The second chapter of the Markets Infrastructure Financial Instruments Directive, MiFID II, signals a period of great uncertainty for financial institutions and market infrastructures. Swathes of the markets for financial instruments are being completely remade. After extensive consultation, the legislative process1 is entering a critical phase with only a few rubrics still to be finalised.

1. MiFID II for Dealer Banks
How to capitalise on the creative destruction of the status quo
The second chapter of the Markets Infrastructure Financial Instruments Directive, MiFID II,
signals a period of great uncertainty for financial institutions and market infrastructures.
Swathes of the markets for financial instruments are being completely remade. After
extensive consultation, the legislative process1
is entering a critical phase with only a few
rubrics still to be finalised.
Impacts are profound. Business models and profits are under threat and the move to the
regulators’ desired future state is likely to be both painful and costly. Once the dust has
settled, the way certain markets function may be unrecognisable, with clear sets of winners
and losers.
How will you secure your place on the winning side?
This paper examines MiFID II specifically from the perspective of the dealer banks2 and the impact
on their OTC derivatives business. We identify key threats and new opportunities, suggest critical
next steps and highlight those remaining areas of uncertainty still to be resolved in the next rounds of
consultation and second level texts.
____________________
1
MiFID II has a legislative deadline of 3rd
July 2016 for conversion into domestic law and 3rd
January 2017 to take effect.
2
Any bank or broker-dealer involved in executing trades with clients, particularly OTC derivatives.

2. © Catalyst Development Ltd 2
What are the real threats?
Let’s deal with the bad news first.
As a direct consequence of MiFID II, you
will find a significant slice of your current
client execution business difficult, if not
impossible, to retain.
MiFID II greatly extends the scope of those
instruments and execution methodologies that
are closely regulated. Dealer banks who offer
client execution through any system not
currently regulated as a trading venue, along
with firms operating Multi-lateral Trading
Facilities (MTFs) which involve discretionary
and non-discretionary trading processes, all
face considerable new pressures.
Many key markets and instruments that dealer
banks previously operated bilaterally are now
likely to transition to trading on either MTFs,
or the new Organised Trading Facility (OTF)
venue type. Experience from the US shows
that the operators of such new venues
(broadly equivalent to the SEFs in the US) are
unlikely to be the dealer banks.
Unless banks push hard to build their own
MiFID II compliant venues, they will
inevitably lose much of this business.
Dealer banks who decide against establishing
an MTF or OTF but who wish to continue to
offer access to their bilateral trading systems
will need to consider whether this will lead to
them becoming classed as a Systematic
Internaliser (SI)3. Even where banks
successfully establish an SI, they will face
increasing restrictions on the instruments they
can trade in this way, reducing the amount of
business such SIs can attract.
Electronic trading of OTC derivatives is a key
pillar of EMIR, Dodd Frank and now also of
MiFID II. The concept of a central limit order
book (CLOB) – normal practice in the futures
markets – is the ultimate regulatory intent.
Overall, the MiFID II provisions seem
designed to break up dealer banks’ client
execution business, bringing key transactions
3
For a short definition of a Systematic Internaliser
see: http://lexicon.ft.com/Term?term=systematic-
internaliser
in derivatives into more transparent markets.
Dealer banks risk losing much of this
business, now having to compete on new
venues or chase smaller numbers of more
tailored trades.
And it doesn’t end there.
This changing execution landscape will
add further complexity to how you assess
your real cost of trading.
Establishing the real cost of trading is an
increasing priority for dealer banks who are
finally recognising the myriad factors they
must consider pre-execution to establish a
truly representative price. It is now widely
recognised that such factors as funding,
margin and collateral costs throughout the life
of the trade cannot be ignored and must be
specifically accounted for.
Regulatory change, and MiFID II in particular,
continues to add new complexities to this
already complicated picture. To establish the
real cost of trading properly in the MiFID II
world, a thorough pre-trade analysis be
essential and should consider in particular:
 the impact of the presence of multiple
new execution venues where the
same product can be executed;
 whether there is a material impact
from the choice of CCP for the lifetime
incremental cost of maintaining the
trade; and
 how best use of netting sets and
collateral optimisation models can
ensure you deploy funding to best
effect.
Now, selecting the correct trading and
clearing venues and collateral allocation have
been transformed from dry operational tasks
with limited options, to quasi front-office
activities with significant bearing on both
pricing and profitability.
