Order Execution Policy

Under the Capital Market Act (Official Gazette 88/08, 146/08, 74/09, 54/13, 159/13, 18/15, 110/15, hereinafter: CMA) management of the investment company Credos Ltd. Zagreb, Nemčićeva 7 (hereinafter referred to as: „the Company“)

 

on 5/22/2017 brings

 

 

ORDER EXECUTION POLICY
  1. GENERAL PROVISIONS

Article 1.

 

Order Execution Policy (hereafter: “the Policy”) is a mechanism that ensures all reasonable steps to achieve the best possible result when executing clients' orders, taking into account the elements and criteria set out below.

The policy applies to the investment services of execution of orders and receipt and transfer of orders in the name and on behalf of clients with brokerage in the purchase and sale of financial instruments that the Company offers to clients, in accordance with the provisions of regulations, and internal documents of the Company.

The provisions of this Policy apply to small and professional investors or eligible counterparty.

The Company will comply with the provisions of this Policy and with regard to the task given by eligible counterparty, not committing the same time to achieve the best possible result.

The Company, the Management Board members, brokers and investment advisors employed by the Company shall, when providing investment services of receipt and transmission of orders and execution of orders always act conscientiously, with due professional care and comply with all applicable regulations and codes of practice.

 

Article 2.

The objective of this Policy is to establish:

  • criteria for determining the relative importance of various elements of the execution of the task relevant for determining the best possible result for the Client;
  • elements and criteria for determining the place of trade, which enables the Company to consistently achieve the best outcome when executing client orders;
  • type of transaction and the circumstances in which the Company may differ from the treatment provided for in this Policy to the Client to achieve a favourable outcome of the transaction;
  • measures and procedures regarding handling the client orders;
  • measures to monitor the effectiveness of the procedures and mechanisms for the execution of client orders at the least cost to the client.

 

The provisions of this policy do not replace the provisions of the Treaty nor the General Terms and Conditions, the provisions of other internal regulations and procedures of the Company, as well as the provisions of the legislation governing the area in question, but are described in detail and complementary.

 

Article 3.

The terms set out in this Policy shall have the meaning as follows:

 

Stock Exchange - Zagreb Stock Exchange d.d., Ivana Lučića 2a, Zagreb, or other regulated public market in the country and/or abroad

 

Financial Instruments - Transferable securities, money-market instruments, units in joint investments, derivatives.

 

Derivatives - instruments which are essential ingredients derived from securities, index currencies, interest rates or energy, and by which it establishes the right or obligation to buy or sell a particular security, currency, index, interest rate or energy, depending on whether the settlement is in cash or the object of purchase or sale.

 

Client or counterparty - Domestic or foreign legal or natural person, or any other regulated form without legal personality, with whom the Company directly or by the authorized representative, in accordance with applicable regulations, enters into all contracts and which authorizes the on behalf of the Client do specific trade with financial instruments.

 

The trading book - the Company's trading book which is kept in electronic form as the sum of the individual orders, and which is formed in a manner and kept in accordance with the Capital Market Law and other relevant regulations.

 

Execution place - regulated market, multilateral trading facility (MTF), a systematic internaliser, a market maker, or another entity in a third country performing similar activities or outside them (OTC market).

 

Multilateral trading platform - (hereinafter: MTF) multilateral system managed by an investment firm or a market operator, which brings together supply and demand for financial instruments of more interested third parties. Connecting supply and demand takes place according to defined rules and unambiguous results in a contract between the parties, in accordance with the provisions of the law.

 

Order - sided statement of the Client addressed to the Company, that the Company on behalf of the Client does specific trade with financial instruments.

 

A market maker - a person who has been continuously active in the market of financial instruments, willing to deal on its own account by buying and selling financial instruments, at prices that it determines, using its own capital.

 

Authorized Dealer - legal or natural person authorized, pursuant to law or a power of attorney by the Client, for an order for the purchase or sale of financial instruments and perform other transactions with financial instruments foreseen in the Treaties with the Company and the General Terms and Conditions, on behalf of the Client.

 

Transferable securities - shares, bonds or other forms of securitized debt, and any other securities giving the right to acquire or sell any such transferable securities.

 

Systematic internaliser - an investment firm which is on organized, frequent and systematic manner trading for their own account by executing client orders outside a regulated market or multilateral trading platform.

 

CDA - Central Depository Agency d.d., Zagreb, Heinzelova 62a.

 

Official website of the Society -www.credos.hr

 

Regulated market - multilateral system operated and/or managed by a market operator, and who: a) connects or you can connect the interests of third parties to buy and sell financial instruments in the system, in accordance with predetermined unambiguous rules and in a way that leads to the conclusion of the contract in connection with financial instruments which is admitted for trading by its rules and/or in the system and b) has received approval as a regulated market and regularly acts.

