Annual ‘RTS 28’ Best Execution Disclosure

Disclosure Period: 01/01/2020 to 31/12/2020

Firm name: SV Health Managers LLP

This disclosure if being made pursuant to RTS 28 and Article 65(6) of the MiFID II Delegated Organisational Regulation, which require firms to adhere to a best execution policy and to make an annual disclosure regarding execution quality obtained during the period. This disclosure requires that for each class of financial instruments traded for clients during the period, the top 5 execution venues by trading volume are published along with a summary of the analysis and conclusions drawn from the execution quality monitoring that was undertaken. This requirement applies at firm level but should only include investment activity that is subject to MiFID.

SV Health Managers LLP (“SV Health”) is authorised and regulated by the Financial Conduct Authority (“FCA”) as a Full-scope UK AIFM. This scope of permission allows SV Health to act as the AIFM to a number of AIFs, and in addition to provide MiFID portfolio management services to managed accounts and third party funds on a delegated basis. At present, SV Health acts as AIFM in every case where portfolio management services are provided. These services are conducted under AIFMD and are subject to the AIFMD best execution requirements. This activity is exempt from MiFID II as a result of the Article 2(1)(i) exemption that applies to the managers of collective investment undertakings. The MiFID II best execution rules do not therefore apply to these portfolio management activities, including the RTS 28 and Article 65(6) disclosure requirements referred to above.

SV Health is therefore making this disclosure to confirm that it is aware of and complying with its obligations under RTS 28 of MiFID II, and that there is nothing to disclose for the Disclosure Period noted above. SV Health is satisfied that it has complied with all of its best execution obligations during the Disclosure Period.

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