UK Disclosures 1. Annual publication of ... - mlp.com

1 UK publication of information on the identity ofexecution venues and on the quality of execution (MiFID IIRTS 28 disclosure) slavery taxstrategyAnnual publication of information on the identity of executionvenues and on the quality of executionAnnual publication of information on the identity of execution venues and on the qualityof executionReport for the calendar year ending 31 December 2017 OverviewMillennium Capital Partners LLP ( the Firm ) is an investment firmauthorisedand regulated by the FinancialConduct Firm is obliged to publish on its website certain information on its use of execution venues in thepreceding year, as required by Commission Delegated Regulation 2017/576 ( RTS 28 ) and CommissionDelegated Regulation 2017/565 of Directive 2014/65/EU ( MiFID II ). The Firm is also obliged to publish asummary ofthe analysis and conclusions it draws from its detailed monitoring of the quality of executionobtained on the execution venues in the previous Firm is a discretionary investment manager whose clients for the purposes of the FCA s Conduct ofBusiness Rules are overseas affiliated companies and fall within the definition of per se Professional Firm manages portfolios of assets pursuant to a delegation of investment management discretion to it byits 1 of this report setsout data on the Firm s top five execution venues and investment firms in each class offinancial instruments that the Firm traded in the calendar year ending 31 December 2017, in the form specifiedby RTS 28.

2 As this report covers the Firm s trading activities in 2017, prior to MiFID II coming into force, someof the information required by the MiFID II rules was not available or only partially available. Accordingly, thisreport has been prepared on a best efforts basis using such information as is available to the Firm for 1 of this report refers to direct and indirect execution. The Firm uses these terms to refer to thefollowing types of client order execution:(i) direct execution of orders by the Firm directly as a member or participant of a trading venue, orwith a systematic internaliser, market marker, liquidity provider, or direct counterparty (such as inOTC markets);(ii) indirect transmission or placing of orders by the Firm with another investment firm for executionby the other firm ( a broker). For the avoidance of doubt, in the context of its portfoliomanagement activities, the Firm treats decisions to deal which are made by the Firm on behalf of itsclients as constituting client orders for the purposes of this Part 1 of this report, each execution venue or broker is ranked by trading volume for asset classes traded bythe Firm.

3 All values are reported in percentages and roundedto two decimal 2 of this report sets out a summary of the Firm s analysis and conclusions from its detailed monitoring ofthe quality of execution obtained on the execution venues and investment firms where it executed note that this document is not marketing or promotional material and has been prepared and publishedto ensure compliance with MiFID II disclosure 1 Class of InstrumentEquities Shares & Depositary ReceiptsNotificationif <1 average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in thatclassPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersMillennium International ManagementLP(Q0HK1 ORK3 JOMOF7R6K47) Capital Management(Singapore) Pte. Ltd.(549300 AXO1 FZJHHY8I21) Capital Management AsiaLtd(549300PT1F3CP6WB2C66) for the above asset class represent indirect of InstrumentDebtInstruments-BondsNotificat ion if <1 average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion ofordersexecutedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersHSBC BankPLC(MP6I5 ZYZBEU3 UXPYFY54) Bank PLC(G5 GSEF7 VJP5I7 OUK5573) Chase Bank, NA(7H6 GLXDRUGQFU57 RNE97) , NA(E57 ODZWZ7FF32 TWEFA76) Prebon (Securities) Ltd(549300 BMVW85YF9 FGN67) for the aboveasset class represent direct of InstrumentDebt Instruments Money Market InstrumentsNotification if <1 average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)

4 Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersNomura International PLC(DGQCSV2 PHVF7I2743539) Lynch International(GGDZP1 UYGU9 STUHRDP48) Bank PLC(G5 GSEF7 VJP5I7 OUK5573) Chase Bank, NA(7H6 GLXDRUGQFU57 RNE97) AG(851 WYGNLUQLFZBSYGB56) for the above asset class represent direct of InstrumentInterest rates derivatives-Futures and options admitted totrading on a tradingvenueNotification if <1 average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedaspercentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersBarclays Capital Inc(AC28 XWWI3 WIBK2824319) Lynch, Pierce, Fenner & SmithInc(8 NAV47T0Y26Q87Y0QP81) Chase Bank, NA(7H6 GLXDRUGQFU57 RNE97) Partners Limited(549300Y58 ZORST3US624) Drax Honore (UK) Ltd(549300 WYFIFDMB6 POR04) for the above asset class represent indirect of InstrumentInterest rates derivatives-Swaps, forwards, and otherinterest rates derivativesNotification if <1 average trade per business day in theprevious yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersBarclays Bank PLC(G5 GSEF7 VJP5I7 OUK5573) Sachs International(W22 LROWP2 IHZNBB6K528) Chase Bank, NA(7H6 GLXDRUGQFU57 RNE97) t G n raleSA(O2 RNE8 IBXP4R0TD8PU41) PLC(RR3 QWICWWIPCS8A4S074)

5 For the above asset class represent direct of InstrumentCredit derivatives-Futures and options admitted to tradingon a trading venueNotification if <1 average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotalin that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersGoldman Sachs & Co. LLC(FOR8UP27 PHTHYVLBNG30) CapitalInc(AC28 XWWI3 WIBK2824319) Morgan Securities LLC(ZBUT11V806 EZRVTWT807) Prebon (Securities) Ltd(549300 BMVW85YF9 FGN67) , NA(E57 ODZWZ7FF32 TWEFA76) for the above asset class represent indirect of InstrumentCredit derivatives-Other credit derivativesNotification if <1 average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersCitibank, NA(E57 ODZWZ7FF32 TWEFA76) Sachs International(W22 LROWP2 IHZNBB6K528) Paribas(R0 MUWSFPU8 MPRO8K5P83) Bank PLC(G5 GSEF7 VJP5I7 OUK5573) Stanley & Co.

