Naya Capital Management UK Ltd (“Naya” or the “Firm”) is authorised and regulated by the FCA and as such is required to provide RTS 28 reports for its “top-up” activities. Naya allocates its trades on a pari passu basis for all its funds and will report top execution venues based on trades including its non-MiFID businesses. This is with the exception of currency derivatives, which are only traded in connection with the Firm’s AIF business for hedging purposes and are thus excluded from this disclosure.

RTS 28 requires Naya to disclose top 5 execution brokers from 2017/2018 split by classes of financial instruments as laid out by Annex I of RTS 28. Naya will also provide a qualitative assessment of execution as required by RTS 28.

File Content Disclosures

  • The tables of top 5 brokers include trades from 1st Jan – 31st Dec 2017/2018 respectively and encompasses all of the funds managed by Naya.
  • Tables are included for all classes of financial instruments traded by Naya. There are no tables for the following classes of financial instruments as there were no trades undertaken by Naya in those classes:
    • a) iii) Equities – Tick size liquidity band 1 and 2
    • b) Debt Instruments
    • c) Interest rates derivatives
    • d) Credit Derivatives
    • e) Currency Derivatives
    • f) Structured finance instruments
    • h) Securitized Derivatives
    • i) Commodities Derivatives and Emission Allowances Derivatives
    • k) Exchange Traded Products
    • l) Emission Allowances
    • m) Other Instruments
  • Non-EU Equity trades fall under tick size liquidity bands 5 and 6 due to the liquid nature of stocks as determined by their average traded volume.
  • Naya is a discretionary asset manager and does not receive trade instructions from their clients and, as such, no trades are directed within the meaning of RTS 28.
  • Naya does not place orders directly at execution venues but rather places orders with brokers who execute on our behalf. Therefore the tables provided encompass indirect executions with brokers who Naya have placed orders with.
  • As our orders are indirectly executed on our behalf by brokers, the passive / aggressive split for executions is not relevant and has not been included in the quantitative disclosure tables.
  • There were no securities financing transactions during 2017/2018

Download Links for Files


Tables for Top Execution Brokers: pdf csv

Qualitative Assessment: pdf


Tables for Top Execution Brokers: pdf csv

Qualitative Assessment: pdf


Tables for Top Execution Brokers: pdf csv

Qualitative Assessment: pdf

 Shareholder Rights Directive II (SRD II) Disclosure

Under obligations arising from the revised Shareholder Rights Directive (EU 2017/828) (“SRD II”), a firm which trades shares on regulated and comparable markets is required to either develop and publicly disclose an engagement policy as prescribed in COBS 2.2B.6R or disclose a clear and reasoned explanation of why it has chosen not to do so.
Naya Capital Management UK Limited (“Naya”, “our”) has elected to disclose its engagement policy as set out below. Further, firms are also required to disclose on an annual basis how the engagement policy has been implemented in a way that meets the requirements in COBS 2.2B.7R. Naya will make its annual disclosure, alongside this engagement policy, on its website.