Website Privacy Notice
Cookie Policy
Privacy Notice Investors and Investees (EU)
Best Execution Disclosure
Remuneration Policy
SFDR - Incorporation of Sustainability Risks in the Investment Process
SRD II Statement
Strategy for the Exercise of Voting Rights
MetLife Investment Management RIAIF ICAV - SFDR Article 10 website disclosures
MetLife European Private Debt Fund I
MetLife European Private Debt Fund II
Best Execution Disclosure
18 November 2025
In accordance with the regulatory requirements set out in the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”) and the Commission Delegated Regulation 2017/565 ("MiFID CDR”), on an annual basis, MetLife Investment Management Europe Limited (“MIMEL” or the “Company”) is required to summarise and make public, for each class of financial instruments, the top five execution venues in terms of trading volumes where MIMEL executed client orders in the preceding year, as well as information on the quality of the execution obtained.
The Company’s clients ("Clients”, each a “Client”) for the purposes of this disclosure are entities with which it has a segregated mandate, whether a discretionary investment management (“Individual Portfolios”, each being an “Individual Portfolio”) or non-discretionary investment advisory mandate, and entities to which it provides the services of the reception and transmission of orders (collectively hereinafter “MiFID Services Clients”, which receive “MIFID Services”), in addition to AIF and UCITS collective investment schemes (“Funds”, each being a “Fund”), such activity also being referred to as collective portfolio management or “CPM” services.
In accordance with S.I. No. 352/2011 - European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 (the “UCITS Regulations”) and the Commission Delegated Regulation (EU) No 231/2013 ("AIFMD Level II Regulation”), the Company must also make available appropriate information on its Best Execution Policy to investors in a UCITS or AIF.
This disclosure thus summarises how MIMEL will seek to achieve best execution for its clients when providing investment services to Individual Portfolios or in its management of AIFs and UCITs.
For the purposes of this disclosure, ‘executing’ shall be taken to mean executing orders or placing orders for execution arising from decisions to deal by either MIMEL, a delegate (or sub-delegate) of MIMEL, or the reception and transmission of client orders by MIMEL with other entities for execution.
Scope and Application of Best Execution Requirements
Where it is established that a duty of best execution is owed to a particular client, including the nature of this duty, the obligation to deliver the best possible result when executing Client orders applies in relation to all types of “Financial instruments” referenced in Annex I, Section C of MiFID II.
However, given the differences in market structures or the structure of Financial Instruments, it may be difficult to identify and apply a uniform standard of and procedure for best execution that would be valid and effective for all classes of instrument. Best execution obligations will therefore be applied in a manner that takes into account the different circumstances associated with the execution of orders related to particular types of Financial Instruments.
When the Company is acting as investment manager and decides to deal in financial instruments on behalf of a Client and / or when the Company is providing the service of reception and transmission of orders, it must act in accordance with the best interests of the Client when placing orders with other entities for execution. In the context of managing Individual Portfolios, when executing Client Orders, the Company is obliged to take all “sufficient steps” to obtain the best possible result for its client.
Similarly, in the context of the management of a Fund’s portfolio, the Company is required to take all reasonable steps to obtain the best possible result for a Fund when:
a) executing decisions to deal on behalf of the Fund; or
b) placing orders to deal on behalf of the Fund with other entities for execution.1 The Company considers the requirement for “sufficient” steps represents a higher bar for compliance than “reasonable” step
Annual Publication of Data – Top Execution Venues and Execution Quality
In respect of the Individual Portfolios to which it provides investment services, on an annual basis, the Company will summarise and make public, for each class of Financial Instrument, the top five execution venues in terms of trading volumes where the Company executed Client orders in the preceding year, as well as information on the quality of the execution obtained.
As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client dealing in Financial Instruments, therefore no disclosures are currently available in respect of each class of financial instrument, the top five execution venues in terms of trading volumes where the Company executed Client orders in the preceding year, as well as information on the quality of the execution obtained.
The Company will also publish on at least an annual basis and make public data regarding the quality of execution of transactions in respect of Individual Portfolios and provide confirmation of whether MIMEL has executed an average of less than one trade per business day in the previous year in that class of Financial Instruments.
As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client dealing in Financial Instruments, therefore such data is not currently available for disclosure.