The speed of execution will also need to
increase greatly, requiring sophisticated

3. © Catalyst Development Ltd 3
analytic tools to be embedded as part of the
OTC workflow.
In addition, as the advent of SEFs in the US
has already witnessed, the electronification of
OTC markets will see reduced trade sizes
coupled with increased volumes.
Those who fail to adapt to this new
environment or to automate their OTC
business will trail behind the pack at
significant competitive disadvantage.
Any remaining client execution business
will be less profitable and more risky.
One inevitable consequence of a move to
new, more transparent trading venues is that
trading which was previously conducted OTC
will become more commoditized, resulting in
narrower spreads. This is a natural
consequence of a move to multi dealer limit
books, which display tradable prices and sizes
from a number of market participants
simultaneously, allowing clients to more
quickly and easily see all prices in the market,
and ensure they obtain the best price.
For dealer banks who operate SIs, the
requirement to provide ‘firm quotes’4 will also
pose a challenge – applying whenever SIs
transact with clients in instruments such as
equity, bonds and derivative, which are traded
and liquid at another venue.
When making firm quotes, the SI is also
obliged to make such quotes available to
other clients, subject to a number of
restrictions. On the surface this is a laudable
aim, as quotes provided to clients by SIs are
part of price formation, and should in principle
be made more transparent.
But there are a number of scenarios,
particularly for uncleared trades, where banks
could argue that they should be able to tailor
their quote to an individual client. For
example:
 where entering into the transaction
would reduce their overall existing risk
profile with that client;
 where the client is highly creditworthy;
or
 where entering into the transaction
would lower the bank’s overall capital,
4
A fixed buy or sell price offered by a dealer or
broker-dealer firm.
funding or bilateral margining
requirements.
If banks are forced to offer a substantial
volume of their quotes to all clients, it will
become increasingly difficult – perhaps
impossible – to offer any such preferential
quotes.
Curbing preferential quotes for certain
instruments may be beneficial from a
transparency perspective, but may have also
unintended consequences for risk at the
dealer banks. For instance:
 preferential pricing can incentivise
trades that reduce risk between
counterparties;
 such preferential pricing is necessarily
specific to each counterparty
relationship, and will therefore no
longer realistically be possible in an
environment where quotes must be
offered to multiple clients; and
 there may also be a general
withdrawal of liquidity, as banks
become nervous of providing firm
quotes to clients with whom they
would rather not transact.
Meanwhile the natural consequences will
include linking the bank’s internal credit risk
systems to its trading activity to ensure trade
execution certainty.
Overall, the effect of all this is to compound
dealer banks’ pain. The removal of opacity
will put a strong pressure on spreads for those
transactions conducted on MTFs and OTFs,
while offering tailored pricing as an SI will
increase risks, as firm quotes must potentially
be offered to all clients.
MiFID II means any dealer banks wishing
to keep their client execution and clearing
business must completely overhaul their
client execution and proprietary trading
practices and accurately assess the real
cost of trading. That requires significant
investment in technology, operational
procedures and processes.
In our opinion, the critical areas of focus
should be:

4. © Catalyst Development Ltd 4
1. Pre and post-trade transparency:
get it right first time - MiFID II’s
transparency requirements greatly
increase the information you need to
process, assess and distribute, both
before and after the completion of a
transaction. Many dealer banks will
find their current IT infrastructure
inadequate to the task, requiring
investment and/or reorganisation.
With banks already reeling from fines
over MiFID 1 transaction reporting it
will be essential to get MiFID
transparency requirements right first
time.
2. Legal/operational reorganisation:
see change in the round – dealer
banks wishing to retain their
execution business will need
operational reorganisation and
enhancement to ensure their existing
execution mechanisms meet new
regulatory requirements. Given that
an OTF and an SI cannot be housed
in the same legal entity, this may well
require legal reorganisation. Many
dealer banks are already undergoing
protracted legal entity reorganisations
as a result of Basel III and any MiFID
II-related changes will need to be
incorporated into this overall scheme.
3. Connections to new platforms:
make the right choice – as with
SEFs in the US, the introduction of
MiFID II is likely to result in significant
market fragmentation, with a plethora
of new trading venues vying for a
share of the market. Connecting to
the right new venues and ensuring
efficient processing will be a
significant challenge, as practices
between venues are likely to vary – at
least initially.