 

 

  1. RELEVANT ELEMENTS OF ORDERS AND CRITERIA FOR DETERMINING BEST EXECUTION

ESSENTIAL ELEMENTS OF ORDER

Article 4.

 

The Company will accept only those orders that contain information about the essential elements of the transaction that would be executed by accepting the order and which is in no doubt sent by the Client.

Essential elements of the order are:

 

(a) personal information identifying the client or his authorized representative, which are identical to personal information of the Contract;

 

(b) the nature of the task (purchase or sale), and the nature of the transaction by the Company to be done;

 

(c) information about the financial instrument which unambiguously determine the subject of the order (official or unique identifier of the financial instrument or the name of the financial instrument, i.e. the characteristics of the contract in the case of derivative);

 

(d) information on the amount of financial instruments that are the subject of the order (the number of units of financial instruments, the nominal value of bonds or the number of derivative contracts);

 

(e) the price of a financial instrument that is the subject of the order, expressed as a unit per one financial instrument or derivative contract excluding commission and (where relevant) calculated interest - for equities and derivatives fraction of currency of the denomination, for example in local market kuna and lipa, and for debt securities as a percentage of their nominal value (price for buying order is expressed as the maximum price the Client is willing to pay for the purchase of financial instruments, or on the order of the sale price is expressed as the minimum price that the Client is willing to accept for the sale of a financial instrument);

 

(f) mark of the price of a financial instrument as the currency in which the price is expressed, and if in the case of a bond or other form of securitized debt expressed as a percentage of price, price tag includes the percentage;

 

(g) the place of execution where the order will be executed;

 

(h) the expiry of the order;

 

(i) the signature of the Client (for the order sent in writing), or user password (for the order transmitted orally, if the user password is requested by the broker).

 

If the Company receives contradictory, vague, unclear or incomplete order, the Company has the right to request amendment to the order, or may delay any action on the received order or until the Company in contact with the Client does not resolve the ambiguity and may reject the received order, and all without any obligation for the Company. In these cases, when the Company refuses received the order, the Company will immediately inform the Client about it.

 

For any information which is not listed in the order, and which are not by specific regulations defined as mandatory elements of the order or for the information for which it is determined to valid information which that are valid on the market, the Company will be conducted with due professional care, and with the interests of the Client, where the Company does not guarantee that with execution of such a order will be achieved maximum protection of interest or benefit for the Client.

 

TYPES OF ORDERS

Article 5.

 

The order with limited price

 

The order with limited price is order to buy or sell a specific amount of financial instruments at the price specified in the order or at a price that is more favourable to the Client.

 

If the limit order of the Client for the purchase and sale of shares listed on a regulated market under prevailing market conditions cannot be executed immediately, the company is obliged to take measures to enable the fastest possible execution of such order, unless the Client has given  specific different instruction.

 

The measures of paragraph 2 of this Article shall include the publication of order, without delay, in a manner easily accessible to other market participants. The obligation of paragraph 2 of this article will be fulfilled with exposure to the Client's limited order to the trading system regulated market or multilateral trading platform.

 

The order with market price

The order is executed at the best possible price at the time of arrival of the order to the market.

 

Stop order

The order is triggered when the price of a financial instrument on the market reaches the stop price, and then automatically becomes the order to the market price. This means that in reality it can be made and at a price that is less favourable than the stop price.

 

Trailing stop order

Price to be filled in order is the current market price which is for informational purposes only. The real price is determined by trailing stop amount, which means the difference to the market price at the time of arrival of the order on the market (not the difference to the market price at the time of entry of the order that is listed in the order and is only informative).

 

Examples:

 

  1. Long trailing stop (to close long positions):the market price in the order $ 10, trailing stop amount of $ 0.50, the market price at the time of arrival of the order on the market $ 10.05. Once at the market, the order becomes order with stop-price at $ 9.55 ($ 10.05 - $ 0.50). If the price continues to rise, e.g. to $ 10.07, the stop-price rises to $ 9.57, and so on, until the market price rises. If the market price falls to $ 10, the stop price remains at $ 9.57 until the market price does not rise again. If the market price continues to drop, the order is activated when the market price reaches the stop price and then becomes order to the market price.

 

  1. Short trailing stop (to cover short positions):the market price in the order $ 10, trailing stop amount of $ 0.50, the market price at the time of arrival of the order on the market $ 9.95. When it arrives on the market, the order becomes an order with stop-priced at $ 10.45 ($ 9.95 + $ 0.50). If prices continue to fall, for example, at $ 9.90, the stop price is lowered to $ 10.40, and so on, until the market price falls. If the market price rises to $ 10, the stop price remains at $ 10.40 until the market price falls again. If the market price continues to rise, the order is activated when the market price reaches the stop price and then becomes order to the market price.

