Fintailor Investments is regulated by Cyprus Securities and Exchange Commission under licence number 133/11.

Transcription

1 BEST EXECUTION POLICY INTRODUCTION Directive 2004/39/EC of the European Parliament and of the Council of 21 April 2004 on markets in financial instruments amending Council Directives 85/611/EEC and 93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repealing Council Directive 93/22/EEC, as the same may be in force from time to time and modified or amended from time to time, which was implemented in the Republic of Cyprus by the Investment Services and Activities and Regulated Markets Law of 2007 (Law 144(I)/2007) as the same may be in force from time to time and modified or amended from time to time and as amended and supplemented by the directives adopted by the Cyprus Securities and Exchange Commission (collectively referred to as the Law ) essentially introduce a single regulatory regime for the provision of investment services across the European Economic Area, governing, among other matters, operating conditions relating to the performance of investment and ancillary services on a professional basis in order to ensure a high level of integrity, competence, soundness and transparency among the leading market participants. Following the requirements of the Law, when executing client orders and for the purposes of ensuring that FINTAILOR takes all reasonable steps to obtain the best possible result for its clients, FINTAILOR shall at all times comply with this Best Execution Policy. BEST EXECUTION When establishing its best execution policy, FINTAILOR determines the relative importance of the factors related to execution and implements effective arrangements in order to deliver the best possible result to its clients, meaning such result that is determined by FINTAILOR to be obtainable with due regard to and after taking such reasonable steps as are provided in this Best Execution Policy. Subject to any specific client instruction, when executing client orders (meaning where FINTAILOR directly executes client orders, directly executes discretionary investment management decisions to deal on behalf of clients, transmits client orders to other entities for execution, places discretionary investment management decisions to deal on behalf of clients with other entities) FINTAILOR takes into account the following execution factors: Price of financial instruments Costs related to execution (including settlement costs) Speed of execution Likelihood of execution Settlement reliability Nature of client order Size of client order Any other factor impacting the efficiency and continuity of the execution or otherwise relevant to the execution of the client order FINTAILOR exercises discretion, in the absence of specific client instructions stating otherwise, in determining the relative importance of the execution factors by using its professional judgment and experience, in light of market and other information available. In particular, FINTAILOR shall take into account the following criteria for determining the relative importance of the execution factors: the characteristics of the client, including its categorization as a retail client of a professional client the characteristics of the client order the characteristics of the financial instruments that are subject of the order the characteristics of the execution venues to which that order can be directed The best possible result for persons classified under the Law and the Client Categorization Policy of FINTAILOR as retail clients is determined in terms of total consideration, representing the price of the financial instruments and the costs related to execution, including FINTAILOR remuneration and commissions, fees payable to execution venues, clearing and settlement agencies, fees payable to third parties involved in the execution of the order and other implicit costs and expenses related to execution that shall be incurred by the client, to the extent applicable. The relative importance of other execution factors shall be taken into consideration, but only to the extent such factors contribute to the obtaining of the best possible result as determined in accordance with this paragraph. For professional clients, in general, price of financial instruments may be the dominant factor when obtaining the best possible result. However, markets, financial instruments and transaction type vary greatly in terms of liquidity, depth, transparency, certainty, ease and speed of execution, etc. and FINTAILOR may therefore determine that best possible result shall be obtained by placing greater reliance on other execution factors. Subject to any specific client instructions, FINTAILOR shall make that determination on basis of the criteria specified above and, to the extent appropriate, with regard to the other provisions of this Best Execution Policy. SECURITIES SUBJECT TO THE POLICY FINTAILOR execution policy addresses the different classes of instrument for which FINTAILOR carries out orders, including, but not limited to: Transferable securities, meaning all classes of securities which are negotiable on the capital market, with the exemption of instruments of payment, such as: o shares in companies and other securities equivalent to shares in companies, partnerships and other entities, and depositary receipts in respect of shares; o bonds or other forms of securitised debt, including depositary receipts in respect of such securities; o any other securities giving the right to acquire or sell any such transferable securities or giving rise to a cash settlement determined by reference to securities, currencies, interest rates or yields, commodities or other indices or measures Money-market instruments, meaning those classes of instruments which are normally dealt in on the money market, such as treasury bills, certificates of deposit and commercial papers, excluding instruments of payment

