Rules and procedures regarding order placement policy

The company is making its best efforts in order that transactions performed on behalf of managed portfolios be made ​​in the best conditions for those portfolios in terms of price, costs, speed, likelihood of execution and settlement, volume, nature of order or any other relevant characteristics for the execution of the order.

Importance of factors that lead to the best results on the investments of UCIs (Undertaking for Collective Investment) managed by the Company, are established based on the following criteria:

  • objectives, investment policy and risks specific to UCIs specified in the fund establishment documents;
  • characteristics of order;
  • characteristics of the order subject to that order;
  • characteristics of trading venues to which that order can be directed.

     The Company will place orders to the intermediaries of the money and capital market, so as it should not advantage one of the managed portfolios to the detriment of another.

     In the placement of trading orders, the Company shall act honestly, fairly and professionally in accordance with the best interests of their customers and in compliance with the principles of professional ethics established by the regulations in force and through the practices established in the field.

     In selecting the intermediaries to whom trading orders will be placed for execution, the Company will consider the following criteria:

  • Their authorization by the competent authorities;
  • Experience and good reputation in the field;
  • Ability to execute those orders in the best conditions of price and execution, in compliance with the best interests of customers;
  • Trading fees charged.

     In case the customers holding individual investment portfolios opt for using a specific agent's services, the Company will place trading orders for execution by means of such agent.

     The Company will send orders to agents according to financial instruments mentioned in the UCIs articles of incorporation or in the individual management contracts.

     The financial instruments will be traded through agents authorized by the FSA and by credit institutions authorized by the National Bank of Romania.

     The placing of orders is conducted within the Analysis and Investments Department. In the placement of trading orders, Analysis and Investments Department employees will follow the rules and procedures in force to act always in the best interest of customers. It is prohibited by them or by the Company of any advantage of using confidential information coming to their knowledge, especially where there might be a conflict of interest between the Company and its customers. To this end, the Company's employees involved in performing transactions will not communicate information of this except only to persons entitled to know by the nature of their job duties and in any case to those who are not employees of the Company, except at the request of the competent authorities.

     If there is a decision to buy / sell a financial instrument for more of the managed portfolios, the Company will try, if possible, to obtain the same conditions of execution for all portfolios. However, taken into account that orders can not place simultaneously for all portfolios managed, it can happen that the same financial instruments be bought / sold in different execution conditions for each managed portfolio. Such differences can also occur because the market of such instrument may be less liquid, or due to the fact that the terms of a certain transaction are also dependent on the size of such transaction value and managed portfolios can be different sizes.

     To this end, the Company will try to trade a certain instrument for all portfolios for which there is such a decision at as close moments as possible, when market conditions allow it.

     If there is a financial instrument decisions for certain portfolios managed sales and purchasing decisions for other managed portfolios, the Company will not enter into transactions between these portfolios, but will place these orders on the market independently, trying to obtain the most good price/execution conditions for each portfolio. However, it is possible that orders should intersect in the market, so that one of the portfolios should sell and the other one should buy.

     Transferable securities trading orders will be placed for execution to agreed agents, for the local and international market, or, for international markets that are not adequately covered by them, to similar authorized entities from abroad.

     Placing of orders shall be made in writing, by telephone (on a recorded line), by fax, e-mail or internet. After execution of orders, it shall be followed by the receipt, in due time, of transaction confirmation from those entities. They will be checked by the employees of the Analysis and Investments Department under orders placed, for compliance with the orders placed, approved and sent to the Back Office Department for their registration into the database.

     Trading orders will be collected until the end of each month for the previous month from all entities through which they were traded and will be archived.

     Operations with fund units of U.C.I. in Romania is done by filling in the adhesion / subscription / redemption forms used by such U.C.I.

     Trading orders include the following information which will allow the detailed restitution of the order:

a) name or identifier of the U.C.I. and of the person acting on behalf of U.C.I.;

b) details necessary to identify the instrument in question;

c) quantity;

d) order type;

e) price;

f) exact date and time of transmission of the order and the name or an identifier of the person to whom the order was sent;

g) name of the person sending the order;

h) applicable, the reasons for revocation of an order.

     The Company shall keep, for a period of at least 5 years, all records and entries relating to orders placed so that A.S.F. can supervise the compliance with the provisions of Law no. 297/2004 and the regulations adopted in implementation thereof and in particular, verification of compliance by the Company, of obligations to customers or potential customers.

     The company provides safekeeping of documents to enable A.S.F., in exceptional circumstances, to access information for a longer period of 5 years, depending on the nature of the instrument or transaction with financial instruments from the managed U.C.I. portfolio.

    Records and entries specifying the rights and obligations of the Company and the customer under an individual portfolio management contract will be kept at least for the duration of the relationship with such customer.

     Company records and entries must be kept in an accessible way to allow A.S.F. further verification, as well as in a form and manner in which to provide the compliance with the following conditions:

  • quick access and reconstruction of each element of the transaction;
  • performing any changes or other amendment, as well as the content of records and entries before such changes or amendments to be easily found;
  • handling or alteration of records and entries otherwise may not be possible.

     The Company will regularly monitor the efficiency of order placement and, in particular, the quality of executing orders made ​​by the approved agents and, if necessary, will correct any deficiency. Thus, this policy will be reviewed at least annually or whenever there is a significant change affecting the Company's ability to obtain the best results for its clients.

     The Company will not approve an order of a U.C.I.V.M. with any of the following orders:

  • an order of another U.C.I.V.M .;
  • an order of another customer, or;
  • an order of their own;
  • except when the following conditions are complied with:
  • approval of orders should not be in disadvantage any of U.C.I.V.M.s or customers whose orders will be approved;
  • the Company shall establish and implement an order allocation policy, stipulating accurate enough terms for a correct allocation of approved orders, including how the volume and price of orders will determine the allocation and treatment of partial execution.

The company provides the equity securities holders, through the publication on the Company's website, information on the policy of sending orders / execution of transactions and the significant changes thereof. Policy of sending orders / execution of transactions will be made ​​available to investors free of charge, on their request.

+4 0213 617 821
+4 0213 617 822