1 ORDER EXECUTION AND CONFLICTS OF INTEREST MANAGEMENT POLICIES Best execution policy of Orey Financial, Instituição Financeira de Crédito, SA, hereinafter the "Company". 1 Introduction 1.1. This policy is published in accordance with European Directive 2004/39/EC of the European Parliament and of the Council of April 21, and Directive 2006/73/EC of the Commission of August 10, relating to markets in financial instruments ("MiFID") and Regulation 1287/2006 of August 10, laying down certain detailed rules contained in the MiFID This policy provides an overview of how the company or the financial intermediary subcontracted under the terms of the Registration and Deposit Agreement (hereinafter the "Agreement") executes orders on behalf of clients, what factors that can affect execution times, and how market volatility plays an important role in the processing of orders relating to financial instruments This policy applies to the execution of orders on behalf of the Company's clients classified as professional investors or non-professional investors Upon acceptance of a client's order, and when there is no specific instruction by the client in relation to the method of execution, the Company or the financial intermediary subcontracted under the Agreement shall strive to execute the order in accordance with this Policy This Policy is available to customers upon request and is also on our website [http://www.oreyitrade.com] and [http://]. The Company reserves the right to amend or add to this policy from time to time. 2 Financial Products covered by this Policy 2.1. The financial products to which this Policy applies are: Shares, Bonds, Futures, Options, Investment Fund Units, CFDs (Contracts for Difference) and Credit-Risk Transfer Derivative Instruments. Some of these products are, by their nature, traded OTC The trading conditions, including minimum commissions applied, transaction costs, margins required, etc, in respect of the products listed above are available on the Company's website [http://www.oreyitrade.com], as well as directly on the OreyiTrade platform. 3 The Company's approach to Best Execution 3.1. When executing orders, the Company or the financial intermediary subcontracted under the Agreement shall take all reasonable steps to obtain the best possible result for the client in the circumstances, taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.
2 3.2. When considering best-execution factors, the Company or the financial intermediary subcontracted under the Agreement takes into account: o The classification of the client as a professional or not-professional client; o The characteristics of the financial instruments related with the order; o The characteristics of the places of execution to which order may be directed Whenever there is a specific instruction from the client, or given on his behalf, the Company or the financial intermediary subcontracted under the Agreement shall to the extent possible execute the order in keeping with the specific instruction. It should be noted that a specific instruction of a client may prevent the Company or the financial intermediary subcontracted under the Agreement from taking take the steps described in this Policy to obtain the best possible result when executing orders. There are certain rules for trading in specific markets that may prevent the Company or the financial intermediary subcontracted under the Agreement from following certain instructions given by the client. Whenever an instruction from a client is not complete, the Company or the financial intermediary subcontracted under the Agreement shall determine the unspecified components of the execution in accordance with this Policy. 4 Elements of the Best-Execution Policy 4.1. The decision regarding forwarding orders is essentially based on four criteria and is regularly reviewed by the Company or the financial intermediary subcontracted under the Agreement. Therefore, to determine the best way to execute a client's order the Company takes into account the following: Speed and feasibility of the execution. Given the unprecedented levels of volatility affecting both the price and the volume of orders, the Company or the financial intermediary subcontracted under the Agreement shall seek to process client orders as quickly as reasonably possible Improvement of prices and overall assessment of costs. Orders are routed to market makers and/or market centres where there are opportunities for price improvement. The criteria to be used by other market makers and/or market centres include: o Automatic matching between the input market and limit orders for outstanding limit orders; o Crossed transactions in circumstances where a price improvement is offered to one or both parties to the transaction Improvement of Dimension On forwarding orders, the Company or the financial intermediary subcontracted under the Agreement seek markets that offer greater liquidity and, consequently, the potential to execute large orders. The Company or the financial intermediary subcontracted under the Agreement also seek opportunities for orders given by the clients to ensure the latter benefit from guarantees associated with the size of orders offered by stock markets and other operators Overall quality of execution When determining how and where to route or execute an order, the Company or the financial intermediary subcontracted under the Agreement base themselves on their vast day-to-day experience with several markets and market makers, focusing their attention on fast, sequential and reliable execution.