2 Units in collective investment undertakings Options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields, or other derivatives instruments, financial indices or financial measures which may be settled physically or in cash Options, futures, swaps, forward rate agreements and any other derivative contracts relating to commodities that must be settled in cash or may be settled in cash at the option of one of the parties (otherwise than by reason of a default or other termination event). Options, futures, swaps and any other derivative contract relating to commodities that can be physically settled provided that they are traded on a regulated market or/and a Multilateral Trading Facility Options, futures, swaps, forwards and any other derivative contracts relating to commodities, that can be physically settled not otherwise mentioned in preceding paragraph and not being for commercial purposes, which have the characteristics of other derivative financial instruments, having regard to whether, inter alia, they are cleared and settled through recognised clearing houses or are subject to regular margin calls Derivative instruments for the transfer of credit risk Financial contracts for differences Options, futures, swaps, forward rate agreements and any other derivative contracts relating to climatic variables, freight rates, emission allowances or inflation rates or other official economic statistics that must be settled in cash or may be settled in cash at the option of one of the parties (otherwise than by reason of a default or other termination event), as well as any other derivative contract relating to assets, rights, obligations, indices and measures not otherwise mentioned, which have the characteristics of other derivative financial instruments, having regard to whether, inter alia, they are traded on a regulated market or a Multilateral Trading Facility, are cleared and settled through recognised clearing houses or are subject to regular margin calls. For the purposes of best investment protection FINTAILOR strongly recommends the clients or potential clients qualified under the Law rules as retail clients to enter in the most part into transactions in exchange listed equities and similar instruments the volatility of which is under control of the relevant market regulators. Assessing the risks involved in relation to various financial instruments, FINTAILOR advises the clients falling within a retail client category to assume for trading the non-complex financial instruments. FINTAILOR acting in best interests of the clients suggests to the clients or potential clients who are classified as retail clients under the Law refrain from execution of trades either in exchange tradable vanilla instruments, that is in the most basic or standard version of a derivative instruments admitted to trading on a regulated market or in an equivalent third country market, or in exotic derivative instruments, which alter the components of a traditional derivative instrument, resulting in a more complex security where an additional contingency is added. The clients are warned that complex financial instruments are not appropriate for all categories of investors and retails clients are requested to seek professional advice before instructing FINTAILOR to execute any order in respect of complex financial instruments. The following categories of financial instruments are considered to be complex financial instruments: financial instruments that have any of the following characteristics or a combination of such characteristics: o financial instruments that are derivatives or embed a derivative; o financial instruments that are made up of one or more underlying financial instrument(s) that are difficult to value, or are combined in such a way so as to make it difficult to assess the risks involved and the likely performance scenarios o financial instruments that use more opaque indices that are for example set up by the product manufacturer, rather than using standard market indices o financial instruments that have a fixed investment term of a number of years with barriers to exit (that are not clearly explained) - whether that is due to the lack of a secondary market, or significant penalties or losses on early exit o financial instruments that have returns/pay-off structures involving multiple variables or complex mathematical formulas o financial instruments that include capital protection that may be conditional or partial, or that can be withdrawn on the occurrence of certain events other complex products, such as contracts for difference (CFDs); binary options; turbos; exchangeable bonds; callable bonds; puttable bonds; convertible bonds; perpetual bonds; subordinated bonds; warrants; certificates; derivatives relating to underlying securities, currencies, interest rates, yields, or commodities; credit linked notes; and asset-backed securities. MATTERS INCIDENTAL TO EXECUTION FINTAILOR shall ensure: that orders executed on behalf of clients are promptly and accurately