EUROCORP

Best Execution Policy

Markets in Financial Instruments Directive

Introduction

EUROCORP GROUP (EUROCORP S.A. & EUROCORP SECURITIES S.A.) provides investment services on financial instruments in accordance with the European Council Directive 2004/39/EC (MiFID) and Greek Law 3606/2007 (Hellenic Government Gazette Issue A 195/17.8.2007), as currently in force in all member states of the European Union.

Specifically, as far as the two group companies are concerned, it is noted that:

  • EUROCORP SECURITIES, as a member of the Athens Exchange, offers order execution services in the markets of the above exchange, and may forward clients’ orders to third parties offering investment services for execution in other markets (e.g. in exchanges of other countries).
  • EUROCORP S.A. (mother company of EUROCORP SECURITIES), is not a member of regulated exchanges or other execution markets and does not offer order execution services. In the context of offering receiving and transmitting services or portfolio management, EUROCORP S.A. may transmit these orders to other investment services companies so that they ensure the execution of the above orders (either executing these orders in specific markets or transmitting them to other companies, themselves members of markets).

Within this institutional framework and taking into account the best possible provision of investment services to its clients, EUROCORP commits to executing client orders in accordance with the following procedure.

Based on Community law and Greek law and with a view to providing the largest possible protection to investors, the present policy is applied to professional and non-professional clients.

The best execution policy we have established guarantees that we have taken all the measures in order to ensure the best possible result for our clients when executing their orders, taking into account the price, cost, execution speed, the possibility for execution and clearing, the nature and size of the order or any other factor that may affect the execution of the order.

EUROCORP commits to taking any reasonable measure so as to achieve, during the execution of client orders, the best possible result for clients as set out in the present policy. In case of specific instructions of the client, EUROCORP will execute the client’s order based on such instructions.

Order execution

For transferable securities traded on regulated markets, EUROCORP will automatically execute the purchase and sell orders on the main market, which by definition offers the largest liquidity or the largest transaction volume.

In conjunction with the size and nature of the order executed by the firm, the latter may use another investment firm that is selected under the criterion of securing the best possible result for the client.

In the context of our obligations for best execution, apart from liquidity we also take into account the following factors when selecting the execution venue for the order:

  • Trading price
  • Transaction cost (commissions for execution of the transaction through a specific venue, clearing cost) which may be direct or indirect
  • Execution speed in the market
  • Possibility for execution and clearing of the transaction
  • The capability of the execution venue to manage complex orders
  • The clearing terms of the order and
  • Any other factor relevant to execution of the order

The trading currency of any instrument does not affect the selection of the execution venue.

The importance of the above factors is specified by EUROCORP according to the criteria set forth below. The importance of such factors may change if specific circumstances arise in the markets.

For non-professional clients (private clients), the best possible result is defined based on the price and cost, while the remaining factors may be considered important if they determine the achievement of best price and cost.

For professional clients the price and costs are generally considered as the most important factors, even though we may, as applicable, also take into account the other factors according to the conditions prevailing at times, when such factors allow improvement of the price.

Best execution refers to the process applied by our firm and not to the obligation to deliver a result. Therefore when a client order is executed, the firm must execute such according to the present policy but it does not guarantee that the best price can be achieved in all cases. The factors for selecting the venue may lead to different results according to the specific features of each transaction.

In some special conditions, the obligation for best execution may not be applied, for example in case of acute turbulence in markets and/or failures of the internal and external order execution systems. In this case, the only criteria will be the ability to execute the order. In a case of systems failure, the firm may not be able to gain access to all the execution venues it has selected.

Execution criteria

As mentioned above, EUROCORP SECURITIES S.A. takes into account specific criteria when defining the priority sequence of the factors for selecting the execution venue (when there are more than one execution venues for the same financial instruments). The execution criteria taken into account are the following:

  • The characteristics of the client (professional, non-professional)
  • The characteristics of the order
  • The characteristics of the financial instrument that concerns the order
  • The characteristics of the execution venues
  • Any other factor that may affect the order at a given time in a given market.

In case where the client has not provided specific instructions, the execution method will aim, in order of priority:

  • At seeking the execution venue that allows the full order execution with the largest possibility to realize the transaction, considering that it is preferable that the order execution is completed at one venue for the efficiency of the post-trade clearing process.
  • At optimizing the overall price of the order including the execution price and the total cost to realize the order.
  • At minimizing the effect of the order on the market price at the execution venue.

In any case, for non-professional (private) clients, through the hierarchy of order execution criteria, the best possible result can be provided based on the total price (execution price, execution cost, clearing and settlement cost of transactions).

