Policy for the Aggregation and Split of Clients’ Orders

 

The following policy for the aggregation and split of clients’ orders has been prepared in accordance with the requirements set by the Markets in Financial Instruments Act and Ordinance № 38 of 25 July, 2007 on the requirements to the activities of Investment intermediaries.

 

Art. 1. With the intent of achieving the best possible execution of clients’ orders, “Deltastock” AD (“the intermediary”) conducts the aggregation of orders, with the clients’ best interest in every occasion. 

Art. 2.  (1)  The intermediary aggregates clients’ orders with other clients’ orders or deals at his own expense only under the following circumstances:

 

1.                         The order aggregation does not cause damage to any of the clients whose orders have been unified;

2.                         Every client whose order has been aggregated with another, will receive an explanation, stating whether the aggregation might not be advantageous for him/her in this particular case;

3.                         The orders being aggregated are of the same kind (buy, sell, exchange, ect.);

4.                         The order aggregation does not cause damage to any of the clients, whose orders have been aggregated;

5.                         Every client whose order is aggregated will receive an explanation, stating whether the aggregation might not be advantageous for him/her in this particular case;

6.                         The orders being aggregated are of the same kind (buy, sell, exchange, ect.);

7.                         Only limit orders are aggregated;

8.                         Limit orders are aggregated only when the specified price in all of them is the same.

 

(2) The terms under Art. 1 Clause 2, do not apply to transactions, made by individual portfolio managers.

Art. 3.  (1) In the cases where the Intermediary aggregates a client's order with one or more other clients’ orders, thereby partially executing the aggregated orders, the split is conducted whereby the Intermediary fulfils wholly or partially the clients’ orders, using as a priority the time of order placement.

                        (2) A split different from that of Art. 1 is possible only with the explicit consent of all of the clients’, whose orders have been aggregated.

Art. 4. In the cases, when the Intermediary aggregates orders made by individual portfolio managers, thereby partially aggregating the orders, the split is made proportionately among the clients.

Art. 5. (1) When aggregating a clients’ order with a transaction at his own expense, the split is always conducted so as not to cause damage to the client.

                        (2) In the cases, when the Intermediary aggregates clients’ orders with a deal at his own expense thereby partially aggregating the orders, priorities receive the deals at the expense of the client.

                        (3) Proportional split between himself and the client is only allowed if the Intermediary can validly prove, that without the aggregation of the clients’ orders the deal would not be possible at such advantageous conditions, or might be impossible to execute at all.

Art. 6. Additional split of deals at own expense is not allowed, in the cases where it would be damaging to the client.