allocated in accordance with Order Allocation and Aggregation Policy; that the retail clients are informed about any material difficulty relevant to proper carrying out of orders promptly upon becoming aware of the difficulty, provided that such difficulty is not foreseen by the retail clients In general, FINTAILOR shall act according to client order as soon as practically possible and within a time frame reasonably seen in the context of the nature of the order. Unless otherwise agreed between FINTAILOR and the client, FINTAILOR shall exert all reasonable efforts to execute client orders within the business day when FINTAILOR receives the respective order. Subject to any specific client instructions, FINTAILOR may partially execute any client order where such partial execution is determined to obtain the best possible result for the client. In the event of partial execution, FINTAILOR shall exert all reasonable efforts to execute client orders in full within the business day when FINTAILOR partially executes the order. If, after the client order is received or partially executed, FINTAILOR believes that it is not reasonably practicable to act upon such client order in full or in any part, because of the characteristics of the client order or prevailing market conditions make this impracticable or the interests of the client require otherwise, FINTAILOR may defer acting upon such client order in full or in such part until it is, in FINTAILOR reasonable opinion, practicable to do so, subject to prior cancellation

3 or amendment of the order by the client. Subject to specific client instructions, no order shall be deemed cancelled or otherwise amended by lapse of time, unless the client informs FINTAILOR of such cancellation or amendment in accordance with and subject to the procedures for cancellation and amendment of orders agreed upon with FINTAILOR. By consenting to this Best Execution Policy and subject to any express agreement to the contrary, where any client orders are client limit orders (order to buy or sell a financial instrument at its specified order limit or better and for a specified size) FINTAILOR is shall not be obliged to take measures to facilitate the earliest possible execution of client orders by making public immediately that client limit order in a manner which is easily accessible to other market participants, including by transmitting the client limit order to a regulated market and/or a Multilateral Trading Facility. In the course of execution of client orders, FINTAILOR may transmit client orders or place discretionary investment management decisions to deal on behalf of clients for execution by another entity, provided that such transmission or placement is determined by FINTAILOR to enable obtaining the best possible result for the client in accordance with this Best Execution Policy. Without prejudice to obligations of FINTAILOR under this Best Execution Policy, the clients are informed that in the event of execution by another entity, the rules and procedures adopted by such other entity shall be applicable to such execution and FINTAILOR may not be able to exercise significant control over implementation of the same. Where FINTAILOR is responsible for overseeing or arranging the settlement of an executed order, it shall take all reasonable steps to ensure that any client financial instruments or client funds received in settlement of that executed order are promptly and correctly delivered to the account of the client. To the extent prescribed by the Law, FINTAILOR shall determine whether the investment services or financial instruments/products envisaged by the client are appropriate to the client, meaning that the client has sufficient knowledge and experience in the investment field relevant to the specific types of financial instruments/products or services offered or demanded in order to understand the risks involved in relation to such financial instruments/products or services offered or demanded. Clients are informed that: the clients that were categorized as retail clients shall not be presumed to possess the necessary experience and knowledge in order to understand the risks involved and FINTAILOR does not consider that any of the financial instruments/products or services are appropriate for such clients unless and until otherwise determined by FINTAILOR on basis of information collected; the clients that were categorized as professional clients shall be presumed to possess the necessary experience and knowledge in order to understand the risks involved in relation to those particular investment services or transactions, or types of transaction or financial instruments/products, for which the client is classified as a professional client. For the purposes of proper assessment of appropriateness, FINTAILOR requests all retail clients to provide FINTAILOR with and to ensure that FINTAILOR is provided with the following up-to-date information: the types of service, transaction and financial instrument with which the client is familiar; the nature, volume, and frequency of the client's transactions in financial instruments and the period over which they have been carried out; the level of education, and profession or relevant former profession of the client; all of the following information in respect of the persons responsible for carrying out transactions/submission of client orders on behalf of the client Should FINTAILOR at any time determine that any investment