6 InternationalPLC(4 PQUHN3 JPFGFNF3BB653) for the above asset class represent direct of InstrumentCurrencyderivatives-Futures and options admitted totrading on a trading venueNotification if <1 average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asapercentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected Morgan Securities LLC(ZBUT11V806 EZRVTWT807) Investimentos Corretora DeCambio, Titulos E Valores MobiliariosS/A(549300CO4Q7A6U0 PDU26) Distribuidora De Titulos EValores Mobiliarios Ltda.(549300E262HP3Y3 PSP77) for the above asset class represent indirect of InstrumentCurrency derivatives-Swaps, forwards, and other currencyderivativesNotification if <1 average trade per business day in the previous yearNTop 5execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersHSBC BankPLC(MP6I5 ZYZBEU3 UXPYFY54) AG(BFM8T61CT2L1 QCEMIK50) Bank AG(7 LTWFZYICNSX8D621K86) Suisse International(E58 DKGMJYYYJLN8C3868) Bank PLC(G5 GSEF7 VJP5I7 OUK5573) for the above asset class represent direct of InstrumentEquity Derivatives-Options and Futures admitted totrading on a trading venueNotification if <1 average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)

7 Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersMillennium International ManagementLP(Q0HK1 ORK3 JOMOF7R6K47) Capital Inc(AC28 XWWI3 WIBK2824319) Sachs & Co. LLC(FOR8UP27 PHTHYVLBNG30) Capital Management(Singapore) Pte. Ltd.(549300 AXO1 FZJHHY8I21) Capital Management AsiaLtd(549300PT1F3CP6WB2C66) for the above asset class represent indirect of InstrumentEquity Derivatives-Swaps and other equity derivativesNotification if <1average trade per business day in the previous yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersJPMorgan Chase Bank, NA(7H6 GLXDRUGQFU57 RNE97) AG(BFM8T61CT2L1 QCEMIK50) Suisse Securities (Europe)Limited(DL6 FFRRLF74S01HE2M14) Bank PLC(G5 GSEF7 VJP5I7 OUK5573) Sachs International(W22 LROWP2 IHZNBB6K528)

8 Forthe above asset class represent direct of InstrumentCommodities derivatives and emission allowancesDerivatives-Options and Futures admitted to trading on atrading venueNotification if <1 average trade per business day in theprevious yearNTop 5 execution venues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersCitigroup Global Markets Inc.(MBNUM2 BPBDO7 JBLYG310) Prebon (Securities) Ltd(549300 BMVW85YF9 FGN67) Securities LLC(UPPK3261S5D7DR01JY66) Financial Limited(5493003 EETVWYSIJ5A20) Morgan Securities LLC(ZBUT11V806 EZRVTWT807) for the above asset class represent of InstrumentCommodities derivatives and emission allowancesDerivatives-Other commodities derivatives and emissionallowances derivativesNotification if <1 average trade per business day in the previous yearNTop 5 executionvenues ranked interms of volume (descending order)Proportion ofVolume traded asa percentage oftotal in that classProportion oforders executedas percentage oftotal in that classPercentage ofpassive ordersPercentage ofaggressive ordersPercentage ofdirected ordersCitibank, NA(E57 ODZWZ7FF32 TWEFA76) Futures USA LLC(549300H8XV7W7WR2RX20) Global Markets Inc.

9 (MBNUM2 BPBDO7 JBLYG310) for the above asset class represent direct 2 Summary of analysis and conclusions regarding quality of execution obtainedWhen executing a transaction for one of its clients or placing an order with a third party for execution onbehalf of one of its clients, the Firm acts in the best interests of the complying with thisobligation for the calendar year ending 31 December 2017, the Firm was obliged to take all reasonablesteps to obtain the best possible result taking account of relevant execution factors, such as price, cost,likelihood of execution and settlement, size, nature of the transaction and any other trading on behalf of its clients, the Firm considered the relative importance of each execution Firm used its experience and expertise to achieve the best balance across the full range of factors,including instances where such factors may conflict with each other.

10 The Firm has processes in place tomake sure best execution is being consistently ranking of execution factors was determined on a trade by trade basis, by reference to thecharacteristics of the order, underlying financial instruments and available execution venues. Generally,however, price was the most important execution factor, across all classes of instruments, theexecution price of the financial instrument (before costs) plus all costs associated with acquiring ordisposing of the relevant financial instrument, including both explicit costs (such as commissions chargedby third party brokers) and implicit costs (such as movements in the price of the financial instrument as aresult of the execution). However, there may have been circumstances where the primary executionfactors varied and total price was no longer the dominant execution example, whenexecuting illiquid securities, liquidity and likelihood of execution were also important factors executing orders in over-the-counter markets, price was again given the highest relativeimportance in obtaining best execution, but there were circumstances in which size requirements didnot permit execution at best priceand other execution factors ( likelihood of execution) were givenequal or greater executing orders in over-the-counter markets, the Firm assesses thefairness of the price proposed by gathering market data and, where possible, comparing with similar orcomparable Firm may pass orders to its affiliates to execute on a trading venue or with a broker.