3 4.2. We would like our clients to take into consideration that the duty of best execution refers not only to price but also involves consideration of several factors, including cost, speed, feasibility of execution and settlement. Even should it later seem that a transaction was not executed at the best possible price, this does not necessarily constitute violation of the duty of best execution Price Formation Notwithstanding what is stated in this point, we would advise that the price formation of products not traded on organised markets (stock markets) is limited to entities subcontracted for the purpose, as stipulated in the contract. 5 List of Execution Venues Currently Selected 5.1. Within the scope of the brokerage service, the Company transmits orders on behalf of its clients for execution by the financial intermediary subcontracted under the Agreement The financial intermediary subcontracted under the Agreement is currently a member of the NASDAQ OMX Copenhagen and the Chicago Mercantile Exchange ("CME"), and, additionally, a number of external financial institutions and brokers are used in the process of receiving and relaying orders or to execute directly-listed financial instruments that are not listed on the NASDAQ OMX Copenhagen and the CME, including Bank of America, BNP, Barclays, Citibank, Commerzbank, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Morgan Stanley, Nomura, RBS, UBS, Citadel, Carregosa, and Banco Best. 6 Effects on the Execution of Orders 6.1. Clients should be aware of the following risks associated with market volatility, especially at or near the opening or closing of a standard trading session: - Execution at price quite different from the quoted bid or offer or the last selling price reported at the time the order is received, as well as execution or partial execution of large orders in several transactions and at different prices; - Delays in the execution of orders concerning financial instruments that have to be sent to another market maker and cannot be processed electronically if the operator has to manually forward them to another company; - Opening prices that may differ considerably from the closing prices of the previous day; - Blocked (the bid is equal to the offer) and crossed (the bid is greater than the offer), markets, preventing execution of the client's transactions; - Price volatility is a factor that can affect the execution of the order. When clients place a large volume of orders, imbalances of orders and logs may occur, meaning that more time is needed to complete pending orders. 7 Types of Orders 7.1. Given the risks that arise when trading in volatile markets, consideration should be given to the use of different types of orders to limit risk and manage investment strategies. (It should be noted that the following descriptions of the types of order may apply to just to some and not all types of financial instruments.) Market order In this case, the investor tells the broker to execute a transaction of a certain size as soon as possible at the current price. Financial institutions are required to execute orders at the market price without taking price changes into account.
4 Consequently, if the market price varies significantly during the time required to satisfy an order placed by a client, the order will probably be exposed to the risks described above, including execution at a price substantially different from the price in effect at the time when the order was received Limit Order In the case of a limit order, the investor sets a maximum purchase price for the execution of the transaction. If the market price deviates significantly from the limit, the order will not be executed unless, or until, the market price returns to the limit price. Since a limit order is always received at a great distance from the current market price, it is almost never executed immediately. A client who places a limit order must be aware that he is exchanging the certainty of immediate execution for an expectation of a better price in the future. Limit orders are always routed to stock markets where there is no form of human intervention Stock market stop orders With a stock market stop order the investor can predefine the price at which he wants to obtain a certain position if the defined price is reached, which is done to set a limit to the loss the investor may suffer in a given position/transaction. On the other hand, a stock market stop order can also be used to open a position (both a long and a short position). In this case, stock markets stop orders are intended to protect profits rather than to limit losses. In general, this type of order is used privately and when the stop price is reached, it is immediately sent for execution as a market order at the price then prevailing. Consequently, a stock market stop order becomes a market order when a certain price (the stop) is reached. Contrary to the limit order, the stop order does not define the actual price at which the transaction will be executed, but the price at which a start will be made to the operation. Although a stock market stop order does not guarantee the execution price, it ensures that the transaction will be executed if the price is reached Variation of stock market stop orders for contracts for difference. This type of order varies with the price of the instrument and remains in force if the price of the instrument is against the investor. A stock market stop order that varied will be executed if the price of the instrument moves down (long position) or moves up (short position) to achieve the level of the order. The investor sets the interval (number of exchange units, trading gap) between the price of the instrument and the variation of the stop order, as well as the dimension of the increases in the direction intended for the order. 8 Review and Communication of the Execution and Venue Policy 8.1. Each year the Company reviews the effectiveness of this Order Execution Policy and its order-execution agreements in order to determine and implement such improvements as may be necessary This policy was revised in November 2012, and the Company considers that any order received from a client expresses his knowledge of and consent to the Policy.