services or products are not appropriate for the client, the client is warned that the client does not or is not likely to possess sufficient knowledge and experience in order to understand, assess and control the risks involved. Should the client fail to provide all the information requested or fail to ensure that FINTAILOR is provided with up-do-date information, the client is warned that such the failure would result in inability of FINTAILOR to determine whether any investment services or products are appropriate for the client. Should the client instruct FINTAILOR to proceed with execution of client orders or submit orders to FINTAILOR for execution notwithstanding such warnings or notwithstanding the determination by FINTAILOR that any one or more of investment services or financial instruments/products envisaged are not appropriate for the client, FINTAILOR may proceed with execution of client orders, but the client is warned that the client shall not benefit from the corresponding protection of the relevant conduct of business rules and that FINTAILOR reserves the right not to perform any advisory functions in respect of such client order (to execute the order on execution-only basis). Clients are informed that FINTAILOR is not required to assess the appropriateness of certain financial instruments/products and services provided or offered and that therefore clients do not benefit from the corresponding protection of the relevant conduct of business rules. FINTAILOR shall not consider that such instruments/products and services are not appropriate for clients, without prejudice to its obligations under the Law. In accordance with the provisions of the Law, the following financial instruments/products and services are subject to such exemption: the services that only consist of the reception and transmission or/and execution of Client s orders, with or without ancillary services, where they are provided at the initiative of the Client and relate to non-complex financial instruments; subject to the condition in the following paragraph, non-complex financial instruments include all of the following: o shares admitted to trading on a regulated market or in an equivalent third country market (a third country market shall be considered as equivalent to a regulated market if it complies with requirements equivalent to those laid down in the Law), money market instruments, bonds or other forms of securitised debt (excluding those bonds or securitised debt that embed a derivative), UCITS; and o other non-complex financial instruments, meaning financial instruments that satisfy the following criteria: the financial instruments are determined to be shares in companies and other securities equivalent to shares in companies, partnerships and other entities, bonds or other forms of securitised debt, including depositary receipts in respect of such any of such financial instruments, but expressly excluding any financial instruments that are considered to be complex financial instruments; there are frequent opportunities to dispose of, redeem, or otherwise realize that instrument at prices that are

4 publicly available to market participants and that are either market prices or prices made available, or validated, by valuation systems independent of the issuer; such financial instruments do not involve any actual or potential liability for the client that exceeds the cost of acquiring the instrument; adequately comprehensive information on the characteristics of such financial instrument is publicly available and is likely to be readily understood so as to enable the average retail client to make an informed judgment as to whether to enter into a transaction in that instrument. METHOD OF EXECUTION FINTAILOR applies this Best Execution Policy to each client order that it executes with a view to achieve the overarching best execution of client orders and decisions to deal in financial instruments in accordance with its policy. EXCHANGE TRADING Unless FINTAILOR determines otherwise in the course of determination of execution venues, in situations where the security is listed on one financial instruments exchange (single listing), FINTAILOR forwards the order to such financial instruments exchange or if the security is listed on two or more financial instruments exchanges (multiple listing), forwards the order to any financial instruments exchange at its discretion based on the available market price, trading volume and other factors for a certain period of time. However, the foregoing does not apply in exceptional circumstances including, but without limitation, where FINTAILOR determines based on the trading volume and other factors related to the security during a certain period of time that there is no substantial difference in liquidity among the financial instruments exchanges, and where the trading volume on a particular financial instruments exchange is expected to be larger than usual due to certain market factors. In such a case, the order is forwarded to a financial instruments exchange selected by FINTAILOR taking into account the liquidity and expected market impact of the order. FINTAILOR will provide detailed information about its selection to clients upon request. If FINTAILOR is not a participating member nor has a membership in a financial instruments exchange to which the client order is to be forwarded under best execution policy, FINTAILOR will forward such order to that financial instruments exchange