4. Automation of pre-trade analytics:
deal with complexity – MiFID II adds
complications to assessing the true
cost of a trade. Enhancements to pre-
trade analytics will be essential to
ensure you get the best from your
trading, clearing and collateralisation
practices.
5. Impact on clearing: forget the past
– the old assumption that client
execution can ‘subsidise’ clearing is
dead: captive clients have decoupled.
Failing to invest now is a serious mis-
judgement, risking far more than mere
operational inefficiency. How you tackle these
key items will determine whether your
business succeeds and remains profitable.
Where are the opportunities?
Despite substantial change and challenge,
MiFID II is good news for who take the right
approach.
Upheaval in the trading landscape breaks
up the old order, opening the door to new
challengers.
Wholesale change means a number of
incumbent dealer banks will lose out – and
where there are losers there are winners. The
opportunities for challenger dealer banks who
master MiFID II are likely to be very significant
indeed.
Transparency is the new watchword.
Opacity - traditionally the defining
characteristic of the market for many
financial instruments – is turned on its
head. Those who can embrace this
mindset and culture shift and adapt
positively to the new environment will gain
ground.
By far the biggest winners are likely to be
those who can master pre-trade analytics and
establish the true cost of trading. Optimising
your use of the fragmented trading venue
landscape, streamlining your clearing
processes and creating the most efficient use
of collateral will enable you to offer the
keenest prices while still retaining – even
increasing – your profitability.
The same is true of your core data. Banks
are already striving to improve pre-trade
analytics and the transparency provisions in
MiFID II will massively increase the available
data. Finding smart ways to use this
information to your advantage will pay

5. © Catalyst Development Ltd 5
dividends.
MiFID II provides a milestone moment at
which to leverage your investment in
technology and address multiple
regulatory headwinds to your advantage.
The prevailing view is that dealer banks are
currently overwhelmed by the pace and
substance of regulatory change, much of
which requires significant investment in
technology. This includes:
 EMIR5
– the requirement to report
transactions to Trade Repositories
(TRs) has proven challenging for the
dealer banks. This is a particular
cause for concern, as in many cases
failures to satisfy the previous MiFID
1 transaction reporting requirements
have been identified, resulting in
regulatory fines. This suggests there
is further investment in technology
required before all banks are fully
compliant.
 BCBS 2396
– the need to aggregate
risk information properly is a
technology problem as well as a data
issue. Large, geographically
dispersed banking institutions rely on
disparate systems, processes and
methodologies, making it difficult for
senior management to see the big
picture, take a consolidated view and
make key decisions based on robust
information. The actual fabric of
technology infrastructure, along with
the policies and procedures that
support it, needs significant
5
The European Union regulation on derivatives,
central counterparties and trade repositories
http://ec.europa.eu/finance/financial-
markets/derivatives/index_en.htm
6
The Basel Committee on Banking Supervision’s
Principles for effective risk data aggregation and risk
reporting http://www.bis.org/publ/bcbs239.pdf
7
The report of the Independent Commission on
Banking headed by Sir John Vickers
http://www.parliament.uk/business/committees/commi
ttees-a-z/commons-select/treasury-
committee/inquiries1/parliament-2010/icb-final-report/
enhancement.
 Vickers Report7
–structural reforms
to the UK banking system (and the
equivalent Volcker rule in the US8
)
necessitate substantial organisational
restructuring for the major banks. This
will also result in a significant change
in the way in which execution and
retail, corporate and wealth
businesses interact, with greatly
reduced internalisation of business.
 Bilateral Margining and the
Fundamental Review of the Trading
Book9
– more challenges lie ahead,
as dealer banks get to grips with the
regular exchange of margin (including
replication of Initial Margin numbers
and optimising the use of collateral),
while the upgrades to trading book
risk measures require new risk
models and methodologies.
 MiFID II 10
now overlays major further
requirements for greater
transparency, speedier, more
accurate reporting, enhanced
execution, substantially improved
connectivity and pre-trade analytics
onto this already fraught landscape.
In our opinion, the sheer scale of MiFID II
and complex context into which it arrives
make this exactly the moment to take a
different approach.
