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HomeMiFID II
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MIFID II




INTRODUCTION

The Markets in Financial Instruments Directive (MiFID) first came into effect in
November 2007 and was the foundation of the Financial Conduct Authority's (FCA)
Conduct of Business (COBS) rules. MiFID consists of the Markets in Financial
Instruments Directive and the Markets in Financial Instruments Regulation
(MiFIR).

MiFID II is the cornerstone of European Capital Markets regulation and considers
developments in the trading environment, advances in technology and the need for
greater transparency for investors and regulators. The regulations were
officially adopted in June 2014 but did not come into effect until January 2018.

MiFID II is one of the most significant pieces of legislation in recent years.
The regulation touches all areas of the business for asset managers, investment
banks, and trading venues and is considered to be one of the most challenging
and costly regulatory initiatives to date.

As a regulation, MiFIR is directly applicable to firms and will effectively sit
alongside FCA rules as its own mini rulebook - the FCA has no power to transpose
the regulation’s requirements.

What is changing


OUR MIFID REGULATED ENTITIES

Entity  Legal Entity
Identifier (LEI)  FCA Registration
Number (FRN)  abrdnIML - abrdn Investment Management Limited 
ONN53RF43KDRFCB1J158   188406  abrdnCL - abrdn Capital Limited 
5493006SPX6SO7EJ6B87  466684  IISL - Ignis Investment Services Limited 
213800GAL1S9UIG83646  121895  abrdnIL - abrdn Investments Limited 
549300EI2QZDOKF0UR93  121891  abrdnAIL - abrdn Alternative Investments Limited 
ITME2JXGKN2DXQ6A9Y56  193707 

 

Entity  Legal Entity
Identifier (LEI)  CBI Reference
Number  aIIL - abrdn Investments
Ireland Limited  2138007AHIT6ZR316H03  C181127 


EMT, EPT AND EET INFORMATION

EMT

The European Fund and Asset Management Association (EFAMA) has endorsed and
published the European MiFID Template (EMT), a MiFID information exchange
template jointly designed by product manufacturers, such as asset managers, and
distributors.

The template provides a functional description of the minimum set of data
(defining a product’s target market, distribution strategy and disclosing its
costs and charges) from product manufacturers, such as asset managers, to
distributors to help them fulfil the new regulatory requirements. These new
requirements came into effect when financial products were distributed after 3
January 2018.

EMT CSV Format
EMT Excel Format
EMT Disclaimer


EPT

EFAMA have also endorsed the use of the European PRIIPS (Packaged Retail and
Insurance-based Investment Products) Template (EPT) as a standardised
methodology for distributing PRIIPS information between investment firms and
insurance entities.

The template provides a functional description of the minimum set of data (e.g.
risk and performance calculations, cost and charges information etc.).

Both the EMT and EPT are in a pipe delimited .csv format since they need to be
machine readable.

abrdn EMTs and EPTs are being hosted by Donnelly Financial Solutions (UK)
Limited.

The file format is in accordance with FinDatEx guidelines, as a CSV file is
required. The XLS format also published on the website is for your convenience.
Since the implementation of MiFID II / PRIIPs we have issued an EMT and an EPT
file from which you can identify those ISINs of particular interest.

Please do not hesitate to contact abrdnsupport@dfinsolutions.com should you have
any questions or have comments regarding these EMT/EPT files.

EPT CSV Format
EPT Excel Format
EPT Disclaimer


EET

endorsed and published the European ESG Template (EET). The EET is an industry
form that provides fund distributors and insurers with information on the
sustainability characteristics of funds, including information required under EU
regulation. The EET enables distributors to provide advice in line with their
clients’ sustainability preferences, for the purpose of fulfilling ESG-related
regulatory requirements contained in the SFDR, relevant provisions of the
Taxonomy Regulation, and the relevant delegated acts complementing MiFID II and
IDD.

abrdn EET Excel Format
EET Disclaimer
abrdn EET CSV Format


PS 17/20

With effect from 3 January 2018, in response to a request from the governance
body of a relevant pension scheme, firms must provide:

 * information about transaction costs calculated according to the ‘slippage
   cost’ methodology
 * information about administration charges
 * appropriate contextual information

Where firms do not have the relevant information, they must seek it from other
firms, and those other firms, where they are Financial Conduct Authority (FCA)
authorised, must provide the information.