Reception and Transmission

In markets in which EUROCORP is not a member, the execution of orders will take place through other investment firms. In this case, EUROCORP receives and transmits the orders to another intermediary investment firm. When client orders are received and transmitted, we act in a way so as to ensure the best possible interest of our clients. The firm takes all sufficient measures in order to achieve the best possible result.

When the firm transmits its client’s orders to other investment firms, which are subject to the same best execution obligations defined by MiFID, the firm considers that it adequately meets its obligations for best execution:

  • It selects the investment firm or firms that ensure the best result for its clients. It specifically trusts investment firms that are subject to the requirements of MiFID and the best execution obligations.
  • It ensures that their order execution policy is compatible with its own best execution policy, as such as described hereunder.
  • It monitors and evaluates the quality of order execution and proceeds with corrections for any insufficiency.

Specific client instructions – exceptions

In case the client has given specific instructions in relation to the execution of his order, EUROCORP may not be held liable for any result incurred by the client and caused by such instructions . EUROCORP’s liability in this case is limited exclusively to making the best possible effort so as to achieve the client’s order. The client’s specific instructions may obstruct the firm in taking all the measures described in this policy.

As regards to orders on options, the client must exactly define the venue on which he wants its order to be executed, taking into account that the closing of such a position on options will take place at the same venue where the position was opened.

When the Firm is obliged to proceed with liquidation of a client’s position (for example in case of an insufficient balance or non-coverage of the client’s contractual obligation according to the general terms for the provision of investment services) it shall be deemed that the relevant order is not subject to the obligation for best execution.

Evaluation of the execution policy

Each year the firm will proceed with a review of its best execution policy as well as after any significant change in the order execution and/or transmission systems, with a view to continuously ensure the best possible result for all its clients. Therefore, the firm may proceed with amendments to the present best execution policy. Any amendment of the present policy will be notified through the firm’s website: www.eurocorp.gr.

Basic execution venues

Indicatively, the basic execution venues and cooperating companies are the following:

EUROCORP SECURITIES S.A. Member of the ATHENS STOCK EXCHANGE: execution of orders on shares, derivatives and other traded financial instruments.
 Cooperating company  Objective of Cooperation
GEDIK Investment Securities Inc. Services for reception and transmission of orders on the Istanbul Stock Exchange
NYFIX Transaction Services Inc.  Services for reception and transmission of orders on U.S. markets.
NYFIX International Ltd  Services for reception and transmission of orders on following markets: London, Paris, Amsterdam, Lisbon, Brussels, Frankfurt and Helsinki.
DENIZ YATIRIM  Services for reception and transmission of orders on the Istanbul Stock Exchange
CLSA LTD  Services for reception and transmission of orders on following markets: Hong Kong, Philippines, Singapore, Shanghai and Shenzhen.
CLSA Singapore Pte. Ltd  Services for reception and transmission of orders on following markets: Indonesia, Japan and Thailand.
SOFIA INTERNATIONAL SECURITIES PLC  Services for reception and transmission of orders on the Sofia Stock Exchange, Bulgaria.
SSIF PIRAEUS SECURITIES  Services for reception and transmission of orders on the Bucharest Stock Exchange, Romania.
ROMANIA SA (ex. EUROPEAN SECURITIES SA)  Services for reception and transmission of orders on the Stock Exchange of Toronto, Montreal and the MTF TSX VENTURE EXCHANGE, ALPHA TRADING SYSTEM LIMITED PARTNERSHIP and OMEGA ATS
ROYAL BANK OF CANADA EUROPE LIMITED  Services for reception and transmission of orders on all Regulated Markets and MTFs in Europe, America, Australia and Canada.
BNP PARIBAS SUISSE S.A. Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
LCF EDMOND DE ROTHSCHILD SECURITIES LIMITED Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
BANK OF AMERICA MERRILL LYNCH INTERNATIONAL Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
BANCA IMI S.p.A. Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
GUY BUTLER LIMITED Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
EUROBANK EFG Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
ZURCKER KANTONALBANK Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
NOMURA INTERNATIONAL Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
BARCLAYS CAPITAL PLC Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
NATIONAL BANK OF GREECE Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
DEUTSCHE BANK Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
J P MORGAN Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
MORGAN STANLEY & Co INTERNATIONAL PLC Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
UBS LIMITED Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
ALPHA BANK (GREECE) Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
RAPOBANK Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
CITIGROUP GLOBAL MARKETS LIMITED Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
OCTO Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
R J O’BRIEN Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
SEAPORT GROUP EUROPE Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.
VANTAGE CAPITAL MARKETS Services for reception and transmission of orders on all Regulated Markets, MTFs and OTC in Europe, America, Australia, Canada and Asia.

 

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