8
US Commodity Futures Trading Commission
(CFTC) rules to implement Prohibitions and
Restrictions on Proprietary Trading as required by
the Dodd-Frank Wall Street Reform and Consumer
Protection Act.
http://www.cftc.gov/LawRegulation/DoddFrankAct/Rul
emakings/DF_28_VolckerRule/index.htm
9
The Basel Committee on Banking Supervision’s
principles for effective risk data aggregation and risk
reporting http://www.bis.org/publ/bcbs239.pdf
10
The European Commission’s updated rules for
markets in financial instruments
http://ec.europa.eu/finance/securities/isd/mifid2/index
_en.htm

6. © Catalyst Development Ltd 6
Many of the challenges associated with these
existing regulations and the likely future
direction of travel share a common theme: the
need for a truly strategic approach to
investment in technology, and a strengthening
of data standards that leave institutions firmly
placed to face the entire regulatory agenda,
rather than reacting piecemeal to single items
or even their compound effect.
What’s more, enhanced technology and data
standards will also convey advantages for
pre-trade analytics, and the key issue of
properly assessing the cost of trading,
benefitting the business as a whole.
You can simplify your relationships with
post trade infrastructure, lowering an
important component of trading cost.
While the trading landscape is likely to
become more complex as a plethora of new
venues emerge, the open access
requirements under MiFID offer opportunities
to simplify your post trade and clearing
arrangements.
If true clearing competition breaks out,
disrupting the existing vertical silo model, you
may also be able to reduce your clearing
costs.
MiFID II correctly identifies that there a
number of potential competition issues
associated with vertical silos, where the
exchange also acts exclusively as the CCP for
its own markets. In particular, bundling and
exploitation of market power are real risks.
Bundling can occur across the transaction
chain, with trading and post-trade activities
being provided by the same group. As a
result, users can’t easily determine the
relative costs they are paying for each
service.
The ability to execute transactions in similar
instruments on different trading venues, but
then clear them via a single CCP of the dealer
banks choice can, however, lead to margin
efficiencies. The margin models used by
different CCPs are not identical, and clearing
the same portfolio at different CCPs will
produce different levels of IM and portfolio
margining.
If CCPs and their users press ahead with true
competition in the post trade space, the
benefits could be particularly significant for
dealer banks:
 fewer CCP connections will be
required, as connections to a smaller
number of horizontal CCPs will allow
full market access without the need
to sign up to every vertical silo (and in
an ideal world, it should be possible to
access almost all EU markets with
just a handful of CCP connections,
rather than the current 20+);
 genuine competition is likely to lead to
reduced clearing fees – analogous to
the reduction in trading fees which
resulted from the growth of MTFs as
part of MiFID 1; and
 greater margin efficiencies will be
possible, as correlated instruments
become eligible for cross-margining in
horizontal CCPs (for example, Bund
futures traded on Eurex, Short
Sterling traded on Liffe and IRS could
all potentially be cross-margined
together).
This would then have a significant impact for
establishing the real cost of a trade, with
clearing efficiency becoming an increasingly
key component.
Key issues to watch out for
A degree of circumspection will pay dividends
as the finer detail of the second level
legislative process is clarified. Here are some
key things to look out for:
Liquidity definition – liquidity is a key
concept within MiFID II, with a number of
central provisions applying only to those
instruments which are deemed ‘liquid’ by
ESMA. This includes the applicability of a
trading mandate, the timeliness of transaction
reporting and the requirement to provide firm
quotes for SIs.
Much debate has already occurred as to how
liquidity may be defined. The implications for
various markets may be profound, particularly
for instruments which have long periods of
illiquidity, followed by short periods where
they are liquid due to being ‘on the run’.
The final definition should be established in
ESMA Regulatory Technical Standards.

7. © Catalyst Development Ltd 7
Whatever method is adopted, or level of
coverage that results, expect this to be
controversial.
Best execution for derivatives – ensuring
best execution for less liquid products is a
challenging, and hotly debated, topic to be
settled in the next wave of MiFID materials.
If anything, the likely fragmentation of trading
venues to follow from MiFID II makes best
execution for derivatives a very tall order
indeed. A great deal of data will need to be
provided by venues, then properly assessed
by the dealer bank, before best execution can
be demonstrated to have occurred.
The key concept for best execution is
‘fairness’, another hotly debated term. Expect
more details of what represents best
execution for derivatives in the next draft of
the legislation.