5 CONFLICTS OF INTEREST MANAGEMENT POLICY 1. INTRODUCTION 1.1 This policy is published in accordance with European Directive 2004/39/EC of the European Parliament and of the Council of April 21, and Directive 2006/73/EC of the Commission of August 10, relating to markets in financial instruments ("MiFID"). 1.2 In determining situations that could lead to a conflict of interest and to define measures to mitigate or reduce to a minimum the risk of its occurrence, the Company will take all necessary measures to ensure fair and impartial action and will act in accordance with the principles and requirements of the Securities Code 1 and by the supervisory entities in the regulations in force. 1.3 This Policy complements the Company's general comprehensive obligation to act with integrity and fairness, both with its clients and with its counterparts, maintaining a professional commitment to manage potential conflicts of interest that may arise between the parties. 1.4 Without prejudice to those responsible for areas that may directly give rise to conflicts of interest, the Company's Board of Directors shall ensure that the Company's policies, procedures and controls are adequate to fulfil the duties of identification, prevention and management of conflicts of interest, and also for proper performance of such duties. 1.5 This Policy is available to clients upon request and is also available on our websites [http://www.oreyitrade.com] and [http://]. The Company reserves the right to amend or add to this policy at any time. 2. IDENTIFICATION AND GENERAL DISCLOSURE OF THE KIND OF POTENTIAL CONFLICTS OF INTEREST AND THEIR ORIGINS 2.1. The Company is required to adopt a formal policy regarding conflicts of interest that should: a. Identify, for each financial intermediation activity carried out by or on behalf of the financial intermediary, the circumstances that may give rise to a conflict of interest; b. Specify the procedures and steps to be taken in order to manage such conflicts At present, the Company identifies and divulges a set of circumstances that constitute or may give rise to a conflict of interest from a potential point of view, but not necessarily implying a significant risk for the interests of one or more clients. There is a risk of such an occurrence if the Company or any person directly or indirectly associated with it in terms of control is able to obtain a financial gain or avoid a financial loss at the expense of the client The circumstances identified are as follows: a. Offering to the general public consultancy services targeting a specific interest of a client/specific group of clients; b. The Company might provide consultancy services to third parties whose interests may be in conflict or competition with the interests of other clients; 1 Title VI, Chapter I, Section III, Subsection VI of the CVM (Securities Code) (Articles 309, 309 A, 309 B, 309 C, 309 D, 309 E and 309 F)
6 c. The Company might have an interest that is contrary to the client's transactions, for example where clients trade in markets in which the Company acts as a market maker; d. The Company, its employees and associate corporate persons might have, establish, modify or cease to hold positions in securities, foreign currencies or other financial instruments based on a recommendation; e. The Company might have an interest in maximising trading volumes with a view to increasing its revenue from commissions, which is inconsistent with the client's personal interest of minimising - transaction costs; f. The Company's system of bonuses and incentives might grant benefits to its employees based on the trading volume; g. The Company's representatives might know of clients' major orders to buy or sell a large quantity of a particular financial product and both the Company and its representatives could buy or sell the (derivative) financial product in advance; h. The Company may receive from or pay incentives to third parties owing to the referral of new clients or new trading orders from clients, other than the normal commission or fee for the service. 3. MANAGING CONFLICT OF INTERESTS 3.1. In order to manage possible conflicts of interests, the Company adopts the processes, procedures and organisational agreements referred to in this document, which include the following: a. All clients shall be treated in a transparent and equitable manner; b. All employees receive instruction and guidance on managing conflicts of interest; c. All employees are at all times bound to act with loyalty to the Company and to act fully in accordance with the Company's procedures; d. All employees are bound by professional secrecy and confidentiality of information, which may be shared only if essential to the accomplishment of their duties. e. Definition of separate areas determined and identified in Internal Regulations. Analysts are not directly accountable to a business unit, and their commercial interests might conflict with the interests of clients; f. The remuneration of an analyst stems from the overall profits of the Company and not from specific departments or transactions; g. Research publications are distributed internally only at the time they are distributed to clients. Analysts in charge of research do not provide Operations employees with advance information on the calendar and content of future publications; h. Analysts charged with research are supervised separately from Operations and Marketing activities; i. Analysts in charge of research are generally allowed to take part in marketing the Company's investment banking services, including their presence at places where transactions are undertaken and to play an active role in road shows, provided there are specific internal controls governing such participation; j. The Company has established controls and procedures (including, where appropriate, actual separation) to regulate and, where appropriate, prohibit the flow of information between the Research, Trading and Marketing areas; k. Operations personnel are not authorised to re-evaluate parts of publications that contain recommendations, research summaries, target prices or value recommendations, or even to verify their factual accuracy prior to publication.
7 4. ACTIVITIES OF ANALYSTS 4.1 To ensure the proper working of this Policy, analysts are required to declare any personal interests relevant to their research duties. 4.2 Analysts are obliged to observe the Company's rules and procedures in operations for their own account. 5. RECORD OF ACTIVITIES The Company maintains and regularly updates records of all types of financial intermediation activities conducted directly by it or on its behalf giving rise to a conflict of interest involving a significant risk that the interests of one or more clients would be affected. 6. POLICY REVIEW AND COMMUNICATION 6.1 Each year the Company reviews the effectiveness of this Conflict of Interests Management Policy and its agreements with partners within the scope of order execution in order to determine and implement such improvements as may be necessary. 6.2 This policy was revised in November 2012, and the Company is responsible for its disclosure to its clients and for ensuring they express their knowledge of and consent to the Policy.
