FIRST
INTEGRATED CAPITAL MANAGEMENT LIMITED
(Member of Nigerian Stock Exchange)
ORDER
HANDING & BEST EXECUTION POLICY
BEST EXECUTION refers
to the duty of First Integrated Capital Management Limited in executing orders
on behalf of customers to ensure the best execution possible for their
customers' orders.
Some of the factors considered of our customers'
orders include:
·
The opportunity
to get a better price than what Is currently quoted,
·
The likelihood
and speed of execution.
OBJECTIVES
Ø This policy provides an
overview of how our firm executes orders on behalf of clients, the factors that
can affect the timing of execution and the way in which market volatility plays
a part in handling orders when buying or selling a financial instrument.
Ø This policy applies to First
Integrated Capital Management Limited execution of orders on behalf of retail
clients and professional clients as defined by the Rules.
Ø Where our firm provides a
quote to a client or negotiates the terms of an Over-the-Counter
("OTC") transaction with our firm as counterparty, our firm will
normally not be acting on the client's behalf. In these situations, our firm
will not owe a duty of best execution under the Rules, and this policy will
therefore not apply. This policy does not create any obligation on our firm
that it does not have under the Rules.
Ø Upon acceptance of a client
order and when there is no specific client instruction regarding the execution
method, our firm will execute an order in accordance with this policy.
FINANCIAL INSTRUMENTS TO WHICH THIS POLICY APPLIES
This policy applies to financial instruments and
products as defined by the Rules, including Stocks.
FIRST INTEGRATED CAPITAL MANAGEMENT LIMITED APPROACH TO BEST EXECUTION
Ø When executing orders our
firm will take all reasonable steps to obtain the best possible result under
the circumstances for the client taking into account price, costs, speed,
likelihood of execution and settlement, size, nature or any other consideration
relevant to the execution of the order ("Best Execution").
When
considering the best executing factors, our firm takes into account:
·
the characteristics of the client order;
·
the characteristics of the financial instruments that are subject to
that order (in particular in relation to OTC financial instruments); and
·
the characteristics of the execution venues to which
that order can be directed.
Ø We execute orders on behalf
of retail clients, Best Execution are determined on the basis of the total
consideration paid by the client, unless the objective of execution of the
order dictates otherwise.
Ø Whenever there is a
specific instruction from or on behalf of a client, our firm will- to the
extent possible - execute the order in accordance with the specific
instruction. A specific instruction from a client may prevent our firm from
taking the steps that it has described in this policy to obtain the best
possible result for the execution of orders. Trading rules for specific markets
may prevent us from following certain of the client's instructions. To the
extent that a client instruction is not complete, our firm will determine any
non-specified components of the execution in accordance with this policy.
ELEMENTS OF BEST EXECUTION
The procedure for routing
determinations is mainly based on four criteria and is regularly reviewed by
our firm. Hence to determine the best way to execute an order for a client in
our firm takes into consideration:
Ø Speed and Likelihood of the
Execution: Due
to the levels of volatility affecting both price and volume, our firm seeks to
provide client orders with the fastest execution reasonably possible although
delays may occur.
Ø Price Improvement and
Overall Consideration of Costs: Orders are routed to NSE XGen
where opportunities for price improvement exist. The criteria to be used by
market centers include:
·
automatically matching incoming market and limit orders to pending limit
orders;
·
crossing transactions where price improvement can be
offered to one or both sides of the trade.
Ø Size Improvement: In routing orders, we seek
markets that provide the greatest liquidity and thus potential for execution of
large orders. We also seek opportunities for client orders to benefit from
order-size commitments offered by third parties.
Ø Overall Execution Quality: When determining how and
where to route or execute an order, Investment services firm’s traders draw on
extensive day-to-day experience with various markets and market makers,
focusing on prompt and reliable execution.
EXECUTION OF CLIENT ORDERS
Ø For instruments admitted to
trading and official listing on a regulated market or stock ex-change (i.e.
Bonds, Stocks, Options and ETFs), our firm routes orders to the exchange.
Ø For OTC products NASD
Platform, our firm will trade (as principal) against its own proprietary desk.
Ø The client’s orders may at
the discretion of our firm be aggregated with our orders, orders of any of our firm’s
associates and/or other clients. Furthermore, we may split the client’s orders
as well as aggregate orders before executing such. Orders will only be
aggregated or split where our firm reasonably believes it to be unlikely that
the aggregation or split generally will be detrimental to any client.
Aggregation and split may in single occasions result in the client obtaining a
less favorable price than if the client’s orders had been executed separately
or together, as applicable. Aggregated orders placed by an Introducing Broker
are allocated to clients in accordance with a predetermined allocation key. We settle
any partially filled orders pro rata at an average price.
EFFECTS ON ORDER EXECUTION
Clients should be aware of
the following risks associated with volatile markets, especially at or near the
open or close of the standard trading session:
·
Execution at a substantially different price from the quoted bid or
offer or the last re-ported sale price at the time of order entry, as well as
partial executions or execution of large orders in several transactions at
different prices.
·
Opening prices that may differ substantially from the previous day’s
close.
·
Locked (the bid equals the offer) and crossed (the bid is higher than
the offer) markets, which prevent the execution of client trades.
EXECUTION VENUES CURRENTLY USED
First Integrated Capital
Management Limited Firm is a member of The Nigerian Stock Exchange (NSE). All
order are executed through the NSE trading terminal
XNET and FIX OMS.
TYPES OF ORDERS
·
Market Order
·
Limit Order
·
Stop Order
REGULAR REVIEW OF EXECUTION QUALITY AND OF EXECUTION VENUES
Our firm will review this
policy annually and whenever a material change occurs that affects our ability
to obtain the best possible result for the execution of client orders.
Our firm regularly reviews the overall quality of its
order executions and its order routing practices, including its order routing
vendors and the available exchanges. We will amend this policy on the basis of
such reviews if it considers it to be necessary. Any new policy will be made
available on our and will be in force as from publication.
BUSINESS
TERMS
This policy is subject to our General Business Terms
and other business terms from time to time governing the relationship between us
and our clients.