2019 Under MiFID II, a new EU regulation, it is a requirement for investment firms to publish their top five recipients of investment orders for the previous calendar year. This quantitative data must be presented for all asset classes in which the investment firm is active, on behalf of both Retail and Professional Clients. In addition to this, firms are required to provide a qualitative Summary Analysis which comments on the conclusions the investment firm has drawn from their monitoring of the quality of the execution of these orders. Please find attached the Best Execution Disclosure on behalf of Stonehage Fleming Investment Management Limited which addresses these new requirements.