Order Execution Process and General Execution Factors
The Company has implemented a Best Execution Policy which establishes a process by which the Company, or appointed delegates, will determine the relative importance of the execution factors. The relative importance that the Company gives to those execution factors must be designed to obtain the best possible result for its Client. The execution factors include: (i) price; (ii) costs; (iii) speed; (iii) likelihood of execution and settlement; (iv) size; (v) nature; (vi) any other consideration relevant to the execution of a client order.
1 Article 27 and 28 of Commission Delegated Regulations (EU) No. 231/2013 of 19 December 2012 (“AIFMD Level 2 Regulation)”, and paragraph 13 of Schedule 5 of European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 (the “UCITS Regulations”).
The Company or delegate ensures that, when determining the relative importance of the above factors, it has regard to the objectives, investment policy and risks specific to a Fund (as indicated in the prospectus or, as the case may be, in the trust deed, deed of constitution or articles of the Fund), or any investment management or advisory agreement with a Client.
(i) Price:
The market price at which the order is executed. This is usually the most important Execution Factor, which is therefore often assigned a high weighting for most client activity. This relates to the bid/offer price that is quoted for the value of the transaction to be executed.
(ii) Costs
This represents the cost covering the risks incurred by the Company by entering into a transaction, such as: a) fees or commissions b) capital requirements; c) liquidity costs; d) cost of hedging our risks resulting from those transactions. Margins and charges will be commensurate with the nature of the market, the characteristics of the transaction and the Client. Costs shall also include any additional charges that may be incurred in executing the order in a particular way.
(iii) Speed of execution
In some markets, price volatility may mean that the timeliness of execution is a priority, whereas, in other markets that have low liquidity and high latency it may be necessary to execute your order over a longer period of time. This can be particularly important in fast moving markets.
(iv) Likelihood of execution and settlement
The likelihood that the Company can source adequate liquidity with sufficient depth of market, having necessary credit facilities in place to guarantee settlement, especially for some OTC products where there is no formalised market or settlement infrastructure.
(v) Size and nature of the transaction
Ensuring that orders are executed in a manner which is suitable to the size requested and does not result in an adverse effect on the market. The way the Company executes an unusual order (for example, one that is larger than the normal market size or has unusual features such as an extended or shortened settlement period) may differ from the way the Company executes a standard order.
In certain circumstances (e.g., for some Client orders, Financial Instruments, or markets), the Company’s policy may appropriately determine that other execution factors are more important than price in obtaining the best possible execution result.
Approved Counterparty List and Execution Venues
The MetLife Global Risk Management Credit Department (“GRM”) maintains a complete listing of approved broker/dealers and derivatives counterparties (the “Counterparty Approved List”). All counterparties must be approved in accordance with the MIM Trading Counterparty Approval and Monitoring Policy. The Counterparty Approved List specifies the types of transactions that can be conducted with each counterparty or broker and any special limitations applicable to a counterparty.
In determining whether a particular broker, counterparty or execution venue is likely to provide best execution in a particular transaction, the factors below are taken into account, broken down per applicable asset class.
A list of the execution venues on which the Company places significant reliance for its Individual Portfolios (where relevant) will be published on an annual basis, as described above, or will be disclosed on this website where any material changes occur to the Company’s overarching arrangements to achieve best execution.
As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client dealing in Financial Instruments, therefore such data is not currently available for disclosure.
RTS 27 (Delegated Regulation (EU) 2017/575) is not applicable as MIMEL is not an execution venue and will not use the output of a consolidated tape provider.
Execution Factors Particular to Equity and Public Fixed Income Securities Transactions
The guiding principle in selecting a counterparty or broker from the Counterparty Approved List for a particular transaction is to seek the best possible result for the Client, taking into account:
- the overall costs of the trade (i.e., net price paid or received) including commissions (if applicable), mark-ups, mark-downs or spreads in the context of the trader’s knowledge of current pricing and transaction costs;
- the nature of the market for the security or instrument;
- the size and difficulty of the order;
- the execution experience of the counterparty with respect to specific markets or securities;
- confidentiality;
- the competitiveness of the commission;
- the certainty of execution;
- the counterparty’s capital clearance and settlement capabilities;
- desired timing of the trade;
- reputation, financial strength, and stability;
- block trading capabilities;
- access to underwritten offerings and secondary markets.