Scope of the trading mandate – linked to
the concept of liquidity, a fundamental
provision within MiFID 2 will be which
contracts are mandated for electronic trading.
With the European regulators still dragging
their heels over the implementation of a
clearing mandate, a key issue will be the
degree of overlap between the clearing and
trading mandate. In the US, the pool of trades
subject to mandatory trading is a subset of
those subject to mandatory clearing. It is not
yet clear whether the same principle will apply
in the EU.
The scope of the trading mandate is key to
the success or failure of the new OTF venue
type, and will also have a significant impact on
the sustainability of any SI business.
Detailed provisions for SIs – following the
implementation of MiFID I, only a small
number of dealer banks were eventually
recognised as SIs for equity. The number of
SIs under MiFID II is widely expected to be
significantly greater, as it will now cover those
active in non-equity instruments.
Central to the number of banks identified as
SIs will be the criteria – to be based on the
scale and frequency of activity undertaken.
Equally important will be the organisational
requirements placed on SIs – particularly
regarding transparency and conduct of
business.
It remains to be seen whether acting as an SI
will be an attractive and profitable activity
once these new definitions are finalised.
Conclusion
MiFID II brings real opportunities: no bank
should feel overwhelmed by this ‘next big
thing’.
But difficult, necessary decisions must be
based on an accurate critical appraisal.
Below is a short summary of the key steps we
advise any dealer bank to consider
immediately.
1. Perform a full review of your OTC
derivatives business
This begins with an honest
assessment of the investment
requirements, potential future
profitability and new competitive
environment. Your objective should
be to validate your strategy and arrive
at a new operating model.
Most firms are already reviewing their
OTC derivatives business, at least at
high level. If you haven’t already
begun, you’re already behind the
curve.
Now that the impact of regulation is
becoming clearer, it is critical to
perform a comprehensive, honest and
realistic assessment of the future
prospects of your business. This
should address as a minimum:
 What proportion of your execution
it will be possible to retain, and
what proportion is likely to migrate
to other platforms. Unless you
have concrete plans to operate an
MTF or OTF, a great deal of
transactions subject to the trading
requirement should be assumed
to migrate away.
 Project the investment you
require to meet your MiFID II
requirements for any business
you wish to retrain. This should
include investment in technology
to meet transparency
requirements for SIs, any
changes in governance and

8. © Catalyst Development Ltd 8
conduct of business and any
operational or legal reorganisation
which may be required.
 Examine the likely profitability of
your future execution and clearing
business. With greater costs now
associated with running the
business and transparency
placing pressures on margins, it is
inevitable that this part of your
business will be less profitable in
future.
Armed with this analysis, you should
be able to decide which execution
businesses continue to offer potential
for your institution and which should
be discontinued.
2. Do not let the volume of change
blind you to potential synergies.
Ever larger sums are being spent by
banks to satisfy the many new
requirements of regulators which
have emerged in the last five years.
But clearly this has not been enough,
with plenty of regulatory censure for
failings on topics such as MiFID 1
transaction reporting in recent
months.
The daunting volume of regulatory
change required means many banks
have separate streams for each major
new regulation. But division will not
help you conquer this challenge:
search for synergies with existing
programmes of regulatory
investment. Common themes on
data quality and technology
investment run through many of the
regulations – particularly MiFID II,
EMIR, BCBS 239 and Bilateral
Margining.
You can save cost and effort by
identifying common themes and
building a single solution or
framework to satisfy many
requirements. What’s more, a strong
data architecture will not simply stand
you in good stead for the current
demands of regulation; it will also
future proof you against the next
round of regulatory demands, and
improve the quality of management
information for the day to day running
of your business.
3. Move towards a systematic
assessment of the real cost of
trading, and understand how it can
play a part in your business.
The ability to understand fully the true
cost of trading activity is increasingly
considered essential to the execution
business. The level of sophistication
of pre-trade analysis amongst the
leading banks is being rapidly
improved. MiFID 2 is an additional
piece in this puzzle.
To remain competitive, you need a full
and reliable pre-trade analysis,
incorporating the impact of the trading
venue landscape, the cost of clearing
and your funding costs. This will
ensure that the prices you offer are
representative of your true costs,
while still allowing you to maintain
profitability.
