Best execution

QUALITY OF EXECUTION

PREMISE

One of the objectives of the MiFID Directive is to favor the growth of the European financial system, allowing the competition between regulated markets, multilateral trading systems (MTF) and authorized intermediaries within harmonized rules that guarantee efficiency and integrity of financial markets and transparency and investor protection.
In this context, in order to meet the needs of the customers, BPER Bank Luxembourg s.a. has adopted an operating system that allows - using negotiating intermediaries - access to the main execution venues of the financial instruments most frequently treated by its customers, providing value services added, which guarantee high quality standards by looking for the best execution of orders based on market conditions.

The compliance function of BPER Bank Luxembourg s.a. has monitored the activity and confirm that BPER Bank Luxembourg s.a. promptly executed client orders that are otherwise comparable, in the same sequence that they were received.

With respect to the trading procedures no permitted practices occurred during the period. In accordance with internal procedures BPER Bank Luxembourg s.a may not direct orders to brokers in return for any gifts or entertainment, may not direct orders to brokers if any conflict of interests exists and which can’t be mitigated, may not receive any remuneration, discount or non-monetary benefit for routing clients orders to broker or execution venue which would infringe the requirements on conflict of interest or inducements.

 

BEST EXECUTION REQUIREMENTS

In accordance with the MiFID Directive, intermediaries who execute orders on financial instruments on behalf of their clients must take the necessary actions to obtain the best possible result (c.d. Best Execution).
The Best Execution applies without distinction to all financial instruments, whether they are listed on regulated markets or not, regardless of the place of trading (regulated markets, multilateral trading systems or outside of them), with reference to the services of execution of orders, but also, with different gradations, to those for receiving and transmitting orders and managing portfolios.
The intermediaries, determining the strategy of transmission and execution of orders, must take into consideration the following factors:

• price of the financial instrument and execution costs;
• speed of execution;
• likelihood of execution and settlement;
• order size;
• nature of the order;
• any other circumstance which, in the Bank’s opinion, is relevant to the execution of a particular order.

Intermediaries attribute a specific order of importance to each of the aforementioned factors category of financial instrument and for each type of customer and, on the basis of this, select execution venues and / or negotiating intermediaries to be used to guarantee the long-term achievement of the best possible result for the execution of orders in the interest of the Clients concerned.

Where a financial instrument is traded on multiple Execution Venues and/or may be executed via multiple Approved Counterparties, the Bank will consider having the trade executed on the market where liquidity is highest, considering that this is the most appropriate option for the Client regarding the most advantageous execution in terms of price, execution speed and probability of settlement.

 

RECEIVING AND ORDERS TRANSMISSION ACTIVITIES

BPER Bank Luxembourg s.a has carried out an analysis between the services and the costs offered by various intermediaries. This analysis was carried out with the aim of defining the reference traders to be used for an order transmission and execution strategy aimed at ensuring the best possible execution of the orders of its customers, taking into account the nature of the orders themselves, the execution venues the negotiating intermediaries have access to and the types of financial instruments, of which this document constitutes an informative summary.
All the various intermediaries selected by the banks have been approved by the senior management of BPER Bank Luxembourg s.a. after having considered all the elements above mentioned.

Once the intermediaries have been approved by the senior management, the selection for transmitting the orders by the Capital market department of BPER Bank Luxembourg s.a., takes into particular consideration:

  1. the characteristics of its customers (mainly those of "professional" customers which, on bonds, equities and funds, mainly operate on international markets and issuers).
  2. the costs applied by intermediaries;
  3. access to the various execution venues;

BPER Bank Luxembourg s.a does not apply any fees that would unduly discriminate between the various Execution Venues and intermediaries.