Contents ORDER EXECUTION POLICY FOR RETAIL CLIENTS... 2 1. Field of application of the Order Execution Policy... 2 2. Obligation for Best Execution... 2 3. Execution Venues... 2 4. Types of transactions that limit the obligation for Best Execution... 3 5. Specific instructions... 3 6. Priority... 3 7. Monitoring and Review... 3 LARGE SIZE ORDERS DEFINITION TABLE... 4 APPENDIX I... 5 1
ORDER EXECUTION POLICY FOR RETAIL CLIENTS Following the implementation of MiFID, which has been incorporated in the Greek Legislation by L. 3606/2007, Alpha Finance Investment Services S.A. (hereinafter referred to as Alpha Finance ) would like to inform you of the Order Execution Policy it has adopted and pertains to its obligation to take all reasonable steps to obtain the best possible result for the client (Best Execution), when executing orders of its Retail Clients. The factors taken into consideration in the policy applied is the price, cost, speed, likelihood of execution and settlement, the volume, the nature of the order and/or any other factor pertaining to the execution of the order. The policy is applied either for the orders executed by Alpha Finance on behalf of its clients, or for the orders transmitted to third parties for execution. 1. Field of application of the Order Execution Policy The Order Execution Policy set out below is applied only for the execution of orders which have been accepted by Alpha Finance and have been placed by Retail Clients. Alpha Finance is liable for Best Execution only for transactions carried out by it in the following financial instruments, defined in article 5 of L. 3606/2007 Shares and Warrants Corporate bonds Exchange Traded Funds (ETFs) Derivative Products 2. Obligation for Best Execution When executing Retail Clients orders in financial Instruments, Alpha Finance will take all reasonable steps to achieve the best possible result for these orders. Alpha Finance has adopted such policies and procedures in order to achieve the best possible result in a systematic way, taking into consideration the kind of the financial Instrument, the nature of the order, the execution venue, as well as any other additional special instructions the client has given to it in relation to the execution of its order. Alpha Finance has taken all the necessary measures for the avoidance of conflicts of interest between its clients, but also between its clients and its employees. Alpha Finance will take into account several factors in order to achieve the best possible result, the most important being the price of the financial instrument. Alpha Finance may also take into consideration other factors which may influence the execution of the order such as the ability to achieve a better price, the market liquidity, the market impact, the size of the order and the nature of the transaction, the execution venue (Regulated Market, MTF, Over the Counter) etc. Unless the Retail Client instructs Alpha Finance to the contrary, Alpha Finance is obliged to make public immediately the Retail Client s limit order in respect of shares admitted to trading on an EU Regulated Market, which is not immediately executed. Alpha Finance is not required to make public an order which is large in scale. An order is considered as large in scale compared with the normal size, if it is equal or larger compared to the minimum size (please see the LARGE SIZE ORDER DEFINITION TABLE). The Average Daily Turnover for each kind of share contained in this table is specified by the relevant Supervisory Authority. 3. Execution Venues The Best Execution Policy of Alpha Finance refers to the financial instruments for which it may receive orders and includes the execution venues in which it deems possible to achieve the best possible result on a consistent basis. The execution venues where Alpha Finance has direct or indirect access include Regulated Markets, MTFs, systematic internalisers, market makers and other liquidity providers (including Alpha Finance) 2
For markets where Alpha Finance has no direct access, it transmits its clients orders for execution to other brokers or credit institutions, APPENDIX I contains the main execution venues where Alpha Finance operates in order to fulfill its obligation to achieve the best possible result for its clients orders. For these orders, Alpha Finance: Either defines to the broker or to the credit institution the execution manner and venue based on the Best Execution Policy that Alpha Finance has adopted, Or transmits its clients orders without further instructions, provided that Alpha Finance has accepted the broker s or the credit institution s Best Execution Policy which is in line with the policy adopted by Alpha Finance. Alpha Finance has formed its pricing policy in a manner, which does not introduce unfair distinctions between the execution venues. 