Key to this will be robust technology
and methodologies. You need to
ensure that your technology is fit for
purpose and can manage the
increasing volumes of information
arising from the transparency
requirements under MiFID 2. Picking
the right methodology will also be key,
to ensure that you accurately project
your future costs – which can be
particularly complex for items such as
Initial Margin over the life of a trade.
4. Invest for the future. Regulatory
demands are only set to grow:
make sure you have the
infrastructure to match the task.
For at least the past five years, both
the pace and associated costs of
regulatory change have been
significant. Trying to reduce costs
through tactical solutions brings risk –
consider the fines levied for trade
reporting deficiencies.

9. © Catalyst Development Ltd 9
With no let-up in the pace of
regulatory change in sight, now is an
appropriate time to assess your future
technology needs for regulatory
change.
If you have already invested, leverage
that investment wherever you can. If
not, be realistic about the suitability of
your current tactical arrangements,
and the risk of regulatory censure you
are running.
It is also important to remember that
good technology and operational
processes are not just about
regulatory compliance. Where
implemented successfully, good
investments in technology make for a
leaner, more efficient organisation
and improve the quality of information
available to senior management.
How we can help
We are experts in the trading, clearing and
post trade processing of OTC derivatives and
proud winners of the Queen’s Awards for
Enterprise: International Trade 2015 for our
impact on global financial markets11.
We solve complex, difficult issues in multiple
regulatory jurisdictions worldwide, helping
clients to achieve regulatory compliance, offer
clearing services, increase capital efficiency
and improve organisational performance. We
are advising a range of clients how to tackle
MiFID II including, but not limited to, the
issues covered in this whitepaper.
If it would be helpful to understand more of
any aspect of our work or to discuss your
particular challenges, please contact us.
11
For more information see
http://www.catalyst.co.uk/news/catalyst-win-queens-award-for-
impact-on-global-financial-markets/

10. Meet our authors
christianlee@catalyst.co.uk
Disclaimer: Comments in this presentation on are based on Catalyst's understanding of the global regulatory landscape as of June 2015.
This document is neither intended to be comprehensive, nor to provide legal or accounting advice.
Catalyst Development Ltd, 167 Fleet Street, London, EC4A 2EA
T +44 (0) 870 901 4155 F +44 (0) 871 433 8876 www.catalyst.co.uk
debasreebhattacharya@catalyst.co.uk
About Catalyst
We are experts in optimising our clients’ balance sheet, reducing the
total cost of trading and enabling regulatory compliance.
We work in joint teams with our clients, combining our experience in
financial markets and programme execution to deliver results. We
provide honest guidance to help you succeed.
We are proud winners of the Queen’s Award for Enterprise:
International Trade 2015 for our impact on global financial markets.
We are Catalysts for enduring excellence.
Christian Lee
Christian leads Catalyst’s
Clearing, Risk and Regulatory
team.
He is acknowledged as a world
leading authority on risk, with in-
depth specialist knowledge of
OTC clearing and experience in a
variety of risk management roles
and specialisms, including market
and credit risk, financial markets,
middle office and regulatory
matters. .
As Head of Risk at LCH, Christian
managed the Lehman’s default:
the biggest market-shaping event
of recent times
Debasree Bhattacharya
Shree specialises in derivatives
clearing, compressions and valuations
and is an expert in OTC clearing,
Swaps Compressions, risk, profit and
loss production.
She is an experienced practitioner in
interest rate derivatives and structured
funds business including risk, profit and
loss production, trade capture, market
data and industry protocols/trade
capture platforms, products, trade
reviews and pricing techniques.
Shree has worked extensively in the
implementation of OIS discounting and
CSA pricing, remediation of incorrectly
designated financial product types and
redesign of risk production platforms.
Damon Batten
Damon is an expert in the field of
OTC derivative reform and
regulation, having worked with
exchanges, central counterparties
and banks around the globe to
understand, manage and respond to
the challenge of regulatory change.
He is a specialist in the European
Market Infrastructure Regulation,
MiFID II, the Dodd-Frank Act and
associated CFTC Rule-making, the
CPSS-IOSCO Principles for Market
Infrastructures, and the BCBS
IOSCO standards for Bank
Exposures to Central Counterparties
and Bilateral Margining for non-
Centrally Cleared Derivatives.
damonbatten@catalyst.co.uk