MetLife Investment Management Limited

Best Execution Disclosure

EU Privacy Notice

 

Best Execution Disclosure

In accordance with the regulatory requirements set out in the Markets in Financial Instruments Directive 2014/65/EU and the Delegated Regulation 2017/565 (“MiFID II”), on an annual basis, MetLife Investment Management Limited (“MIML”) has a requirement to summarise and make public, for each class of financial instrument, the top five execution venues in terms of trading volumes where MIML executed client orders in the preceding year, as well as information on the quality of the execution obtained. 

This report summarises how MIML seeks to achieve best execution for its clients and includes the following information:

1. volume of client orders executed on that execution venue expressed as a percentage of total executed volume;

2. number of client orders executed on that execution venue expressed as a percentage of total executed orders;

3. confirmation of whether MIML has executed an average of less than one trade per business day in the previous year in that class of financial instruments.

This report also explains the critical factors affecting the approach to client order execution and the relative importance that MIML gives to these critical execution factors.

 

Information on the top four execution venues and quality of execution obtained

Class of Instrument

EUR & GBP denominated public bonds

 

 

 

 

Notification if <1 average trade per business day in the previous year

Y

 

 

 

 

 

Proportion of volume traded as a percentage of total in that class

Proportion of orders executed as percentage of total in that class

Percentage of passive orders

Percentage of aggressive orders

Percentage of directed orders

Name and Venue Identifier (MIC or LEI)

Merrill Lynch International (31%)
GGDZP1UYGU9STUHRDP48

31%

n/a

n/a

n/a

Name and Venue Identifier (MIC or LEI)

Credit Suisse Securities (23%)
DL6FFRRLF74S01HE2M14

23%

n/a

n/a

n/a

Name and Venue Identifier (MIC or LEI)

UBS Limited (23%)
REYPIEJN7XZHSUI0N355

23%

n/a

n/a

n/a

Name and Venue Identifier (MIC or LEI)

RBC Europe Limited (23%)
TXDSU46SXBWIGJ8G8E98

23%

n/a

n/a

n/a

 

For all trades, price has been the most important factor when determining with which counterparty to trade, followed by ability of the counterparty to settle on time and in line with our requirements.

There have been no conflicts of interest with respect to any execution venues used. MIML 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. Where the potential risk cannot be prevented, MIML must disclose this to its client before providing services. A copy of MIML’s Conflicts of Interest Policy is available upon request.

Our trading has been directed to counterparties able to provide us with the best execution for our clients, without external influence and no payments, rebates or non-monetary benefits have been derived from these trades.

There have been no changes to the list of execution venues.

There is no differentiation in client treatment.

RTS 27 is not applicable as we are not an execution venue, and we have not used output of a consolidated tape provider.

MIML’s approach to monitoring its execution arrangements is set out in its Order Execution Policy.

A copy of MIML’s Order Execution Policy is available upon request.

 

For any queries, please feel free to contact Lisa Gray, Director - Compliance (lisa.l.gray@metlife.com or +1 973.355.4021) or by writing to:

MetLife Investment Management Limited
Level 34
One Canada Square
Canary Wharf, London
E14 5AA

 

EU Privacy Notice

MetLife strongly believes in protecting the confidentiality and security of your personal data. This document is referred to as our “Privacy Notice” and describes how we use the personal data that we collect and receive about you.

Our Personal Information Collection Statement contains some terms which you may need help understanding. These terms are listed in the Glossary at the end of our Privacy Notice. There are also hyperlinks to these terms when they appear in blue text except that as the terms personal data and processing are used so frequently, we have just put the hyperlink in this section.

How to get more help

If you want help with our Privacy Notice or have questions about it, please contact our Data Privacy Champion whose contact details are below:

Data Privacy Champion
MetLife Investments
Level 34
One Canada Square
Canary Wharf
London E14 5AA

Telephone: 020 7715 2000
Email: MetLifeInvestmentsEUPrivacyChampion@metlife.com

If you are unhappy about any aspect of the way we collect, share or use your personal data, we would like you to tell us. You can contact us using the details above.

If you are not happy with our response, you have a right to complain to the Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Tel: 0303 123 1113 or on its website at www.ico.gov.uk.

What are your rights?

We have set out a summary of your rights regarding your personal data below. Further details about your rights are contained in the Your Privacy Rights page of this Privacy Notice:

Rights

What does this mean?

1. The right to be informed

 

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we're providing you with the information in this Privacy Notice.

2. The right of access

You have the right to obtain access to your personal data (if we're processing it), and other certain information (similar to that provided in this Privacy Notice).

