Best Execution: Client Summary
Your consent to our Best Execution Policy
Please take care to ensure that you read and understand this Best Execution Summary before you commence any transactions involving Deliverable FX Forward, Deliverable FX Option Dated Forward or Deliverable FX Swap.
If you have any objections, please let us know as soon as possible but in any event before you issue any instructions. Once you commence issuing instructions, you shall be deemed to have read and consented to the terms and conditions of this summary, unless you notify us of any objections in advance of the provision of your first instructions. In addition, unless you notify us otherwise, we shall consider your continued placement of instructions to constitute your continued consent to Barclays Corporate Banking executing orders on your behalf over the counter (OTC).
This document sets out a summary of the Best Execution Policy only for the UK operations of the Corporate Bank of Barclays Bank PLC (‘Barclays Corporate’) (the “Policy”). Our approach to providing Best Execution is in accordance with the requirements of the European Union Markets in Financial Instruments Directive (‘MiFID II’) and the rules of our regulator, the Financial Conduct Authority (‘FCA’).
Before we undertake any orders on your behalf, it is important that you understand how we will execute such transactions. The following summary of our Policy is intended to provide you with a general understanding of the typical dealing arrangements we use for Foreign Exchange (FX) transactions (explained in Part 3 below) and the execution venues we use (explained in Part 4 below).
Best Execution is the requirement, when Barclays Corporate is executing a client order, to take all reasonable steps to obtain the best possible result for our clients on a consistent basis, taking into account various factors such as price, cost, speed, likelihood of execution and settlement, size, nature or any other relevant execution consideration (‘Best Execution’) (explained in Part 2A below).
It is important to note that when you give us specific requirements relating to the execution of your order, this may affect the extent to which Best Execution applies (please see Part 2B below).
The information below sets out general information with respect to our approach to Best Execution under MiFID II and how we assess whether a transaction falls under the scope of the Policy (explained in Part 1 below). Please note that this information should not be seen as a prescriptive statement of how a particular order must be dealt with.
Part 1 – Scope: when we apply best execution to client transactions
The Policy applies to all clients classified by Barclays Corporate as Retail clients, for certain types of transactions in Financial Instruments. A Financial Instrument has a particular meaning under MiFID II which includes, but is not limited to, FX derivatives. We will apply our Best Execution to all FX derivative client transactions.
You will have been informed of how Barclays Corporate has classified you either when you were initially on-boarded into Barclays Corporate, or as part of the Barclays Corporate MiFID II client outreach. However, if you have any questions about your classification, please speak to your usual Barclays Corporate contact. For the avoidance of doubt, nothing in the Policy shall result in Barclays owing you any fiduciary responsibilities.
Part 2A – Process by which we determine the relative importance of the execution factors
When executing an order on behalf of a Retail client, Best Execution is primarily determined in terms of total consideration. Total consideration is the price of the relevant Financial Instrument, plus costs related to execution, including all expenses incurred by you which are directly related to the execution of the order, such as Barclays’ fees and charges, execution venue fees and settlement fees.
There are other execution factors to be considered and which may be given precedence over the immediate price and cost consideration but only insofar as they are instrumental in delivering the best possible result in terms of total consideration. These are:
- Speed of execution;
- Likelihood of execution and settlement;
- Size and nature of order;
- Market impact; and
- Any other implicit transaction costs.
The applicability of, and importance attached to each execution factor will vary according to the type of transaction that is being executed and the instructions that you give us. In determining the relative importance of these factors, we will use reasonable judgment together with our understanding of the appropriate execution criteria for the specific transaction. For example, when transacting a large order, minimising market impact might be more important than price. In contrast, when trading an illiquid product (for example, Over the Counter Deliverable FX Forward), certainty of execution might be more important than price.
Part 2B – Process when you provide specific instructions regarding execution
Where we owe you a duty of Best Execution but you provide us with specific instructions in relation to the entire transaction, or any particular aspect of the transaction (for example, where you instruct us to execute the order within a particular timeframe or at a particular price), then, if we are willing to accept your requirements, we will execute the transaction in accordance with your instructions and, in doing so, we will have satisfied our Best Execution obligations with respect to the relevant aspects of the transaction.
Where your specific instructions relate to only part of the transaction, however, the remaining element of the transaction not covered by your specific instructions will continue to be subject to Best Execution requirements.
Please note that if you provide us with specific instructions, this may change the way in which we would normally execute your transactions and may prevent us from taking the steps that we have designed and implemented in accordance with the Policy to obtain the best possible result for the execution of your in-scope transactions.
Part 3 – Our typical dealing arrangements for Foreign Exchange (‘FX’)
The FX market in which we deal is wholly over the counter (OTC) across all FX products we offer to you.
You can trade with us electronically or via voice contact with the Corporate Banking Execution Team.
Part 4 – Execution venue
As Barclays Investment bank will be the sole execution venue upon which we execute your FX transactions, there will only be one execution venue in your Top Five Annual Execution Venue report (Excel document) and Quality of Execution summary (Excel document).
Part 5 – Policy governance and review
We will monitor the effectiveness of the Policy and its implementation in order to identify and correct any deficiencies.
We have a governance framework in place which includes a Best Execution Oversight Forum which is responsible for reviewing the business on an on-going basis to ensure that we continue to comply with our Best Execution obligations.
We will undertake a review of the Policy at least annually and will notify you of any material changes.
If you wish to discuss the application of Best Execution to your transactions, please contact your usual Barclays Corporate contact.
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