1 1. Definitions and Interpretation 1.1 In this Agreement the following words shall have the corresponding meanings: Account: Any transaction account which the Company may open for the Client on its systems
INFORMATION ON THE SERVICE PROVID- ER AND THE INVESTMENT AND ANCIL- LARY SERVICES OFFERED TOGETHER WITH INFORMATION ON THE FINANCIAL IN- STRUMENTS AND THE ASSOCIATED RISKS 1. GENERAL This document contains
Date: 27 March 2014 ESMA/2014/332 OPINION Structured Retail Products - Good practices for product governance arrangements Legal basis 1. Regulation (EU) No 1095/2010 (ESMA Regulation) 1 sets out the European
Authorised Persons Regulations Contents Part 1: General Provisions Article 1: Preliminary... Article 2: Definitions... Article 3: Compliance with the Regulations and Rules... Article 4: Waivers... Part
GENERAL BUSINESS TERMS SAXO BANK A/S Page 1 of 1 1. DEFINITIONS INTERPRETATION OF TERMS 1.1 In these General Business Terms (hereinafter the "Terms") the following terms shall, unless the context otherwise
1. General Terms and Conditions of Services Agreement April 2015 The Site is owned by Grizzly Ltd. (hereinafter, the Company ) a subsidiary to IFSC license number 60/402/TS/15, authorized to trade on financial
A Guide to Non-Life Insurance Regulation in Ireland Contents A Guide to Non-Life Insurance Regulation in Ireland Introduction Page 2 Regulatory Regime Page 4 Authorisation Page 6 Organisation and Supervision
CEBS/2008/214 CEIOPS-3L3-19/08 CESR/08-543b Guidelines for the prudential assessment of acquisitions and increases in holdings in the financial sector required by Directive 2007/44/EC  Table of contents
Consumer Protection Code August 2006 SCOPE Legislative Basis This Consumer Protection Code ( Code ) is issued by and in the name of the Irish Financial Services Regulatory Authority ( Financial Regulator
PRINCIPLES FOR PERIODIC DISCLOSURE BY LISTED ENTITIES Final Report TECHNICAL COMMITTEE OF THE INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS FEBRUARY 2010 CONTENTS Chapter Page 1 Introduction 3 Uses
25 January 2006 Guidelines on the Application of the Supervisory Review Process under Pillar 2 (CP03 revised) Table of contents Executive Summary...2 Chapter 1: Introduction...4 Chapter 2. Guidance for
ASR FONDS An open-ended investment company incorporated under Luxembourg law Prospectus NOVEMBER 2012 INFORMATION REQUESTS ASR FONDS 33, rue de Gasperich L-5826 Hesperange Grand Duchy of Luxembourg NOTICE
Plus500CY Ltd. USER AGREEMENT (NON-US RESIDENTS ONLY) USER AGREEMENT (NON-US RESIDENTS ONLY) This User Agreement (the Agreement ), including terms and conditions relating to your use of the trading service,
Marketing Communication Global Markets Product Risk Book English version This communication was not prepared in accordance with Legal requirements designed to promote the independence of investment research
CONFLICTS OF INTEREST IN PORTUGAL Tito Arantes Fontes Filipe Romao Catarina Gonçalves de Oliveira (Financial Institutions) José João Ferreira Gomes (Auditors) Assunção Magalhães e Menezes (Lawyers) Uría
Corporate Policy. Data Protection for Data of Customers & Partners. 02 Preamble Ladies and gentlemen, Dear employees, The electronic processing of virtually all sales procedures, globalization and growing
Principles for the Management of Credit Risk I. Introduction 1. While financial institutions have faced difficulties over the years for a multitude of reasons, the major cause of serious banking problems
Conseil UE Council of the European Union Brussels, 20 March 2015 (OR. en) PUBLIC Interinstitutional File: 2014/0121 (COD) 7315/15 LIMITE DRS 26 CODEC 366 NOTE From: To: Presidency/General Secretariat of
Appendix no. 1 to the Regulation of the Member of the Bank s Management Board no. 181/2015 of 27 March 2015 CAPITAL GROUP Dom Maklerski BZ WBK (DM BZ WBK) is a separate organisational unit of Bank Zachodni
Information for Customers concerning Business with Baader Bank Aktiengesellschaft As at: July 2015 Contents 4 General customer information 10 Dealing with conflicts of interest 12 Policies of Baader Bank
AIM Rules for Companies May 2014 AIM Rules for Companies Introduction 2 Part One AIM Rules 3 Retention and role of a nominated adviser 3 Applicants for AIM 3 Special conditions for certain applicants 4