This is so you're aware and can check that we're using your personal data in accordance with data protection law.

For more information, see Accessing your information.

3. The right to rectification

You're entitled to have your personal data corrected if it's inaccurate or incomplete.

For more information, see Correcting your information.

4. The right to erasure

This is also known as ‘the right to be forgotten’ and enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not an absolute right to erasure. We may have a right or obligation to retain the information, such as where we are under a legal obligation to do so or have another valid legal reason to retain it.

For more information, see Erasing your information.

5. The right to restrict processing

In certain situations you have the right to "block" or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their personal data to be 'blocked' to make sure the restriction is respected in future.

For more information, see Restricting processing of your information.

6. The right to data portability

You have rights to obtain a copy of some of the personal data that we hold on you and reuse or share it for your own purposes.

For more information, see Taking your personal data with you.

7. The right to object

You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent).

For more information, see Objecting to processing.


Who we are

In this Privacy Notice, MetLife Investments Limited and MetLife Investment Management Limited are referred to as "MetLife".

MetLife will be the controller of your personal data.

How we contact you

We may contact you through one or more of the following communications channels: by telephone, mail, email, text (SMS) message, instant messaging or other electronic means.

We record some telephone calls and other electronic communications for regulatory reasons and for audit purposes. We store call and other communication recordings securely in accordance with our retention policies and applicable laws. Access to those recordings is restricted to those individuals who have a need to access them for the purposes set out in this notice.

What we learn about you

The types of personal data we hold may include your:

  • name;
  • contact details including email details and phone numbers;
  • age or date of birth;
  • passport number and passport photo page;
  • national identity numbers;
  • gender, occupation;
  • hobbies, recreational activities or sports;
  • details of any criminal convictions; and
  • education details.

We do not hold special categories of personal data about you.

How we learn about you

What we know about you is mostly provided by you or your company or agent on your behalf in connection with an investment transaction or other business relationship. You or someone acting on your behalf may provide us with personal data at various times and via various communication channels including phone, email and text, for example when you:

  • hold a role within a company that we are providing financing to and we require your personal information in order to conduct "know your customer" and related due diligence checks in relation to that company;
  • ask to have a MetLife representative contact you;
  • do business with us as a representative of a company and we need a person to contact for purposes of administering the relationship and/or financing contract with the company you represent.

We may need to check the personal data we have about you to make sure it is correct and complete with other sources such as anti-fraud agencies.

Why we need your personal data

We use the personal data we have about you to:

  • check your identity and to comply with our legal, compliance, audit and regulatory requirements;
  • provide you with the information, products and services that you request from us;
  • administer our relationship with you whilst you represent a client, counterparty or other entity doing business with us and to communicate with you relating to such relationships;
  • investigate any complaint you may make;
  • provide evidence in any dispute or anticipated dispute between you and us;
  • train our staff; and
  • monitor the quality of our products and services.

The legal basis for our processing of personal data which is not a special category of personal data

The legal basis for our processing of personal data will depend on why we process your information.

Where a company you work for or otherwise represent is involved in a financing transaction with us, we may process your personal data in order to enter into, perform, and administer such transaction.

We may also need to process your personal data to comply with our legal obligations including in relation to performing anti-money laundering, terrorism prevention and sanctions screening checks, complaints and investigations or litigation.

Where you use our website, we will process your personal data collected by using cookies in accordance with our cookie policy. Please click here to view our cookie policy.

We also have a legitimate interest to process your personal data for:

  • communications purposes;
  • ongoing management of our relationship and contracts with a company with which you are associated or which you represent or work for (e.g. providing client reports);
  • our internal business purposes which may include business and disaster recovery, document retention/storage, IT service continuity (e.g. back-ups and helpdesk assistance) to ensure the quality of the products and services we provide to you;
  • corporate transactions (please also see the section below How we treat personal data on a business sale).

Where you have given us your permission to do so, we will use relevant personal data to enable us to provide you with information about products and services that may be of interest to the company you work for, represent, or similar.

We will always seek your consent to process personal data where we are legally required to do so.

How we disclose your personal data

We may use and share your personal data with other companies in the MetLife group to:

  • help us provide products or services to the company you represent or are employed by;
  • administer the financing transactions that we enter into companies, such as the one you represent or are employed by;
  • confirm or correct what we know about you;
  • help us prevent fraud, money laundering, terrorism and other crimes;
  • comply with the law by, for example, to enable sharing your personal data with the police or fraud agencies where necessary to prevent fraud;
  • audit our business;
  • provide you with information about MetLife and the products and services that may be of interest;
  • fulfill other business purposes such as product development and website administration.

