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GWG (Cyprus) Ltd — RTS28 2019

EXECUTION QUALITY SUMMARY STATEMENT ("EQSS")

Introduction

GWG (Cyprus) Limited (the “Company”), whose registered office is at 18 Kyriakou Matsi Avenue, Victory Tower, office 302, Nicosia 1082, Cyprus, is authorised and regulated by Cyprus Securities and Exchange Commission under license number 291/16.

Scope of EQSS

The Company is required to provide a summary of the analysis and assessment done, during 2019, following the monitoring of the quality of execution of orders via the Company’s execution venues. This EQSS Statement Policyhas been prepared pursuant to the European Market in Financial Instruments Directive (MiFID II) and the Commission Delegated Regulation 2017/576 (RTS28) and sets out a general overview on how the Company obtained the best possible result when executing Clients’ orders by taking into account the criteria and factors stated below during 2019. The Company urges its clients and/or potential clients to read the Statement carefully as it contains information on how the Company executes orders to various execution venues.

Best Execution factors

It is our regulatory obligation to take all sufficient steps to obtain, when executing orders, the best possible result for our clients taking into account the following factors or any other consideration relevant to the execution of the order:

a.Price (Highest Importance)

b.Costs and Charges (Highest Importance)

c.Speed of Execution (Medium Importance)

d.Likelihood of Execution (Medium Importance)

e.Likelihood of Settlement (Low Importance)

f.Size of Order (Low Importance)

g.Market Impact (Low Importance)

For orders that are not wholly covered by your specific instructions, the best possible result is assessed -when executing Client Orders against the Company’s quoted prices-by taking into consideration the abovementioned execution factors and their relevant importance.

It is further worth noting that the Company determined the best possible result in terms of the total consideration, represented by the price of the contract and the cost related to execution as the main factors. The other execution factors of speed, likelihood of execution size, nature or any other relevant consideration are, in most cases, secondary to price and cost considerations, unless they delivered the best possible result for the client in terms of total consideration. The description of each factor and how the company assess each factor can be found in the Company’s Execution Quality Summary Statement.

Conflict of Interest

The Company maintains a Conflicts of Interest Policy where it states the measures taken by the Company in managing any conflicts of interest that might arise from potential types of conflicts of interest.

Review and Monitoring

The Companymonitored the effectiveness of its Order Execution Policy during the year under review and relevant order execution arrangements in order to identify and implement any appropriate enhancements. In addition, the Company had reviewed the latter policy and the relevant order execution arrangements so as provide the best execution for its clients on a constant basis. The Company considered a range of factors in deciding whether to execute a Client’s Order. These include price, costs, speed together with any other consideration relevant to the execution of the order. In determining the relative importance of these factors the Company took into account the client’s status, together with the nature of the order, the characteristics of the financial instruments to which order relates and the characteristic of the execution venues. Prior the selection of an execution venue, the Company had considered both qualitative and quantitative criteria. In particular, the pricing and the costs in relation

to the execution of the Client’s orders and the overall impact to the Client is one of the main factors for the selection of an execution venue. Other factors have also been taken into consideration, for instance, the speed of processing and likelihood of execution as well as the financial soundness and order execution policy of such venue.

Additionally, the Company assess and monitors regularly its execution venues by assessing various execution parameters such as:

a.Price Latency

b.Negative or Positive Slippage c.Price Updates

d.Re-quotes, etc

The company also carried assessment and monitoring of the financial institutions used as hedging liquidity/price providers in order to ensure that the best possible result is provided to Clients.

Execution Venues during 2019

The Company’s execution venues during 2019 were:

# Execution Venue Country of Establishment Commencement of Relationship with the company
1 Broctagon Prime Ltd Cyprus 10/11/2017

Information on the top five execution venues (As per Annex II of the Commission Delegated Regulation (EU) 2017/576

Table 1: Retail Clients

Class of Instrument Financial Contracts for Differences (CFDs)
Notification if <1 average trade per business day in the previous year Y        
Top five execution brokers ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
Broctagon Prime Ltd 100 % LEI:213800AYVP83GMTLSE33 100% 100% 0% 100% 0%

Report Notes:

  • ECB exchange rates used as of the last trading day of 2019
  • All calculations in ‘EUR’
  • RTS 28 report reflects all closed trades as of 1.1.2019 to 31.12.2019 & open orders as of the last trading day of 2018.
  • Only one (1) Execution venues are listed representing one venue for each trading platform offered to Retail Clients as a Straight Through Processing ‘STP’ brokerage model.
  • All Data reflects Retail Client’s only as no other client categorization was granted in 2019
  • Nominal Value was used to generate proportion by percentage for Class of Instrument
  • Contract for Difference is the only Class of Instrument used as per the EMIR reporting obligations

Key Definitions under RTS 28:

"Passive Order" means an order entered into the order book that provided liquidity - not applicable to GWG (Cyprus) Ltd as we do not operate the order book.

"Aggressive Order” means an order entered into the order book that took liquidity - not applicable to GWG (Cyprus) Ltd as we do not operate the order book.

"Directed Order" means an order where a specific execution venue was specified by the client prior to the execution of the order; not applicable therefore deemed as 0%.

“Retail Client” is a client who is not a Professional Client by default and is afforded with the highest level of protection

Table 2: Professional Clients

Class of Instrument Financial Contracts for Differences (CFDs)
Notification if <1 average trade per business day in the previous year Y / N        
Top five execution brokers ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
Broctagon Prime Ltd LEI: 213800AYVP83GMTLSE33 N/A N/A N/A N/A N/A

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