 

 

 

 

Related (grouped) Orders

 

The client has the option to open two accounts, and to instruct broker to give them by the same name of the group. The realization of one of the tasks automatically recall other orders.

 

Orders with special terms of execution

 

In certain markets, it is possible to specify the tasks of the specific requirements of execution, taking into account the technical and operational infrastructure of regulated market or MTF, the contracting parties, and the Company itself. Certain special conditions when issuing an order can be: order with hidden quantity, order in which certain minimum amount of financial instruments which is set to be sold or bought, stop orders, smart automatic orders, peg orders, orders which are only valid at the beginning of the trading day and so on. When placing orders with special terms of execution the Company will appreciate the same, if possible, and send such order to the information system of regulated market or MTF. Such orders behave according to the rules of the regulated market or MTF. Orders that can be set via the interface for trading via the Internet described in general terms that relate to the service. Special conditions at the given task are considered as an explicit order and the Company believes that with the presentation - the execution of such an order under the explicit instructions of the Client, fulfilled its obligation to achieve the best possible result.

 

HANDLING THE CLIENT ORDER

Article 6.

 

The Company provides timely and proper execution of Client orders according to the time of accepting the order.

In order to have timely and correct execution of client orders Company undertakes these measures and actions:

  • properly and promptly records the information on the receipt of the order;
  • accepts client orders in accordance with the contract documents, unless it considers that there are circumstances that constitute an order as unacceptable;
  • exhibits and executes client orders according to the time of acceptance of the order of the Company and without delay, unless the prevailing conditions in the market prevent it or different treatment requires explicit instructions of the Client;
  • transmits client orders according to the time of acceptance of the order of the Company and without delay, in accordance with the possibilities allowed by the technical and operational infrastructure of the Company and the third party;
  • duly and promptly records information on a place of execution or transfer the order to a third party;
  • properly and promptly records the information on the execution of orders on behalf of the Client;
  • correctly and promptly allocate order executed on Client's behalf;
  • takes all reasonable steps to ensure that all financial instruments or client's funds received in settlement of executed order are promptly and properly allocated to the appropriate Client's account;
  • informs the Client of the transaction;
  • immediately informs the Client about potential significant difficulties in connection with the properly execution of orders;
  • continuously monitors the eligibility and correctness of the order, through the entire process of the Company, in accordance with applicable regulations and market practices.

 

GIVING ORDERS

Article 7.

Orders can be sent to the Company in the following ways:

 

  1. Personally, in writing, in the Company's offices

 

  1. Oral (by phone)

 

  1. Fax

 

  1. E-mail, electronically

 

  1. Through the online trading system

 

Personal/written order Client may refer exclusively to the Company by visiting the business premises of the Company, by signing the form, or with a connected agent of the Company, where the Company operates also through a connected agent.

 

Telephone/oral order client can refer exclusively by telephone at the telephone numbers of the Company (in which the conversation is being recorded, and recording made serves as evidence of the fact of placing the order on its content, and as a verification/signature of orders by the Client), using the code for identification/ user password, which client will receive from the Company or determined himself, depending on the type of service and contractual relationship with the client, when signing the contract, and by that will, at the request of the broker, identify when making orders.

The customer can make an order via fax number indicated in the contract documents between the Client and the Company.

Client can give order electronically, directly by valid e-mail address indicated in the contract documents between the Client and the Company.

Anyone who gives order for the account of another (representation), must be able to prove his authority to make such a task.

When placing an order via the trading system client will use the username, password or confirmation number for the order, where the Company reserves the right to prescribe different or additional ways of authentication to be used to access the Internet trade and to ensure the safety of operations.

 

The client will at his own risk, based on his own business, legal and financial evaluation, experience and knowledge give orders in time and at a price which he determine himself.

 

 

RECEIPT, ACCEPTANCE AND TRANSFER ORDERS

Article 8.

 

Receipt of order by the Company does not constitute an acceptance of the order. The Company commits to confirm receipt of the Clients order no later than the next business day after receiving the order.

 

Acceptance by the Company is considered to be exclusively the entry in the Trading book and the Company commits to inform the Client that his order was accepted and enrolled in the Trading book.

The Company will by acceptance of orders, enrol the same order at the execution on the market or transfer to the execution to a third party, whereby the Client sets the order transaction with a financial instrument, as well as all requests for modification and revocation of orders, exclusively to the Company.

 

By accepting the order, the Company commits on behalf of the Client provide investment services or perform investment activity in connection with certain financial instruments, in accordance with the information stated in the order and any further instructions in accordance with paragraph (8) of this Article.

