Information on Intermonte Holding SIM's Execution Policy
We have put in place arrangements to enable us to deliver Best Execution, including an Execution Policy, information about which is set out below. The execution strategy relates exclusively to operations in derivative financial instruments connected to emissions trading, the only type of financial instrument traded by the company.
The scope of Best Execution
The Execution Policy applies to clients of Intermonte Holding SIM that give the company an order to execute on their behalf in respect of financial instruments covered by MiFID.
The Best Execution obligation
When we execute an order on your behalf, we will, subject to any specific instructions that you give us, take all reasonable steps to obtain the best possible result for you in accordance with MiFID and our Execution Policy, taking into account the factors identified below. If you give us specific instructions as to how you wish your order to be executed that we accept, we will follow those instructions. This may prevent us from taking the steps that we have designed and implemented to obtain the best possible result for the execution of your orders.
When Intermonte acts as a dealer Best Execution does not apply
When we quote or negotiate with you the terms of a transaction in which we are willing to deal with you as principal, we will not be executing an order on your behalf and therefore Best Execution will not apply, unless you request otherwise and we agree to such request.
OTC products are typically transacted on a principal basis and do not involve a firm executing orders on behalf of a client.
In accordance with market practice, Intermonte acts as a dealer on the wholesale OTC derivates and Bonds markets by dealing on its own account each time it enters an OTC transaction with a client.
Practically, this means that for all such transactions on OTC products, Intermonte Holding SIM will act as direct counterparty of the client.
In the wholesale markets, the client may obtain prices from different dealers. Consequently, the client does not rely on Intermonte Holding SIM to obtain the best possible result on its intended transaction and Execution is not owed by Intermonte Holding SIM.
Where a client asks to quote for an instrument and size, Intermonte Holding SIM will communicate to the client a price for the requested instrument and size taking into account various criteria including one or more of the following:
The client is free either to accept or reject the quote given.
We include in our Execution Policy details of the various sources of liquidity which we access for each of the financial instruments covered by MiFID in respect of which we execute orders on behalf of clients. These sources of liquidity consist primarily of regulated markets. We may only execute orders on an execution venue which is not a regulated market under MiFID 1) when the regulated market is not a sufficient source of liquidity in respect of the specific financial instrument and 2) when we act on our own account under particular circumstances described above.
Where you give Intermonte Holding SIM an order in respect of a share whose primary source of liquidity is on an exchange on which Intermonte Holding SIM is not a member, we will transmit your order to another broker or dealer for execution. In this case we will either determine the ultimate execution venue ourselves on the basis described above, and instruct the other broker or dealer accordingly, or we will satisfy ourselves that the other broker or dealer has arrangements in place to enable us to comply with our Best Execution obligations to you.
Type of access
ICE Futures Europe
Through BNP CFL
European Energy Exchange
Subject to any specific instructions that we accept from you, when we have indicated more than a trading venue for the financial instrument object of your order, we take into account a range of factors in deciding where to execute your order between the trading venues. These include price, costs, speed, likelihood of execution and settlement, together with any other consideration relevant to the execution of the order. In determining the relative importance of these factors we will take into account your status as a professional client, together with the nature of your order, the characteristics of the financial instruments to which the order relates and the characteristics of the execution venues to which the order can be directed.
We will generally give the highest priority to total consideration, representing the price of the relevant financial instruments and the costs related to execution. However, we may at our discretion prioritise other factors, including the impact on market prices of displaying and executing your order, the speed and likelihood of execution and the availability of price improvement. We may prioritise such other factors where there is insufficient immediately available liquidity on the relevant execution venue(s) to execute your order in full, where you instruct us to work your order over a period of time or by reference to a benchmark calculated over a period of time or where we determine that there are other circumstances such that obtaining the best immediately available price may not be the best possible result for you.
In determining what is the best possible result for you, we do not compare the results that can be achieved for you on the basis of our Execution Policy and fees with results that might be achieved for you by another investment firm on the basis of that firm's execution policy or a different structure of commission or fees, nor do we compare the differences in our own commissions or fees which are attributable to the nature of the services that we provide to you.
Monitoring and review
We monitor the effectiveness of our order execution arrangements and Execution Policy on an ongoing basis to identify and implement any appropriate enhancements. In addition, we regularly review whether the execution venues included in the Execution Policy and the brokers and dealers to whom we transmit orders for execution provide for the best possible result for our clients on a consistent basis and whether we need to make changes to our execution arrangements.
We will notify you of any material changes to the above description of our order execution arrangements and Execution Policy.
Intermonte Holding SIM S.p.A. - Corso Vittorio Emanuele 13, 20122 Milano, Italia – Tel. +39 02 77115.1 – Fax +39 02 77115.300
Capitale Sottoscritto e Versato € 3.290.500 Part. IVA, Cod Fiscale e Isc. Registro Imprese n. 06108080968 - Cod. LEI: 8156007125B2DED00348