Värde Partners Europe Limited

Annual publication of information on the identity of execution venues and on the quality of execution for 2017

The primary selection criterion employed by Värde Europe in connection with selecting execution venue or brokers is the ability to obtain best execution.  In assessing best execution, Värde Europe considers a variety of factors including, without limitation, pricing, market/asset knowledge, market access, reliability, settlement risk, integrity/confidentiality, financial stability, infrastructure (technology/operations) and access/responsiveness. Värde Europe generally gives primary consideration to obtaining the most favorable price and efficient execution.  Värde Europe may, however, pay a higher commission than would otherwise be necessary for a particular transaction when, in Värde Europe’s opinion, to do so would further the goal of obtaining the best available execution on an aggregate basis for the related investment. Commissions are negotiated with the broker on the basis of the quality and quantity of execution services that the broker provides, in light of prevailing commission rates with respect to any securities transactions involving a commission payment.

Värde Europe endeavors to be aware of current charges of eligible broker-dealers and to minimize the expense incurred for effecting portfolio transactions. Although Värde Europe seeks competitive commission rates, it will not necessarily pay the lowest commission or commission equivalent. Transactions may involve specialized services or unique sourcing considerations on the part of the broker-dealer involved, resulting in higher commissions or their equivalents than would be the case with transactions requiring more routine services.  The reasonableness of commissions is based on the broker’s ability to provide professional services, competitive commission rates and other services that will help Värde Europe in providing investment management services to clients. The limited availability of a particular investment may also impact the selection of a broker-dealer and the related commission.

Periodically, and in no event less frequently than annually, Värde Europe will conduct a best execution review to evaluate and review brokers and dealers to assess the continued appropriateness and effectiveness of Värde Europe’s best execution procedures.  The review involves evaluation of internal data against the best execution factors and identification of potential conflicts or favouritism.  Where applicable, inputs from the Investment Professionals, the Operations groups, and  relevant market data will be obtained.

In line with Värde Europe’s policies and procedures, Värde Europe did not receive any fee, monetary or non-monetary benefits from any broker-dealer other than general reasonable business entertainment and gifts that are not lavish or excessive.

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