 

If the Company decides not to accept the received order, the Company is required to inform the Client immediately about the refusal of the order, after receiving the order, stating the reasons for the refusal.

 

The Company will not accept the order for which particularly, but not exclusively, determine or assess: (a) that does not contain the essential elements to perform the transaction; (B) that the Company could not fulfill the order or transfer order to the execution because of significant deviations from market conditions or for other reasons; (C) that the client did not allow the disposal of financial instruments or paid the amount of funds for the payment of the purchase price and costs related to the transmission and / or execution of orders; (D) that order could be sent for the purpose of unauthorized manipulation of prices of financial instruments or other unauthorized and illegal activities; (E) that the execution of the order of the Company suffered damage, or (f) the execution of the task would be a misdemeanor or a criminal act.

 

Likewise, the Company will not accept the order if it considers that the execution of the order or the transfer of the execution of the order in accordance with its information and definitions constitutes damage to the Client or that it requires further instructions, but the Company will warn the client and seek further instructions. The resulting additional instruction becomes an integral part of already receiving order and represents a new order which will be considered accepted by enrolling in the Trading book.

 

At the special request of the Client, Company shall promptly deliver to the Client printed order from the Trading book.

 

CHANGES OF THE ORDER

Article 9.

Any modification of the order, except of reducing the amount of a financial instrument, is considered the revocation of an existing order and creation of a new order, where the rules for the cancellation and placing orders are valid.

 

EXPIRATION OF THE ORDER

Article 10.

The order lasts until the date specified within the order or order may be daily or last until revocation.

 

The exception, for the orders of the domestic capital market stipulates that the maximum duration of the order in the exchange trade system is 365 days from the entry of orders in the trading system of the Exchange, independently if order is in this period changed and / or partially executed, in accordance with the applicable rules of the Exchange. After the expiry of 365 days the order is automatically deleted from the system of the Exchange and canceled in the Trading book of the Company.

 

The Company is not obliged to inform the customer on the expiry of the order.

 

REVOCATION OF THER ORDER

Article 11.

 

The client or the Company may revoke the order to the extent where he has not be executed, at anytime.

 

CANCELLATION OF ORDER FROM THE COMPANY

Article 12.

 

The Company may at any time, unless otherwise agreed,  cancel an unexecuted order even when it is already partially executed, with the obligation to state reasons of the cancellation, while not liable to the Client for damage caused by the unilateral cancellation of the order of the Company.

 

The Company may cancel unexecuted order for reasons which specifically include, but are not limited exclusively to the following circumstances:

 

  • the announced or started corporate actions because of which conditions of the order significantly differ or depart from the market conditions that will apply on the implementation of corporate action;
  • suspension of trading of certain financial instruments at the place of execution of the order;
  • decisions of the competent regulator;
  • unpaid claim from the Company towards the Client;
  • the Company's suspected manipulation or abuse of the market by the Client (in a way this term is defined in the Capital Market Act and the internal rules of the Company).

 

In addition to the grounds mentioned in paragraph (2) of this Article, the Company may at any time cancel the order and the reasons for which it, in accordance with the provisions of this policy may or may not be accepted, especially if it cannot get in touch with the Client.

 

About the order cancellation the Company commits to promptly notify the Client, primarily by telephone and in writing extremely (if the Company cannot seem to get in touch with the Client).

 

Cancellation of order shall be valid from the moment when such a dismissal is entered in the Trading book.

 

EXECUTION OF THE ORDER

Article 13.

 

The Company is obliged to fulfill the order with due professional care, while remaining within its borders and in all things to take care of the interests of the Client and being guided, while applying the appropriate measures and procedures to enable timely and proper execution of client orders in relation to the orders of other clients.

 

The Company will be guided in the execution of the order and the specific regulations governing the provision of investment and ancillary services and performance of investment activities, the rules of an institution whose services are used, as well as general rules and business practices that apply in the market or between its participants.

 

The Company offers the service of trading financial instruments abroad through foreign brokers authorized to conduct transactions with financial instruments.

The Client is aware and accepts that the trading in financial instruments abroad done through a third party, the foreign broker, authorized to conduct transactions with financial instruments and to trade foreign financial instruments executed in foreign currencies, depending on the market on which the order is executed.

 

In the choice of partner foreign investment firms/brokerages the Company takes care of the reputation and status of the same on the domestic market, with particular attention to the requirement that the relevant investment company / broker company provides its services, while respecting the relevant regulations of the country where it provides investment services.

 

The company will also in the selection of foreign investment firms/brokerages in particular take into account the fact that its services are provided in an efficient, fast and simple way, a cost-effective and that the Company and its clients at all times are ensured with quality and continuous support to the target foreign market.

 

Article 14.