DCPT & FVPT

A joint ABI/IA working group has developed the DC Workplace Pensions Template
(DCPT) and the Fair Value mid-Price Template (FVPT) for the purpose of providing
insurers with transaction costs data in accordance with COBS 19.8.4R. DCPT V1.0
was issued in December 2017 and FVPT V1.0 was issued in May 2018.

Beginning with the January 2021 data, we are sending a single combined abrdn
file with the DCPT for the AAM and SLI fund ranges. This streamline follows the
merger between AAM and SLI in August 2017.

No change is required on your part, you will be able to continue to filter for
your required data as you do now, simply from a larger file. We reassure you
that this combined DCPT will process as our previous DCPT files have; however,
should you have any issues do not hesitate to contact us.

Negative transactions costs have been overwritten to zero in DCPT field 02010 to
ensure compliance with FCA rules around treatment of anti-dilution mechanisms
(COBS 19.8). The actual calculated transaction cost can be seen in DCPT field
02020. Guidance relating to this approach was released in the UK DC Workplace
Pensions Template V1.1, issued in April 2020.

DCPT CSV Format
DCPT Excel Format
DCPT Disclaimer
FVPT Excel Format


BEST EXECUTION

Best execution means achieving the best possible result for customers when
executing their orders.

MiFID II aims at achieving extensive transparency over investment firms' order
execution methods. Moreover, investment firms like abrdn are required to install
thorough reporting and monitoring mechanisms in order to evaluate whether the
execution quality achieved corresponds to the quality promised in the Order
Execution Policy (OEP).

At abrdn we have worked to produce a single OEP that applies to abrdn and the
two heritage entities of Aberdeen Asset Management and Standard Life
Investments.

Order Execution Policy


MIFID II TOP 5 REPORTS

Annual publication on specific 'quantitative and qualitative' information
related to the Top 5 Brokers and venues through which client orders were
executed, on a per asset class and per client type basis, is required. abrdn has
made this annual report available for the relevant entity below.

Aberdeen Standard Investments Ireland Limited - 2021


PRODUCT APPROVAL PROCESS

The product approval process is integrated into abrdn’s Product Life Cycle which
governs all new fund launches and their on-going review and monitoring.

abrdn’s Product Life Cycle is centred around client needs and requirements. At
the product concept and feasibility stage client analysis, in particular target
market identification, forms a key part of instigating the product design and
overall launch proposal to be approved by the relevant internal and external
Boards/committees prior to launch.

On-going product monitoring and reviews are conducted by abrdn’s Product team.

abrdn’s Product Life Cycle


DISTRIBUTOR GOVERNANCE & OVERSIGHT

WHO IS A DISTRIBUTOR?

Product Manufacturers must oversee the activity of their appointed Distributors
to ensure that financial instruments are reaching the clients for whose needs,
characteristics and objectives they are considered compatible (i.e. the target
market). In turn Distributors are required to provide due diligence information
and data to assist in this.

abrdn has designed the below “Categories Table” confirming which counterparty
types we view as distributing our funds, and the level of oversight and data
exchange we require under our Product Governance Process:

Counterparty Category Counterparty
sub-category Distributor AML/KYC ume onboarding KPIs required Platform Advisory
Yes Yes Yes Yes Platform Execution only Yes Yes Yes Yes Platform Technology
platform (also referred to as order routing platform, clearing house or trading
platform) No Yes No No Investment / fund manager Discretionary
Advisory Yes Yes Yes* No Fund of Funds N/A No Yes No No Wrap arrangements /
product manufacturers Unit-linked products or with-profits policies No Yes No No
Independent Financial Adviser (“IFA”) N/A Yes Yes Yes* No Non-UK/EEA distributor
US broker dealer (other sub-categories may be introduced) Yes Yes Yes Yes
Introducer N/A No Yes No No Marketer/promoter N/A No Yes No No

*only where there is a direct distribution agreement in place with abrdn


WHAT DOES THIS MEAN FOR YOU AS OUR DISTRIBUTOR?