Execution Factors Particular to Derivatives Transactions
The selection of an execution venue can be contingent on market specific factors, Client guidelines and investment strategy/product considerations. Execution venues may include, without limitation: principal traders and market makers (e.g., broker/dealers), multi-lateral trading facilities (including electronic trading platforms) ("MTFs”), regulated markets or other liquidity providers.
When selecting a counterparty or broker, traders must choose the counterparty or broker from the Counterparty Approved List and ensure that any other criteria agreed with a Client have been satisfied.
The guiding principle in executing a derivatives transaction is to take all sufficient steps to achieve the best possible result for the Client, with due regard to the factors listed below:
- price and total costs of trade execution including exchange and clearinghouse fees and costs of collateralisation;
- the size and complexity of the derivative to be transacted;
- the current market for the derivative instrument, including trading/market-making liquidity and desired timing of the derivative transaction;
- confidentiality;
- derivative product and execution venue; and
- the following factors in relation to counterparties, brokers and execution venues:
- applicable credit limits of the counterparty or broker with the execution facility;
- reliability and promptness of trade executions, including the execution experience of the counterparty, broker or execution facility with respect to the derivative instruments to be traded; and
- reliability of transaction processing and settlement.
Other Assets
Other asset classes such as private debt, real estate and private equity are not Financial Instruments and therefore not within scope of best execution requirements. However, the Company acts in the best interests of its Clients and seeks to maximise overall Client results in the investment process, taking into account appropriate quantitative and qualitative factors.
Managing Conflicts of Interest
MIMEL takes all appropriate steps to prevent conflicts of interest from constituting or giving rise to a risk of damage to the interests of its Clients or investors in its Funds. Where the potential risk cannot be prevented, MIMEL must disclose this to its Client before providing services.
Trading will be directed to counterparties that are demonstrably able to deliver best execution on a consistent basis.
MIMEL will conduct periodic monitoring to verify that its best execution arrangements are adequate and working effectively without prejudicing the interests of Clients.
Ongoing Monitoring and Review
The Company, and its delegates as applicable, will monitor the execution quality obtained and the quality and appropriateness of its execution arrangements and policies, to identify circumstances under which changes may be appropriate.
The Company, and its delegates as applicable, will monitor the execution quality obtained and the quality and appropriateness of its execution arrangements and policies, to identify circumstances under which changes may be appropriate.
The Company reviews its Best Execution Policy and framework on an annual basis, or more frequently if a material change occurs that may impact MIMEL’s ability to continue to obtain the best possible execution quality for its Clients on a consistent basis following the existing arrangements. Any deficiencies identified must be appropriately remediated.
The Company will notify all Clients of any material changes to the Company’s execution arrangements or its Best Execution Policy.
Client Consent and Specific Instructions
The Company will obtain the prior consent of applicable clients to its Best Execution Policy. Where relevant, the Client will be requested to specifically consent to the provision of information on the Company’s policy via an appropriate website. In this case, the Client will be notified electronically of the address of the website, and the place on the website where the information may be accessed.
In addition, the Company will obtain the prior express consent of applicable Clients before arranging to execute its orders outside a regulated market or a MTF.
Certain fixed income instruments are listed but may trade off-exchange in a dealer market where more liquidity can be sourced, however this may increase the risk of failure by a dealer to deliver or settle orders.
If the Company or its delegate receives a specific execution instruction from a Client, including to use a counterparty with which the Client has established a derivatives trading agreement, the investment manager will execute the order in accordance with that specific instruction. Any specific instructions received from Clients may prevent the investment manager from taking some or all of the steps (or consider the factors) set forth above in implementing its Best Execution Policy, and, therefore, the investment manager will use best efforts to obtain best execution after giving effect to that Client’s instructions in such cases.
Order Execution Policy
A copy of MIMEL’s Best Execution Policy is available upon request.
For any queries, please contact Rory Caldwell (rory.caldwell@metlife.com), or by writing to:
MetLife Investment Management Europe Limited
20 on Hatch,
Lower Hatch Street,
Dublin 2,
Ireland