 

If orders can be executed at different places from the place of execution of the order, the Company shall, unless it has received different instructions from the Client, select the place of execution of the order in accordance with paragraph III. of this Policy.

The Company may deviate from the accepted orders and instructions only with the consent of the Client, and when the same is not possible to ask because of the shortness of time, or any other cause, if only on the basis of assessment of all the circumstances may reasonably be considered to be so in the interest of the Client.

If the Company during the order execution subsequently determines that there are facts and circumstances which, if known, would have been reason for not accepting the order in the Company, the Company in accordance with the state of execution of the order may suspend the transaction and ask for new instructions, or cancel the order and on the same immediately inform the Client.

 

Article 15.

 

The Company will while executing the order take all reasonable steps to obtain the best execution of the order and while it will give special attention to the elements of the order:

 

- price,

 

- the costs execution speed and likelihood of execution,

 

- the costs, speed and likelihood of settlement,

 

- the size and type of order.

 

The Company determines the relative importance of the above elements, taking into account the following criteria:

 

- the categorization of the Client,

 

- characteristics of the order,

 

- characteristics of the financial instrument,

 

- the availability and performance of the potential places of trade to which the order can focus on execution.

 

When the Company executes the order of a small investor, achievement of the best possible result is determined primarily in relation to the total costs, speed and likelihood of execution of the transaction.

 

The total cost of the transaction includes the price of the financial instrument and all costs directly related to the execution, which includes reimbursement of trading, clearing and settlement fee of the transaction and any other fees paid to third parties involved in the execution of the order.

 

To further protect the interests of small investors, the Company may take into account the characteristics of the order and the likelihood of settlement in order to ensure the best possible result for the small investor.

When executing the order of professional Client, the Company may further take into account the speed and likelihood of execution and settlement, size and type of order, the impact of the market, the type of financial instruments, transparency as well as all other circumstances which the Company estimates that represents the best order execution in a particular case.

 

 

Article 16.

 

The Company does not guarantee that in any situation will be able to provide the best execution, but it will act in accordance with the provisions of this Policy, which it considers to guarantee the most favourable outcome for the Client in most cases.

 

Achieving the best possible result for the Client involves treatment of the Company with due professional care in accordance with the provisions of this Policy, all applicable regulations and internal acts of the Company.

 

If the Company receives from the Client an express instruction for the execution of the order, such order will be executed in accordance with relevant instruction, regardless of the elements and criteria regarding the best execution of the order, taking into account the technical and operational restrictions. In relevant case there is no obligation of the Company to act in accordance with this Policy in order to achieve the best possible result for the Client.

 

Order execution on regulated markets and MTFs which the Company is a direct member are, in the opinion of the Company, the best execution for the Client with regard to the total cost of the transaction.

 

When the Company from the Client receives explicit instructions for execution of the order, the Company will, if it is able, execute the order as instructed. The explicit instructions of the Client (for example, regarding the place of execution) may prevent the Company to take steps that are required by this Policy in order to achieve the best possible result when executing order of the Client.

 

It is believed that with the execution of such order under the explicit instructions of the Client the Company fulfilled its obligation to achieve the best possible result, although the outcome of the execution of such a task may not be the most favourable to the Client in the particular case.

 

III. THE PLACE OF ORDER EXECUTION

Article 17.

 

In general, the place of the execution of order for purchase/sale of financial instruments can be:

 

  • regulated market,

 

  • multilateral trading platform (MTP)

 

  • systematic internaliser,

 

  • a market maker,

 

  • the management of investment funds,

 

  • other liquidity provider or other entity in a third country which performs a function similar to the above.

 

In situations where the third entity or technical and operational infrastructure for the implementation of the order requires, the Company may require the customer to determine the place of the execution of the task. Determination of the place of execution will be considered as an explicit order and the Company considers that the execution of such order under the explicit instructions of the Client fulfilled its obligation to achieve the best possible result.

 

Article 18.

 

The Company provides following ways of transfering Clients orders to the market: smart and focused.

 

With a smart sending of orders, the market trading system determines itself on which market will send the order to the execution, until focused sending of the order involves sending the order to the selected spot trading (market) stated in the order.

 

No matter which method of sending is selected by the Client, it shall be considered as an explicit order and the Company considers that with the execution of such a task to the express instructions fulfills its obligation to achieve the best possible result.

 

Article 19.

 

The Company will while providing the services of execution and / or receipt and transmission of orders on behalf of the Client choose a place of execution that allows permanently achievement of best execution.

 

The Company will, in accordance with this Policy, execute Client orders exclusively on regulated markets or multilateral trading platforms. Exceptionally, at the request or with the express consent of the Client, the Company can fulfill the order outside of the regulated market or multilateral trading platform.