We ask our distributors to:

 * Complete an annual distributor due diligence questionnaire via the ume
   platform & answer any follow up queries
 * Provide regular Distributor KPIs (see “abrdn FAQ: Distributor KPIs”)
 * Take part in a Site Visit / Knowledge Share meeting if deemed necessary (e.g.
   for key strategic relationships or where a knowledge share is required in
   line with regulatory themes)


DISTRIBUTOR KPIS

Until a standard industry approach to Distributor KPIs is agreed, the abrdn
Investments Vector firms will request 5 KPIs from counterparties we deem to be
“Distributors” under our Product Governance Process as follows:

KPIs 1. Suspicious transactions Number of suspicious transactions relating to
abrdn funds reported to local authorities by the Distributor in the reporting
period. We do not look for details on individual cases (unless our involvement
is required) but rather this KPI is intended to demonstrate that Distributor
processes and controls are effective (or otherwise) 2. Target market Number of
deviations from positive target market (or within negative) which relate to the
distribution, marketing or promotion of abrdn funds by the Distributor in the
reporting period 3. Complaints Number of complaints received relating to the
distribution, marketing or promotion of abrdn funds or the funds themselves by
the Distributor in the reporting period 4. Marketing incidents Instances of
non-compliance with marketing country requirements and/or errors in marketing
materials relating to the abrdn funds in the reporting period 5. Distribution in
prohibited countries Instances of non-compliance with distributing funds in any
jurisdiction where the fund is not permitted to be distributed as determined by
the product manufacturer Format To be submitted via the KPIs section of the ume
portal, at no cost to the Distributor (or submitted by email to
distributorkpis@abrdn.com where the Distributor is unable to provide the data
through ume) Frequency Required monthly in line with abrdn’s Distributor
Governance & Oversight Process. Where a Distributor is unable to submit KPIs
monthly, we can accept quarterly or annually. Data must be broken down per month
even if submitted less frequently.

Whilst our strong preference is to encourage Distributors to engage with us via
our chosen distributor due diligence partner ume, creating efficiencies and
consistency of approach for all parties, we can accept KPIs via email where
required in line with the Distributor’s process. It is expected that a standard
industry template will be agreed during 2023/2024. Until such time, abrdn has
created a simple excel template (5 data points only, approx. 10 minutes to
complete if the data is available to you). The template is available from the
Distributor Governance & Oversight Team (details below). Alternatively, we can
accept the Distributor’s preferred format. Once completed please send
to distributorkpis@abrdn.com

Please see a PDF copy of our Distributor Categories and KPI information.


SHARE CLASS REGISTRATION

Please note abrdn funds and their respective sub-Funds and share classes must be
made available to clients of our Distributors in accordance with the applicable
regulations permitting non-public offers (for example private placements or
reverse solicitation).  

The authorisation status of each sub-Fund and share class of abrdn’s Luxembourg
SICAV fund range is available at:

http://www.abrdn.com/en/luxembourg/distributors/fund-centre/lux-fund-authorisations.

Also, the distribution restrictions list for abrdn’s Luxembourg SICAV fund range
is available at Distribution restrictions (abrdn.com).

For abrdn’s UK domiciled Fund ranges, these are generally only available for
sale in the UK. The Distributor should always check with the relevant management
company if there are any queries of the permitted jurisdictions for
distribution.


CONTACT US

The abrdn Distributor Governance & Oversight Team is ready to assist you with
any queries. You can also reach out to your dedicated abrdn Client Relationship
Manager.

Distributors of UK Funds: Distributors of Luxembourg Funds: Send us your KPIs:
UKDistributorGovernance@abrdn.com LuxDistributionOversight@abrdn.com
distributorKPIs@abrdn.com

IMPORTANT INFORMATION

Risk warning – Investment involves risk. The value of investments, and the
income from them, can go down as well as up and an investor may get back less
than the amount invested. Past performance is not a guide to future results.


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MiFiD II
Modern Slavery Statement
Copyright © abrdn plc 2023. All rights reserved.abrdn plc is registered in
Scotland (SC286832) at 1 George Street, Edinburgh, EH2 2LL


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