk" in relation to a client. RBCCM will therefore
take into account any credit status, history or position of a client in accordance with its risk
management framework before permitting such client access to SI quotes;

Counterparty risk: RBCCM will not provide access to SI quotes where it considers, based oninternal or external benchmarks, that there is "counterparty risk" in relation to a client. RBCCM
will make such a determination with reference to its internal risk management factors such as
exposure to client and external benchmarks used to calculate counterparty risk;

Settlement risk: RBCCM will not provide access to SI quotes where it considers there is a“settlement risk” in relation to such a client. Additionally, where the client does not provide
adequate details or agreements in relation to the settlement procedures that would govern atransaction, RBCCM may choose not to provide such a client with access to its quotes.

3.3

Execution Terms

Where a client has requested, and RBCCM has agreed to provide, a SI quote, the client will have theability to execute against said quote, subject to RBCCM's terms of business with the client and this Policy.
If the client does not execute against the SI quote provided, RBCCM will not be required to provide theclient with another SI quote unless agreed by RBCCM.

3.4

Waivers

To the extent applicable, RBCCM may rely on certain pre-trade transparency waivers in accordancewith UK MiFIR (each, a “Waiver”) and in such circumstances, will not be required to make an SI quotepublic.

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3.5

Quote Access and Identifiers

In relation to any SI quote that is not subject to a Waiver, the SI quote will be published and madeavailable via RBCCM's appointed APA. The quotes will be made available in accordance with applicableregulation, including publication in machine readable format. The ability of a client to access RBCCM’s
SI quotes will be contingent on said client having entered into any necessary agreement governing
connectivity and technical specifications.
A client will be able to identify an SI quote published by RBCCM in accordance with the above
procedures through the following identifiers:
RBC Europe LimitedoMarket Identifier Code (MIC) – RBCE;o

Bank Identifier Code (BIC) – ROYCGB22.

oLegal Entity Identifier (LEI) – TXDSU46SXBWIGJ8G8E98; andRoyal Bank of Canada, London BranchoMarket Identifier Code (MIC) – RBCM;oBank Identifier Code (BIC) – ROYCGB2L.

o

3.6

Legal Entity Identifier (LEI) – ES7IP3U3RHIGC71XBU11 andUpdates, Errors and Withdrawing Quotes

RBCCM reserves the right to withdraw its quotes under exceptional market conditions in accordancewith Commission Delegated Regulation (EU) 2017/56, Article 14. RBCCM has determined that suchconditions would exist where the obligation to provide firm prices to clients would be contrary to theprudent management of the risks it is exposed to in its capacity as a SI.
RBCCM may also withdraw its quotes where such quotes have been made in error, either due totechnological failure or human error, such as erroneous input values.
RBCCM may update its quotes at any time, including to reflect changes in market conditions or its risk
management or credit exposures.
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