Aurelius Financial Group Limited Luxembourg S.A.

RTS 28 and Article 65(6) Disclosure

Aurelius Financial Group Limited Luxembourg S.A. (“ARYEX Luxembourg”) authorised and regulated by the Commission de Surveillance du Secteur Financier (“CSSF”), fully delegates portfolio management and trading for its in-scope Markets in Financial Instruments Directive (“MiFID") clients to its affiliates, Aurelius Financial Group Limited, LLC (“ARYEX Investments”) and Aurelius Financial Group Limited (UK) Limited (“ARYEX UK”) (hereafter collectively referred to as ‘ARYEX’).

As part of ARYEX Luxembourg’s regulatory commitment and to increase transparency related to executing client orders, in accordance with MiFID II (Markets in Financial Instruments Directive 2014/65/EU) and Commission Delegated Regulation (2017/565) supplementing MiFID II, ARYEX Luxembourg is required to summarise and publish, on an annual basis, best execution information and data in order to enable its in-scope MiFID clients and the public to evaluate the quality of ARYEX’s execution practices.

In particular, ARYEX has identified and analysed the top 5 execution venues (as required under MiFID II Regulatory Technical Standard (RTS) 28) and the top 5 execution brokers (as required under MiFID Delegated Regulation Article 65(6)), in terms of trading volumes in the classes of financial instruments that ARYEX executes on behalf of ARYEX Luxembourg’s in-scope MiFID clients and provided information on the quality of execution obtained.

The analysis and reporting data in respect of ARYEX Luxembourg’s RTS 28 and Article 65(6) disclosures can be found using the links on this page.