through an exchange participating member with whom FINTAILOR has made a relevant prior agreement. TRADING OUTSIDE REGULATED MARKETS OR MULTILATERAL TRADING FACILITY (MTF) FINTAILOR may execute client orders outside a regulated market or Multilateral Trading Facility against a principal position, thereby acting for the client as an execution venue where prices shall reflect the current market prices that FINTAILOR can obtain, taking into account the execution factors and criteria described above. Subject to express consent with the client to that effect in respect of any particular client order, FINTAILOR may execute any client order against principal position, thereby acting for the client as an execution venue where prices do not necessarily reflect current market prices that FINTAILOR can obtain, in which case FINTAILOR may cross/match the client order with a relevant order of another client of FINTAILOR or with proprietary position of FINTAILOR. The Client is warned that in this case FINTAILOR will only give prices that have been communicated to FINTAILOR by other clients operating in the same market or, in case of execution of client order against proprietary position of FINTAILOR, that have been determined by FINTAILOR and therefore any best result of such trade will solely be within these limits. It is provided that FINTAILOR would not request prior express consent of the client to cross/match the client order with a relevant order of another client of FINTAILOR or with proprietary position of FINTAILOR where the same is determined to obtain the best possible result for the client. In the course of such execution of client orders, FINTAILOR shall closely adhere to its Conflict of Interests Policy and requirements of the Law in order to ensure that such execution does not result in material determent to the interests of its clients. No execution of client orders shall take place outside regulated markets or Multilateral Trading Facilities in the absence of the prior client express consent to such execution in general or, where general consent is not given, in respect of any particular client order. Clients are informed that revocation of consent to such execution of client orders may result in inability of FINTAILOR to offer any one or more of services in respect of such financial instruments that are commonly traded outside regulated markets and Multilateral Trading Facilities. MARGIN TRADING Margin trading is more aggressive and involves a higher degree of risk than an ordinary trading. A client may use margin to perform transactions in financial instruments for which it does not have available or sufficient investment capital. These activities could lead to shortfalls in the client's account in the event of a market downturn or upon occurrence of such other events that may be inconsistent with anticipation of the client. Margin trading is suitable only for those clients who fully understand its nature and who can bear the responsibility and increased risk. In this light, FINTAILOR acting in best interests of the clients suggests to the clients or potential clients who are classified as retail clients under the Law refrain from margin trading for the purposes of best investment protection. In all cases FINTAILOR risk management policies and procedures shall apply. The clients or potential clients who are qualified as retail clients under the Law are kindly requested to note that FINTAILOR negotiates a margin level with clients on the case-by-case basis and, subject to an express agreement to the contrary, may unilaterally impose additional or alternative margin requirements upon occurrence of extraordinary events or in any circumstances where FINTAILOR determines that original margin levels negotiated may or are liable to result in inability of the client to settle any of the transactions in financial instruments. EXECUTION VENUES In order to give effect to the execution policy FINTAILOR selects the execution venues and market access providers that enable it to obtain on a consistent basis the best possible result for the execution of client orders and decisions to deal in financial instruments listed in the Law. Subject to any specific client instruction, in the course of selection of the execution venues FINTAILOR shall base itself upon the execution factors and their relative importance for the execution of the particular client order. The execution venues are the sources of liquidity that FINTAILOR accesses for each of the financial instruments in respect

5 of which FINTAILOR execute client orders. These venues include: Regulated markets and other exchanges to which FINTAILOR has permanent access Multilateral Trading Facilities operated either by FINTAILOR or a third party Systematic internalisers Market makers and other liquidity providers Non-EEA entities performing a similar function to any of the above An indicative list of execution venues on which FINTAILOR places significant reliance in meeting its obligations to take all reasonable steps to obtain on a consistent basis the best possible result for the execution of client orders is provided as Schedule 1 to this Best Execution Policy. It should be noted that this list is subject to periodic review by FINTAILOR and does not include all execution venues on which FINTAILOR may rely in the course of execution of client orders. Should FINTAILOR determine the same to be necessary in order to obtain best possible result for its client, FINTAILOR