Order Execution Policy

Transcription

1 This document sets out the Order Execution Policy of Santander Investment Bolsa, SV, SAU (SIB), as required by the Markets in Financial Instruments Directive of the European Union (otherwise known as "MiFID") SIB shall take all reasonable steps to obtain the best possible result in transactions with its clients by implementing an Order Execution Policy that will apply to the financial instruments for which it offers execution services. SIB shall review this policy at least once a year and shall update it as and when required. SIB will notify clients of any material change that could affect its ability to continue offering them the best possible results under the terms of this policy by posting such changes on the website, on which the current Order Execution Policy will also be published. SCOPE SIB's Order Execution Policy will apply to transactions with clients when SIB executes orders on their behalf and/or receives and transmits orders in their name. This policy extends to all products that SIB trades or brokers at European execution venues for equities. Compliance with this policy should be viewed and interpreted in general terms. Accordingly, this policy will apply to all orders. It imposes no obligation to obtain the best possible result in respect of all of them, but rather the obligation to obtain the best possible result on a consistent basis in accordance with the criteria and factors described herein. This Order Execution Policy will not apply in the following cases: When SIB acts as distributor. When SIB is the client's counterparty. In transactions on the primary market. When SIB offers its brokerage services on the basis of a previously quoted price. When SIB is following the client's specific instructions in executing the order. EXECUTION FACTORS When executing orders on behalf of its clients, SIB shall pay due regard to the following execution factors: price, costs, speed, likelihood of execution and settlement, size and nature of the order, and any other consideration relevant to executing the order, such as available liquidity. SIB will rely on its experience in determining the relative importance of each of these factors, based on the prevailing market conditions, and will take into account: (I) the client's characteristics, (II) the order's characteristics, (III) the characteristics of the financial instruments Page 1

2 that are the subject of the order and (IV) the characteristics of the execution venues to which the order may be directed. SIB will often attach a high relative importance to the price in obtaining the best execution, provided there is available liquidity. However, in some circumstances, the other execution factors mentioned above may merit greater importance than the price in obtaining the best possible result. SPECIFIC INSTRUCTIONS SIB shall take all reasonable steps to obtain the best execution for its clients when receiving and transmitting orders or executing client orders. If SIB receives specific instructions from a client, it shall execute the order in accordance with those specific instructions insofar as reasonably possible. When this occurs, SIB will be deemed to have provided "best execution" simply by following the client's instructions. Where the client's specific instructions relate to only part of the execution, SIB will continue to apply its execution policy to those aspects not covered by the specific instructions. Should SIB provide direct market access ("DMA") or direct strategy access ("DSA") services to a client (where the client chooses an algorithm for executing the order), the client will be entirely responsible for achieving best execution when it transmits a specific instruction. SIB has no decision-making authority over the execution of these transactions and accepts no liability for the parameters selected by the client. When these situations arise, SIB will be deemed to have provided best execution. EXECUTION VENUES When SIB executes orders outside regulated markets and multilateral trading facilities (MTFs) or other similar venues, the client accepts execution of the orders outside such regulated markets or facilities. It shall review the different execution venues at least once a year. SIB may execute orders through third parties. SIB shall review the Best Execution Policies of each of the brokers it uses. In no event will SIB send orders to a third party for the sole purpose of obtaining any remuneration, discount, or non-monetary benefit from that third party for having sent the orders. Execution speed may become a priority at certain execution venues with high levels of price volatility. At execution venues that offer little liquidity, the act of executing the trade may in itself constitute best execution. Page 2

3 There may sometimes be a limited choice of execution venues due to the nature of the order, the client's needs and other prevailing circumstances. AVAILABLE EXECUTION VENUES A list of the main execution venues and entities commonly used by SIB when executing or transmitting the orders of its clients is provided in the appendix. CONSENT SIB is required under applicable regulations to obtain the client's prior consent to its execution policy. Prior consent to this policy will be deemed received when a client sends SIB an order. Likewise, the client accepts that the information that SIB must provide to clients may be provided via the following website, on which this policy is published: Inversores/Informes-de-filiales.html?leng=en_GB SIB must obtain the client's express consent before executing orders outside the regulated markets or MTFs. The client may communicate its acceptance of this policy and authorise SIB to provide the relevant information via the website by writing to SBGM_Compliance@gruposantander.com. Page 3

4 APPENDIX Main execution venues. EXECUTION VENUES Athens Stock Exchange Wiener Borse AG (Vienna Stock Exchange) BATS OMX Copenhagen (Copenhagen Stock Exchange) OMX Helsinki (Helsinki Stock Exchange) OMX Stockholm (Stockholm Stock Exchange) Chi-x Deutsche Börse Borsa Italiana Irish Stock Exchange Oslo Bors (Oslo Stock Exchange) Warsaw Stock Exchange (Poland) Bolsas y Mercados Españoles SIX Swiss Exchange Borsa Istanbul (Turkey) Turquoise London Stock Exchange (incl. AIM and International Order Book) Euronext (Brussels, Paris, Lisbon and Amsterdam) Page 4

5 Main brokers BROKERS Bank Zachodni Wbk, SA BSN Dealers Cantor Fitzgerald London Citibank NA London Credit Suisse London Daiwa Securities Exane Fincor Sociedade Corretora, S.A. Flow Traders B.V. Goldman Sachs HSBC Investment Bank PLC ING Group Instinet Intesa San Paolo Investment Technology Group LTD. Jefferies International LTD. J.P. Morgan Securities LTD Merrill Lynch Morgan Stanley International London Nomura International PLC Royal Bank of Canada Santander Investment Sec. New York UBS AG (London Equities) Winterflood Securities Page 5