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CIL Global Credit

Cowen International Limited, Global Credit:

Trading venues and qualitative report for execution obtained for 2017

Cowen International Limited, Global Credit(“CIL Global Credit””) is subject to the EU’s Markets in Financial Instruments Directive 2015/65/EU (“MiFID II”) and related Commission Delegated Regulation. Under these requirements CIL is required to disclose its execution venues and a summary of quality of execution obtained.

CIL’s Global Credit division traded with institutional Professional Clients in Bond Debt Instruments during 2017. All trades were introduced to our affiliate entity, Cowen and Company, LLC for execution. As we have alluded to in our Order Execution Policy, CIL Global Credit ’s approach is focused on achieving the best possible overall results on a consistent basis, and not merely best price for an individual order. CIL Global Credit cannot guarantee success of each order but can guarantee best efforts in obtaining an executable trade.

Trade orders are ordinarily initiated by the Client in a discontinuous OTC bond market. Due to the nature of the illiquidity in this type of market, CIL Global Credit priced the bonds based on prevailing market demand.

When Client orders were received by CIL Global Credit, the execution factors were considered and then transmitted to Cowen and Company, LLC, for execution. The execution factors include likelihood of execution, size and nature of the order, nature of the market for the bond, price, transaction cost, and speed to execute. Due to the size of the orders and the illiquidity in the market, CIL Global Credit viewed the likelihood of execution as the most relevant execution factor in order to achieve best execution for the Client.

Overall, we are satisfied that our best execution process has provided Clients the best possible execution under prevailing circumstances.

CIL Global Credit believes that routing orders via Cowen and Company, LLC enables it to obtain results for its Clients that are at least as good as the results it could reasonably expect to obtain from using alternative entities for execution.

Due to the nature of the of the discontinuous OTC bond market and CIL’s approach to order execution, information relating to the execution venues would not necessarily be representative.