We may share your personal data with our professional advisers who help us enter into and administer financing transactions and provide services to our asset management clients. For example we may share your personal data:

  • to comply with the law or rules of any regulatory body whose rules apply to MetLife;
  • with credit reference agencies, police, consumer reporting, fraud prevention agencies, and sanctions databases and authorities (such as World Check, the United States Treasury Department's Office of Foreign Assets Control's lists of sanctioned countries, governments and individuals, and the United Kingdom's list of sanctions targets kept on the gov.UK website) to check your identity and conduct "know your customer" and other due diligence checks we consider necessary in conducting our investments business.

When we share your personal data with third parties who perform business services for us, we require them to take appropriate steps to protect your personal data and only use the personal data for the purpose of performing those services.

Other reasons we may share what we know about you include:

  • enforcing our agreement with the company you represent or are employed by;
  • protecting the rights, property, or safety of MetLife, our customers, or others; and
  • doing what a court, regulator or government agency requires us to do, for example, complying with a search warrant or court order or acting as required or permitted by applicable law or regulation.

How we treat personal data on a business sale

From time to time, we may sell or transfer one or more of our businesses to another company or affiliate, and your personal data may be transferred as a part of that sale or transfer. Any new provider will continue to use your personal data for the same purposes unless you are notified otherwise. We may also share your personal data with prospective purchasers of our business and their professional advisers, but will ensure that appropriate safeguards are in place to protect your information in such circumstances.

How we protect your personal data

The security and confidentiality of your personal data is extremely important to us. We have technical, administrative, and physical security measures in place to:

  • protect your personal data from unauthorised access and improper use;
  • secure our IT systems and safeguard the information; and
  • ensure we can restore your data in situations where the data is corrupted or lost in a disaster recovery situation.

Where appropriate, we use encryption or other security measures which we deem appropriate to protect your personal data. We also review our security procedures periodically to consider appropriate new technology and updated methods. But, despite our reasonable efforts, no security measure is ever perfect or impenetrable.

Where we transfer your information

We may transfer your personal data to other countries. The countries in the European Economic Area are considered to provide the same level of protection to personal data as the UK does. Where we transfer personal data or share it with others outside the European Economic Area, we will ensure that we and those persons or companies who we transfer it to agree to protect it from improper use or disclosure, in accordance with data protection law by model clauses or other appropriate mechanisms. Companies outside the European Economic Area with whom we may share your personal data include our other group companies, IT providers and other suppliers.

How long will we keep your information?

Our data retention policies comply with all applicable laws and privacy legislation to which we are subject. They set out how long we are allowed to retain all the different types of data we hold and are reviewed on a regular basis.

We safely and securely destroy data which we no longer need to keep in accordance with time limits set out in our policies.

How will you know if we amend this Privacy Notice?

We may amend this Privacy Notice at any time. If we make any material change in how we collect your personal data, or how we use or share it, we will prominently post notice of the changes on the websites covered by this Privacy Notice.

Governing law

This Privacy Notice is governed by English law.

 

YOUR PRIVACY RIGHTS

This section explains your rights in relation to your personal data in more detail. The various rights are not absolute and are subject to certain exceptions or qualifications.

Further information and advice about your rights can be obtained from the Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Tel: 0303 123 1113 or on its website at www.ico.gov.uk.

You are entitled to receive your personal data free of charge except in the following circumstances where we may charge a reasonable fee to cover our administrative costs of providing the personal data for:

  • manifestly unfounded or excessive/repeated requests, or
  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.

In order to exercise any of the rights described below please contact us at MetLifeInvestmentsEUPrivacyChamption@metlife.com.

How can we help?

Accessing your information

Correcting your information

Erasing your information

Restricting processing of your information

Taking your personal data with you

Objecting to processing

 

Accessing your information

What can you request access to?

You have the right to:

  • receive confirmation from us that your personal data is being processed;
  • access to your information; and
  • certain other personal data (most of which should be in our personal data notice anyway).

You can request copies of paper and electronic records (including recorded calls, where applicable) about you that we hold, share or use. To deal with your request, we can request proof of identity and enough personal data to enable us to locate the personal data you request.

When will access not be provided?

We can only provide you with your information, not personal data about another person. Also, where access would adversely affect another person's rights, we're not required to provide this. Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding.

Please clearly set out in your access request the personal data that you're requesting. If this is not clear, we may come back to you to ask for further personal data by way of clarification.

