MiFID Directive
CLIENT INFORMATION REGARDING THE EXECUTION POLICY
EXECUTION POLICY INFORMATION
(Document updated)
I. Introduction
As a result of the increase of financial products and the markets where
these are traded, the European Union considers that a set of common rules need to be implemented
to provide greater investor protection in all EU Member States.
In order to meet this objective, a regulation known as MIFID has been developed (Directive 2004/39/EC of
the European Parliament and the Council, Commission Directive 2004/73/EC and Commission Regulation (EC) 1287/2006)
to supervise the activities carried out by entities rendering investment services or undertaking activities with financial instruments.
Under this regulation, special emphasis has been given to investment companies’ obligation to maintain an Execution Policy
aimed at offering its clients the best possible result regarding the execution of orders.
The objective of this statement is to meet the regulation’s requirement to inform Clients of the most relevant aspects making up the
INTERMONEY VALORES SV, S.A. Execution Policy.
II. Scope of application
The Execution Policy applies to Clients classified as Retail and Professional Clients according
to the MIFID provisions, when a service of execution and/or reception and transmission of orders is provided on behalf of
the Client, regarding the financial instruments for which INTERMONEY SV, SA is duly authorised, acknowledged as such under MIFID.
INTERMONEY VALORES SV, SA is not obliged to obtain the “best execution” in relation to orders from clients classified a an Eligible Counterparty.
III. Execution Policy
INTERMONEY VALORES SV, SA has adopted all reasonable measures to obtain the best possible result for the
execution and/or receipt or transmission to third party entities of orders from Clients regarding financial instruments
included under the MIFID regulation.
In this sense, INTERMONEY VALORES SV, SA has optimum execution efficient systems, including an execution policy describing the
execution principles, INTERMONEY VALORES SV, SA’s obligations and responsibilities to their Clients regarding the execution
and/or reception or transmission of orders.
In order to obtain the best possible execution for their clients, INTERMONEY VALORES SV, SA shall take into consideration:
Factors such as:
- Price.
- Costs.
- Speed.
- Execution probability
- Volume and settlement reliability.
- Any other factor that due to its characteristics could influence the execution result.
The type of Client and the order’s characteristics will also be taken into consideration.
Possible execution centres:
INTERMONEY VALORES SV, SA will select the execution centre that in each specific
case allows INTERMONEY VALORES SV, SA to comply with its execution policy.
For this purpose the following are considered as execution centres:
- Official secondary markets.
- Multilateral trading systems.
- Systematic internalizers.
In the event of receiving specific instructions from the client regarding how to execute an order, INTERMONEY VALORES SV, SA will execute the order following such specifications. In this case it is understood that the entity is complying with its performance obligations in the client’s interest.
IV. Relative importance of said factors during the execution
Price
Among the possible execution centres that meet the reasonable accessibility conditions to execute an order, INTERMONEY VALORES SV, SA will give priority to the price factor, while understanding that such centre meets sufficient liquidity conditions.
Execution costs.
The concept of an optimum execution result shall be understood as established in terms of the total consideration, understood as the price and the costs related to the execution. These costs can include: intermediation, compensation and settlement, execution centre rates and other necessary third party expenses to execute the order.
Speed, execution probability, volume and settlement reliability.
These factors shall be taken into consideration according to the financial instrument upon which the transaction is executed, as the valuation of these factors will be conditioned by the characteristics of the execution centres where the instruments can be traded and by the specific characteristics of each product.
V. Order execution
INTERMONEY VALORES SV, SA in its attempt to achieve the best possible execution result, may proceed to execute client orders directly or by transferring such executions to other intermediaries.
Direct execution.
For direct executions INTERMONEY VALORES SV, SA will use one of Execution Centres according to the type of financial instrument listed under “Annex I”.
Transfer of order to third parties
INTERMONEY VALORES SV, SA will transfer client orders for execution to other intermediaries only when it does not have direct access to the appropriate execution centres to achieve the best possible execution.
In these cases, INTERMONEY VALORES SV, SA will adopt the following measures:
- It will verify that the selected intermediaries have established, in turn, execution policies allowing INTERMONEY VALORES SV, SA to comply with its own optimum execution policy.
- INTERMONEY VALORES SV, SA will select the intermediary that can prove it can obtain equal or better results than an alternative intermediary with respect to the optimum execution.
- It will establish execution agreements with one or more than one intermediary.
VI. Acceptance of the execution policy
The MIFID regulation states that INTERMONEY VALORES SV, SA must obtain prior consent, from its client, of its Execution Policy before proceeding to execute any order given by such client.
For such purpose, it is understood that INTERMONEY VALORES SV, SA will obtain such prior consent from its clients, whether by means of a specific contractual document or, once the client has received the Execution Policy information, it gives an execution order without expressing objection whatsoever to such information.
VII.- Revision of the Execution Policy
INTERMONEY VALORES SV, SA will regularly, and at least once a year, revise the efficiency of its Execution Policy with the objective of detecting and, if applicable, correcting possible deficiencies in the application thereof.
It will also periodically supervise and check that the Execution Centres and the Intermediaries comply with the criteria allowing them to obtain the best results possible on a systematic basis for their Clients.
Clients will be duly notified of any significant change to the order Execution Policy described in this document, not necessarily considering as such the inclusion or exclusion of any Execution Centre, Intermediary or Instrument.