4. Types of transactions that limit the obligation for Best Execution In cases where orders or transactions are of a specific nature, the best execution obligation is limited. Such cases might be the following: Where the order pertains to a financial instrument traded on only one execution venue. In such a case the only criterion for the fulfillment of the best execution obligation is the time of execution. OTC transactions since there are no comparable prices to respective transactions or financial instruments. For this reason, when Alpha Finance receives an order of a Retail Client for OTC transactions, Alpha Finance will require its specific instruction. 5. Specific instructions When the client gives specific instructions in relation to the execution of an order (e.g. price limit, execution venue etc.), Alpha Finance will execute in accordance with these instructions. In this case, Alpha Finance does not have the obligation for Best Execution. Provided there are no specific instructions by the client in relation to the execution of its order, Alpha Finance will execute the order at its own discretion, taking into account and assessing those factors which will lead to the achievement of the best possible result for the client. In case where the client selects to transmit an order through an Alpha Bank branch, or through ALPHA PHONE TRADING, ALPHA IVR TRADING, or ALPHA WEB TRADING, the client should set the order s characteristics such as purchase or sale share price, size, order type, venue. In this case, Alpha Finance obligation for best execution is fulfilled, deeming that the client has given specific instructions in relation to the execution of its order. Consequently, when the client wishes its order to be executed in a different manner than the manner defined in the Order Execution Policy of Alpha Finance, it must give relative clear instructions. If the instructions are not clear, Alpha Finance will determine the unclear factors of the order based on the Order Execution Policy it has adopted. 6. Priority The orders are placed for execution with a time priority which is determined by the time of their receipt. 7. Monitoring and Review Alpha Finance will periodically (annually) or earlier, reexamine the Order Execution Policy and will proceed to the appropriate adjustments if required, in order to improve its effectiveness. Alpha Finance will inform its customers of any change. 3
The Order Execution Policy applied by Alpha Finance for the clients who have been categorized as Retail Clients is available on the website of Alpha Finance at www.alphafinance.gr. LARGE SIZE ORDERS DEFINITION TABLE The following table is an extract from the Commission Regulation no. 1287/2006, Appendix ΙΙ, Table ΙΙ, in which the orders are defined which may be considered as exceeding the normal market size. Based on this table the obligation is determined, whether or not to publicize a limit order. Class in terms of average daily turnover (ADT) Minimum size of order qualifying as large in scale compared with normal market size Orders large in scale compared with normal size ADT<500,000 500,000 ADT <1,000,000 1,000,000 ADT <25,000,000 25,000,000 ADT <50,000,000 (in Euro) ADT 50,000,000 50,000 100,000 250,000 400,000 500,000 4
APPENDIX I EXECUTION S EUROPEAN MARKETS GREECE CYPRUS AUSTRIA BELGIUM DENMARK FINLAND FRANCE FRANCE GERMANY IRELAND ITALY NETHERLANDS NETHERLANDS NORWAY NORWAY PORTUGAL SPAIN SPAIN SWEDEN SWEDEN SWITZERLAND SWITZERLAND SWITZERLAND UNITED KINGDOM ATHEX CSE WIENER BOERSE AG AMTLICHER HANDEL EURONEXT BRUSSELS OMX NORDIC EXCHANGE COPENHAGEN A/S OMX NORDIC EXCHANGE HELSINKI NYSE EURONEXT EUROLIST BY EURONEXT PARIS FRANKFURTER WERTPAPIERBOERSE MAIN MARKET OF IRISH STOCK EXCHANGE ELECTRONIC SHARE MARKET NYSE EURONEXT - ALTERNEXT AMSTERDAM NYSE EURONEXT - EURONEXT AMSTERDAM OSLO BΟRS ASA FISH POOL ASA EUROLIST BY EURONEXT BOLSA DE MADRID MERCADO CONTINUO ESPANOL FIRST NORTH STOCKHOLM OMX NORDIC EXCHANGE STOCKHOLM SCOACH SWITZERLAND SWISS EXCHANGE SWX EUROPE LIMITED AIM AMERICAN MARKETS CANADA NYSE ARCA OTC BULLETIN BOARD NYSE AMEX EQUITIES NASDAQ CAPITAL MARKET NASDAQ/NGS NASDAQ/NMS NEW YORK STOCK EXCHANGE INC OTC BULLETIN BOARD TORONTO STOCK EXCHANGE 5
ASIAN MARKETS HONG KONG JAPAN JAPAN SINGAPORE STOCK EXCHANGE OF HONG KONG LTD OSAKA SECURITIES EXCHANGE TOKYO STOCK EXCHANGE SINGAPORE EXCHANGE AUSTRALIAN MARKETS AUSTRALIA AUSTRALIAN SECURITIES EXCHANGE LIMITED EXECUTION S FOR DERIVATIVES GREECE GERMANY NETHERLANDS UNITED KINGDOM UNITED KINGDOM SINGAPORE ATHEX-DERIVATIVES MARKET AMEX EUREX EURONEXT LIFFE CME CBOT CBOE LME COMEX & NYMEX ICE NYBOT & NYCE SIMEX SGX 6