 

List of trade places to which the Company is a direct member, as well as a list of regulated markets or MTF to which the Company executes orders for the purchase or sale of financial instruments is an integral part of this Policy and is attached.

 

List of companies to which the Company transmits orders for the purchase and / or sale of financial instruments that are traded in markets in which the Company is not a direct member is an integral part of this Policy and is attached.

 

The Company reserves the right to update the above list and will be available in the business office of the Company and the Company's website (www.credos.hr).

 

Article 20.

 

When the Company receives from the Client order for the purchase / sale of a financial instrument that is listed in two or more places of execution, the Company will always, if it does not receive a different explicit instruction of the Client, execute order on the regulated market or MTFs where it is  a direct member. The Company considers, having taken into account and assessing all relevant circumstances, that it ensures the best execution of the order because of these factors:

 

- the most favourable total costs of the transaction,

 

- direct control over the speed of exposure of the order and and likelihood of executing the order,

 

- direct access to the speed and likelihood of settlement,

 

- other circumstances related to the execution of the task.

 

If the Company receives the order regarding financial instruments listed on two or more regulated markets or MTF where it is a direct member, the Company will execute the order on that market that provides the most favourable total cost of the transaction, taking into account the relevant circumstances regarding the type and size of the order.

 

Article 21.

 

Orders for the purchase and / or sale of a financial instrument that is subject of trade on a market in which the Company is not a direct member, the Company will receive and transmit them to third entities (authorized companies - partners) which have direct or indirect access to relevant market, acting in the best interests of the Client and in accordance with the rules of professional conduct. The execution of the order in relevant case will be carried out in accordance with the Order execution Policy of that third entity, which means that the client's order may be made in other places of execution or outside the regulated market or multilateral trading platform.

 

When choosing a third entity The Company will consider their approaches to execution of the order, establish does relevant subject allows activity in accordance with this Policy and will it monitor the quality of execution that it provides.

 

The Company does not guarantee that each client's order will be executed at the best price possible, inter alia, for the following reasons:

 

  • The Company has no access to every market where trading in a particular financial instrument;

 

  • Orders of other market participants may be executed before the clients and cause loss of supply or demand of financial instruments at the price specified in the order;

 

  • Third Party may forward the order out of the system for automatic execution "by hand" execution, which may cause a delay in the exposure of the order;

 

  • Malfunction of the trading system of a third entity can prevent the execution of the Client's order, cause a delay exposure of the client order or cause that the client's order will not be executed at the best price exposed.

 

For trade outside the multilateral system (s) of organized trading in financial instruments (regulated market or multilateral trading platform), so-called. OTC (Over The Counter) transactions via the website www.trades.com , the Company will receive and transmit orders to a the Third party. In relevant case, the Company will receive orders for the purchase and / or sale of a financial instrument and transfer them to the Third party, acting in the best interests of the Client and in accordance with the rules of the profession. The execution of orders will be carried out in accordance with the policy of order execution the Third party, which means that the order of the Client will be made in other places of execution or outside the regulated market or MTF.

 

In the case when orders for the purchase and / or sale of financial instruments the Company receives and transmits to the company Franklin Templeton International Services S.A. and the company Interactive Brokers LLC as a third party, order execution will be carried out in accordance with the order execution policy of those third parties.

 

Article 22.

 

When choosing a third party, the Company will follow primarily the following criteria:

 

  • compliance of a third party with the provisions of the MiFID directive, which includes the principle of best execution of orders;

 

  • the number of markets in which the third party has access (directly and/or indirectly) and the volume of trading in these markets;

 

  • dynamic model comparisons in real-time elements of best execution of the order, with a focus on (sorted by priority): the total transaction costs, likelihood of execution of the order, the speed of order execution;

 

  • financial strength, expertise, reputation and stability of the third party.

 

If  for execution of the order third entity should be engaged that is not obliged to adopt a policy of order execution and implement the principle of achieving the best possible result for the Client, the Company cannot guarantee that the Client will ensure the best execution of the order.

 

Article 23.

 

If the client place an order to the Company regarding financial instruments listed in only one place of execution, the Company will execute the order, or forward (directly or indirectly) to the place of execution, and it will be regarded as achieving the best possible result for the Client.

 

Article 24.

 

The Company will not charge its commission in a manner that would unduly discriminate against any one or more possible places of execution. The Company will give priority to the place of execution where the execution of the transaction further financially would charged Client.

 

In selecting the third parties the Company will not give priority to those subjects that allow the execution of transactions unjustified additional financial charged Client.

 

TRADING FOR PORTFOLIO CLIENTS

Article 25.

 

In order execution for the portfolio clients all provisions of this Policy apply equally.

 

Orders to buy and sell financial instruments of the portfolio Clients the Company can execute outside the organized market, in which case the Company will act honestly, fairly and in accordance with the rules of the profession, and to protect the interests of the Client.