may rely upon alternative execution venues or not to rely on any particular execution venues, including on provisional basis or to accommodate a client request to trade in an unusual instrument or subject to satisfaction of particular requirements. ORDER ALLOCATION AND AGREGATION POLICY FINTAILOR keeps the record of all client orders, including precise date and time of receipt. Upon receipt of client order FINTAILOR proceeds with transmitting the order to the relevant execution venue and arranges for a practicable soonest execution of the order. All comparable orders shall be executed sequentially, on "first come, first served" basis, with due regard to the mode in which the order is communicated, e.g. in case when two equivalent orders are transmitted through the electronic trading system, the first received order must be transmitted or executed before the second (save that all other things equal), but in case when one order is communicated by phone and the second is transmitted through electronic trading system, faster execution of the second order is more probable by virtue of speed advantages attributable to electronic trading system. In certain market circumstances FINTAILOR may aggregate client orders with client orders of other clients and transactions of FINTAILOR for own account, including due to the following reasons: Execution of an aggregated order may result in lesser execution costs; Execution of an aggregated order is the most suitable type of execution due to certain characteristics of the transaction, i.e. the transaction is based upon a takeover or mandatory bid, etc.; The large size of aggregated order may result in more advantageous prices for the clients; Client order is incapable of being executed without aggregation under prevailing market conditions or due to characteristics of the client order. FINTAILOR would not aggregate client orders with client orders of other clients and transactions for own account unless the following conditions are met: it must be unlikely that the aggregation of orders and transactions will work overall to the disadvantage of any client whose order is to be aggregated; FINTAILOR has disclosed to each client whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to a particular order. By consenting to this Best Execution Policy, the client consents to aggregation of client order with client orders of other clients of FINTAILOR, provided that FINTAILOR determines, with regard to the information available, that such conditions have been satisfied. In case of partial execution of the aggregated order, the trade shall be allocated among the clients, whose orders were aggregated, on sequential basis as described above, irrespective of price and volume of each client order. Where it is not possible to allocate any part or all (as applicable) of the trade on sequential basis as described above, FINTAILOR shall allocate such part or all (as applicable) of the trade: equally among the clients whose orders were aggregated, irrespective of price and volume of each client order, provided that such part or all (as applicable) of the trade is capable of being allocated equally; or to such clients, whose client orders permit allocation of such part or all (as applicable) of the trade to them by reference to volume of each client order, but irrespective of the price of each client order, provided that such part or all (as applicable) of the trade is not capable of being allocated equally and such allocation is performed on sequential basis as described above. By providing express consent to aggregation of any client order, the client confirms its understanding that the effect of aggregation may work to its disadvantage in respect of a particular order, including that it may not be possible to cancel the client orders that have been aggregated, that the speed and likelihood of execution may be reduced, that settlement reliability may be negatively affected, that the difference in price and costs may not be significant or may not convey sufficient benefit to the client and that, in case of partial execution, FINTAILOR shall allocate the trade in accordance with the principles described above. Where FINTAILOR aggregates client orders with transactions on own account, FINTAILOR shall not allocate the trade in any manner that may be prejudicial to the clients whose orders have been aggregated with transactions of FINTAILOR on own account. In particular, in case of partial execution FINTAILOR shall always allocate the related trades to the clients in priority to FINTAILOR and shall not permit reallocation in a way that is detrimental to the clients. To the extent such requirements are satisfied, FINTAILOR is entitled to allocate any part or all (as applicable) of the trade in accordance with the principles described above. EXEMPTIONS FROM THE PROVISION OF BEST EXECUTION ELIGIBLE COUNTERPARTIES Entities falling within an Eligible counterparty category are not entitled to best execution under the Law and therefore are not deemed to have the best execution regime applied to transactions and/or any investment and/or ancillary services provided to such entities by FINTAILOR without prejudice to the right of such entities to request either on a general form or on a trade-by-trade basis, treatment as retail or professional clients and without prejudice to obligation of FINTAILOR to provide the benefit of this Best Execution Policy to such clients in circumstances prescribed by Law.

