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Disclosure of Information on the Identity of Execution Venues and on the Quality of Execution by Investment Firms

AKCENTA is obliged to comply, pursuant to Articles 64-66 of Regulation 2017/565, with the rules for  best execution of orders. The objective of these rules is to ensure that every individual client order is executed in compliance with the relevant rules for order execution and to ensure consistent execution of orders under the best possible conditions. AKCENTA stipulates that these rules are shared for all customer categories (non-professional clients, professional clients and eligible counterparties).

The review of compliance with best execution obligation shall take into account the specific nature of this type of transactions, where the products offered by AKCENTA (OTC derivatives) are instruments concluded on the basis of a specific request from the client and factually have no exact equivalent traded at the Regulated Market, Multisided Trading System or Organised Trading System. The execution venue is the securities broker itself (AKCENTA) and other factors relevant from the viewpoint of best execution are subordinated to the fact that they are subject to individual agreement between the securities broker and client in the arrangement of the given product. The Regulation 2017/565 further stipulates for non-standardised OTC derivatives that they shall include unique contractual relationship taking into account specific conditions of the client and securities broker (AKCENTA), and do not necessarily have to be fully comparable for the purpose of best execution with trades involving shares traded at the Regulated Market, Multi-sided Trading System or Organised Trading System. As the best execution obligation applies to all investment instruments, it is necessary to obtain for products offered by AKCENTA the relevant market data to verify whether the price offered to the client on OTC market is correct and ensures fulfilment of the securities broker’s obligation to ensure best execution of client orders. This means that the broker (AKCENTA) checks the correctness of the specific price proposed to the client not only according to the market data accessible to the client, used for the estimation of the price of the arranged but also, if possible, through comparison with similar or comparable products. The market commodity of OTC derivatives arranged with clients is monitored before the relevant contract is entered into.

Listed below are the criteria for determining the best terms according to their relative importance in descending order.

Criterion

Procedure and importance of criterion

Ranking acc. to importance

Achievable price

Lowest price is decisive in the case of a purchase, highest price is the case of sale. The quality of price depends on the number of traders and current supply and demand.

To compare specific prices, AKCENTA uses the business platforms of selected banks (ING, DB) and information sources REUTERS and BLOOMBERG.

1

Quality  (credibility) of counterparty

AKCENTA, in compliance with its own risk management rules, evaluates the selection of counter-parties for the quality of provided services (arranged terms), credibility and financial stability

2

Speed at which the order can be executed

The settlement speed includes the speed of transfer between banks

3

Volume of requested trade

Volume is taken into account in relation to the counter-party’s conditions and limits

4

Volume of fees billed to client

AKCENTA is the execution venue for the client. The fees are governed by the valid Pricelist or individual pricing program. Not relevant for the counter-party’s evaluation

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Volume of own fees billed to client

AKCENTA is the execution venue for the client. The AKCENTA does not transfer fees for investment instruments billed by the counter-party onto the clients

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In case that multiple counter-parties exist for one order, AKCENTA proceeds according to the criteria defined above from the most important towards less important ones. For specific orders, AKCENTA will always consider factors for best execution of order, such as price (1), counterparty risk (2) and speed (3) – and selects the counterparty for the trade according to these factors.

AKCENTA is obliged to publish (based on EU Commission Directive 2017/576 of June 8, 2016), five execution venues for individual types of investment instruments on which it executed client orders, a summary and conclusions of the analysis of trade execution quality. AKCENTA is the execution venue for the client. The attached information is based on the templates contained in Annex II to Directive 2017/576.

Glossary of terms
  • RT - Regulated Market
  • OOS - Organised Trading System
  • MOS - Multi-sided Trading System
  • OTC derivatives - Derivatives may be traded OTC (Over the Counter) or on the offbourse market. The most transactions are done OTC.
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