 

When the Company sets the order for more portfolio clients with the same financial instrument, in cases where this is possible, orders will give in the form of joint order.

 

TRADING FOR JOINT ACCOUNT

Article 26.

 

The Company can execute more individual orders for the purchase or sale of financial instruments at the same time (trading for joint account) and under the same conditions which receives from clients in accordance with the relevant elements to achieve the best execution of the order and its proportional parts, required by this Policy, and if considers that such a way of trade would not harm the interests of any other client whose order joins.

 

In the case of trading for the joint account of the previous paragraph, and partial execution of the joint orders, the Company will make an allocation of orders of individual clients, according to the criteria as in Article 27 of the Policy, as set out in the joint order.

 

 

Article 27.

 

The Company in the case of trading financial instruments of portfolio clients can execute more individual orders for the purchase or sale of financial instruments at the same time (trading for joint account), with respect to the elements of best execution of orders required by this policy.

 

The Company allocates the purchase and sale orders of the portfolio clients accounts by the following criteria:

 

  • in the ideal percentage parts, and thereby use available funds / financial instruments portfolio of clients.

 

  • with randomized allocation of realized transactions of purchase or sale of financial instruments;

 

  • with chronological allocation according to the orders from the Trading book.

 

  1. NOTICE OF EXECUTED TRANSACTION

Article 28.

 

The Company will immediately give to the Client the information necessary to complete the transaction by Client's order.

 

The notice about transaction execution for the Client will be contained within the bill for the service provided.

 

The notification of the executed transaction, which is contained within the bill for the service provided to the Client, the Company shall deliver to the Client on a durable medium within the meaning of the Capital Market Law by post or electronically no later than the second business day after the execution of the order or after receiving confirmation of the execution of the order of a third party and for clients through trading system e-trade, notification of the transaction shall be submitted by the end of the working day. Where the order execution occurred while the client is in the office of the Company, the Company shall promptly deliver to the Client Account for the service an integral part of the notification of the Client about the transaction, which will confirm the client with his own signature on one copy which will the Company keep in its records.

 

Notification of the transaction which is an integral part of the bill for the service provided to the Client contains the following information: mark of the Company, the name of the Client, day and time of trading, the number / type of order, mark of place of trade, mark of trading instrument, mark of the purchase or sale, quantity, unit price , the total cost and the total amount of fees to be charged.

 

Customers, regardless of the method of trading, are available with electronically reporting or by post, which are referred to when signing the contract.

 

  1. INQUIRIES RELATED TO EXECUTION OF THE ORDER

Article 29.

 

The Company is obliged to request the Client to present information which shows that the order of the Client is executed in accordance with the Policy, or in accordance with specific instructions of the Client. Clients can send a written request to the Company at the following address:

 

 

 

Credos d.o.o.

Nemčićeva 7

10000 Zagreb

 

  1. OFFERING OF INFORMATION ON ORDER EXECUTION POLICY TO CLIENTS AND APPROVAL OF CLIENTS

Article 30.

 

Before providing new services to the Client, the Company shall submit the same to the signature of the contract documents, and this Policy make available. By signing the contract documents from the Client, it will be considered that the same is timely informed and agrees with executing policy, in terms of the execution of all transactions.

 

If the client wants to give consent to the policy for each transaction separately or explicit approval for each transaction required, such consent shall be submitted in writing to the Company in a timely manner, or before executing of the order.

 

VII. REVISION AND UPDATING OF THE POLICY

Article 31.

 

The Company will continuously monitor the effectiveness of this policy, particularly in relation to the quality of execution of the order, and will at least once a year assess if they ensure the envisaged measures and procedures for achieving the best possible result for the client and, if necessary, revise this Policy. The purpose of the audit and monitoring the effectiveness of policies is to determine and correct its possible shortcomings.

 

Article 32.

 

Any changes to this Policy the Company will notify the Client in a way that makes available last issued executing policy on the Company's website, at the Company's premises and the premises of the connected agent that acts on behalf of the Company, if the same Company have cooperation.

 

Any amendment or supplement to this Policy shall apply from the entry into force of the same and the Company considers that all amendments and additions are adopted by the Client with the first following making of the order after the adoption of new policy, unless the client fails to notify the Company otherwise.

 

VIII. FINAL PROVISIONS

Article 33.

 

This Policy shall enter into force upon its adoption.