 

Correcting your information

You have the right to obtain from us without undue delay the correction of inaccurate personal data concerning you. If you tell us that the personal data we hold on you is incorrect we will review it and, if we agree with you, we will correct our records. If we do not agree with you we will let you know. If you wish, you can tell us in writing that you believe our records still to be incorrect and we will include your statement when we give your personal data to anyone outside MetLife. You can contact us using the details on the previous page at the bottom of the section entitled "Your Privacy Rights."

You may also have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Whether or not this is appropriate in any particular case depends on the purposes for which your personal data is being processed.

We need to notify any third parties with whom we've shared your personal data that you've made a rectification request (see "Why we need your personal data"). We'll take reasonable steps to do this, but if it is not possible or may involve disproportionate effort we may not be able to do this or ensure they rectify the personal data they hold.

How You Can See and Correct Your Information

Generally, we will let you see the personal data that we hold about you, or take steps to correct any inaccurate information, if you ask us in writing.

Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding.

 

Erasing your information

When can you request erasure?

Subject to the section below "When can we refuse erasure requests?", you have a right to have your personal data erased and to prevent proecssing where:

  • the personal data is no longer necessary for the purpose it was originally collected/processed;
  • you withdraw consent (where previously provided and required for us to process such data);
  • you object to the processing and our legitimate interests in being able to keep processing your personal data don't take priority;
  • we've been processing your personal data in breach of data protection laws; or
  • the personal data has to be erased in order to comply with a legal obligation.

When can we refuse erasure requests?

The right to erasure does not apply where your information is processed for certain specified reasons, including for the exercise or defence of legal claims.

More importantly, if we have to erase your data we will not be able to provide you, or the company you are employed by or otherwise represent, with our products and services, including if we need to process the erased data in connection with the administration, management or provision of products and services we provide.

Do we have to tell other recipients of your personal data about your erasure request?

Where we have provided the personal data you want to be erased to third parties (see "Why we need your personal data"), we need to inform them about your erasure request, so they can erase the personal data in question. We'll take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.

It may also be that the recipient is not required/able to erase your personal data because one of the exemptions above applies, see "When can we refuse erasure requests?"

 

Restricting processing of your information

When is restriction available?

You have the right to restrict the processing of your personal data:

  • where you disagree with the accuracy of the information, we need to restrict the processing until we've verified the accuracy of the information;
  • when processing is unlawful and you oppose erasure and request restriction instead;
  • if we no longer need the personal data but you need this to establish, exercise or defend a legal claim; or
  • where you've objected to the processing in the circumstances detailed in paragraph (a) of "Objecting to processing", and we're considering whether those interests should take priority.

Do we have to tell other recipients of your personal data about the restriction?

Where we've disclosed your relevant personal data to third parties, we need to inform them about the restriction on the processing of your information, so that they don't continue to process this.

We'll take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.

We'll also let you know if we decide to lift a restriction on processing.

 

Taking your personal data with you

When does the right to data portability apply?

The right to data portability only applies:

  • to personal data you've provided to use (i.e. not any other information);
  • where the processing is based on your consent or for the performance of a contract; and
  • when processing is carried out by automated means.

When can we refuse requests for data portability?

We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal data concerns more than one individual, we may not be able to transfer this to you if doing so would prejudice that person's rights.

 

Objecting to processing

You can object to processing in the following circumstances:

  • (a) Legitimate interests

    You have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you which is based on legitimate interests.

    If we can show compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms, or we need your personal data to establish, exercise or defend legal claims, we can continue to process it. Otherwise, we must stop using the relevant information.
  • (b) Direct marketing

    You can object at any time to your personal data being used for direct marketing purposes (including profiling related to such direct marketing).

    If you sign up to receive newsletters or other e-mail messages from us, you can opt-out at any time free of charge by clicking the unsubscribe link at the bottom of the message. You may also choose to opt-out from receiving marketing materials from us by contacting us using the details above under the section headed "Your Privacy Rights."

 

GLOSSARY

The Controller is the person or organisation which decides the purposes and means of the processing of personal data either on its own or with others.

Credit Reference Agencies are companies which collect personal data relating to the credit ratings of individuals and make it available to organisations such as insurers and banks.

Fraud Prevention Agencies collect, maintain and share, personal data internationally on known and suspected fraudulent activity.

Model clauses are standard contractual clauses which have been approved by the European Commission as providing adequate safeguards to enable personal data to be transferred outside the European Economic Area.

Personal data is any personal information relating to an individual who can be identified, directly or indirectly, by reference to that information.

Processing means any operation or set of operations which is performed on personal data such as collection, recording, organisation, structuring, storage, alteration, retrieval, consultation, use, disclosure, erasure or destruction.

Special categories of personal data are types of personal data which might show a person’s race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, details about their health and any genetic or biometric data.