6 SPECIFIC CLIENT INSTRUCTIONS Where FINTAILOR determines that it is provided with a specific client instruction in relation to an entire client order or any particular aspect of a client order, including an instruction for a trade to be executed on a particular venue, FINTAILOR will execute the order in accordance with specific client instruction. It should be noted, however, that FINTAILOR in following specific client instructions will be deemed to have taken all reasonable steps to provide the best possible result in respect of the order or the aspect of the order covered by a specific client instruction. The clients are warned that specific instructions that may be provided by clients in relation to an entire client order or any particular aspect of a client order may prevent FINTAILOR from taking the steps that it has designed and implemented in this Best Execution Policy to obtain the best possible result for the execution of the orders in respect of the elements covered by those instructions. MONITORING AND REVIEW, OTHER MATTER FINTAILOR shall monitor the effectiveness of its order execution arrangements and execution policy in order to identify and, where appropriate, correct any deficiencies precluding it from compliance with statutory requirements and obtaining the best possible result for the execution of client orders on a consistent basis. Should FINTAILOR implement any material changes to this Best Execution Policy, FINTAILOR shall notify its clients who might be affected by such changes in the manner appropriate or otherwise agreed upon between the client and FINTAILOR. By consenting to this Best Execution Policy, the client undertakes to ensure prompt review of all amendments to this Best Execution Policy, as may be notified by FINTAILOR or published on the web-site of FINTAILOR at: Should the client have any questions about any matters specified in this Best Execution Policy or its effects on execution of client orders, the client is advised to contact FINTAILOR in order to seek clarifications.

7 SCHEDULE 1 to Best Execution Policy List of execution venues/execution venue access providers for transaction with transferable securities, money-market instruments and units in collective investment undertakings (including related financial instruments that may possess characteristics of complex financial instruments): JSC Alfa Bank Alfa Capital Holdings (Cyprus) Limited ATONLINE Limited Merrill Lynch International BrokerCreditService (Cyprus) Limited PJSC JSCB BALTICA BNP Paribas, London Branch CJSC Citibank Credit Bank of Moscow (OJSC) Commerzbank AG Credit Suisse Securities Europe Ltd Deutsche Bank AG Global Credit Partners, LLC GFI Securities Ltd Goldman Sachs International Gazprombank (OJSC) ING Bank (Eurasia) ZAO (CJSC) J.P. Morgan Securities PLC Knight Capital Europe Limited Leonteq Securities AG OJSC MDM BANK MeritKapital Limited Morgan Stanley and Co. International PLC Mitsubishi UFJ Securities International PLC PJSC MTS-Bank Nomura International PLC Otkritie Securities Limited PJSC Bank Oktritie Financial Corporation PJSC Promsvyazbank Raiffeisen Bank International AG CJSC Raiffeisenbank Renaissance Securities (Cyprus) Ltd Ronin Europe Limited Schildershoven Finance B.V. SIB (Cyprus) Ltd Sigma Broking Ltd UBS Limited Unicredit Bank AG (HypoVereinsBank) VTB Capital PLC Bank ZENIT (PJSC) List of execution venues/execution venue access providers for transaction with derivatives and other complex financial instruments: BrokerCreditService (Cyprus) Limited Otkritie Securities Limited Promsvyazbank OJSC Renaissance Securities (Cyprus) Ltd VTB Capital PLC