 

Credos d.o.o., Zagreb

 

 

 

 

 

 

 

 

 

 

 

Annex I. List of the execution places of financial instruments that the Company Credos Ltd., Nemčićeva 7, Zagreb, use to execute and/or transfer clients' orders:

 

Country of the place of executionMIC (Market and exchange identification code)The place of the executionACR (Acronym)Type of place of the executionWay of execution
FranceXPARNYSE Euronext – Euronext ParisSBFRegulated marketIndirectly / Third party
CroatiaXZAGZagreb stock exchangeZSERegulated marketDirectly
CroatiaXZAMZagreb stock exchangeZSEMTPDirectly
Croatia Investicijsko društvo – Credos d.o.o.CRDSOver-The-Counter (OTC) marketApplication for Broker of the Central Depository and Clearing Company Ltd
ItalyMTAAElectronic share market (Mercato Telematico Azionario)

MTA

(BVME)

Regulated marketIndirectly / Third party
NetherlandsXAMSNYSE Euronext – Euronext AmsterdamAEBRegulated marketIndirectly / Third party
GermanyXFRADeutsche Boerse AG (Frankfurt Wertpapierboerse)*FWBRegulated marketIndirectly / Third party
GermanyXETAXetra – Regulierter marktXetra (IBIS)Regulated marketIndirectly/ Third party
GermanySTUABoerse StuttgartSWBRegulated marketIndirectly/ Third party
United StatesXNYSNew York Stock Exchange, Inc.NYSE

Markets outside the EU

 

Indirectly/ Third party
United StatesARCXARCA Exchange (electronic stock market)

ARCA

(ECNs)

Markets outside the EUIndirectly/ Third party
United StatesXASEAmerican Stock Exchange (NYSE Amex Equities)AMEXMarkets outside the EUIndirectly / Third party
United StatesXNCMNational Association of Securities Dealers Automated Quotation (NASDAQ Capital Market)NASDAQMarkets outside the EUIndirectly / Third party
United StatesXISEInternational Securities Exchange, LLC - equitiesISEMarkets outside the EUIndirectly / Third party
United States Automated traded deskATD

Markets outside the EU

 

Indirectly / Third party
United States 

I Deal

(Interactive broker day trading)

IDEALMarkets outside the EUIndirectly / Third party
United StatesBATSBATS Exchange, Inc.BATSMarkets outside the EU

Indirectly / Third party

 

United StatesXCIS

National stock exchange

(Chicago)

NSXMarkets outside the EUIndirectly / Third party
United StatesCBSXCBOE Stock ExchangeCBSXMarkets outside the EUIndirectly / Third party
United StatesXCHIChicago Stock Exchange, Inc. Markets outside the EUIndirectly / Third party
United StatesXOTCOver-the-counter Bulletin Board (OTC BB)

ARCA Edge

(EDGEA)

Markets outside the EUIndirectly / Third party
United StatesPINXPink Sheet

ARCA Edge

(EDGEA)

Markets outside the EUIndirectly / Third party
SwedenXSTOOMX Nordic exchange Stockholm ASSFBRegulated marketIndirectly / Third party
SwedenXSWXSwiss ExchangeSWXMarkets outside the EUIndirectly / Third party
SwitzerlandXVTX

SWX Europe

Virt-X (Virtual Exchange)

VIRTXMarkets outside the EUIndirectly / Third party
Great BritainXLONLondon Stock ExchangeLSERegulated marketIndirectly / Third party

 

With respect to foreign financial instruments, there are many potential places of execution of orders, which are not mentioned here, which may be selected in accordance with the provisions of executing policy.

 

 

Annex II. List of third entities or third parties to which the Company Credos Ltd., Nemčićeva 7, Zagreb transmits orders for the purchase and/or sale of financial instruments that are traded in markets in which the Company is not a direct member:

 

  • Interactive Brokers LLC, Two Pickwick Plaza, Greenwich, Connecticut 06830, US, interactivebrokers.com
  • AK Jensen Limited, 148 Leadengall Street, London EC3V4QT, UK, akj.com
  • Franklin Templeton International Services S.A.(The management company of investment funds), 26 boulevard Royal, L-2449 Luxembourg, franklintempleton.lu
  • Leverate Financial Services Ltd, 88 Ayias Fylaxeos Street, Zavos City Center, 4th Floor, 3311 Limassol, Cipar, leverate.com
  • Leads Capital Inc. (Vanuatu), Govant Building BP 1276, Port Vila, Vanuatu

 

Annex III. List of custodian / third parties with whom the company Credos Ltd., Nemčićeva 7, Zagreb holds assets of the Clients:

 

  • Splitska banka d.d., Domovinskog rata 61, Split, Hrvatska, splitskabanka.hr
  • Franklin Templeton International Services S.A.(The management company of investment funds), 26 boulevard Royal, L-2449 Luxembourg, franklintempleton.lu
  • Leverate Financial Services Ltd, 88 Ayias Fylaxeos Street, Zavos City Center, 4th Floor, 3311 Limassol, Cipar, leverate.com