Order execution policy

The Order execution policy takes into consideration three client categories, namely, retail clients, professional clients, and clients, eligible counterparties.
The Order execution policy of the company regarding financial instruments focuses on the following:

The Order execution policy can be different, depending on the category the client belongs to. In case of retail clients the price and other costs can be decisive argument, as compared to professional clients, for which of higher importance may be the volume and nature of transaction, liquidity at the trading venue.

As an exception, from the provisions mentioned above, transactions based on clients’ clear and specific instructions are executed as such.

In the event that the client sends a specific instruction, Blue Rock Financial Services has the obligation to execute the order according to that instruction.

Client orders take precedence over the orders of the relevant persons and the orders on the company’s own account, provided that market conditions allow for their execution, under the same time and price conditions. Blue Rock Financial Services is responsible for the manner in which orders are executed in compliance with the regulations in force. A refusal to execute an order, along with its motivation, shall be communicated to the client forthwith.

Concerning a client’s limit order in respect of the shares admitted to trading on a regulated market and which may not be executed immediately under the existing current market conditions, Blue Rock Financial Services shall, unless otherwise expressly stated by the client, take all necessary measures in order to facilitate the execution of that order in the most expeditious manner possible, making public the limit order in a way that is easily accessible to the other market participants by using the regulated market system, the alternative trading system or any other supervised system and ensuring the publicity, accessibility and quick execution of the order.

If there is a conflict of interests, the company is obligated to clearly notify each client concerning the nature and source of the conflict of interests prior to the provision of financial investment services on its behalf. Client information shall comprise enough details, taking into consideration the type of client, in order to allow such client to make a decision with full knowledge of the case regarding the investment or related services in respect of which there is a conflict of interests.

In the case of client order execution, Blue Rock Financial Services has the following obligations:

Blue Rock Financial Services may execute a client order or a transaction on own account together with another client’s order, only if the following conditions are fulfilled:

Client orders may be totally executed by means of one or several transactions, or partially, depending on the concrete market conditions available at the respective time (demand and supply) as well as on the liquidity of the respective issuer. A client order may be executed at different prices, according to the type of the order. The company may suspend the acceptance of orders if the access to the trading system is suspended. The client may cancel or change an order, provided that the order was not executed until the time when the change was entered into the trading system.

In the relationship with the clients, the financial investment service agents that receive the trading orders shall introduce the clients to the facilities and terms of the orders and shall provide them with accurate information concerning the reference price of the current session, the current price, as well as the maximum and minimum prices admitted in the trading sessions.

If transactions are executed for clients whose cash and securities are deposited with a custodian bank, they shall observe the specific procedure provided by the Bucharest Stock Exchange Code concerning the carrying out of transactions by settlement though an agent/custodian bank. The general rule consists in the receipt of the order settlement confirmation upon receipt of the order and not the receipt of the transaction settlement confirmation after the transaction has been operated in the system, so as to avoid the risk of a failed or deferred settlement in the system. Furthermore, an order shall not be accepted for execution if by that order the company would exceed the limit imposed by the requirements of capital/own funds adequacy, in the event that settlement is refused by the agent/custodian bank and a special buy-in transaction would be appropriate or required.

The trading order comprises the information provided by the legal regulations in force. If the order does not comprise all of the information included in the order form, the agent may refuse to accept it. The transaction confirmation includes all the information provided by the legal regulations in force.
Blue Rock Financial Services shall notify its clients with respect to any order execution change or any amendment of its order execution policy.

In order to prevent the apparition of conflicts of interests and to respect the confidenciality of the information obtained while providing various services, S.S.I.F. Blue Rock Financial Services S.A. identifies the conflict of interest situations and manages them according to its own policy and internal procedures, so that its customer’s interests are not affected.
Nevertheless, situations where conflicts of interests might appear between the Intermediary, relevant persons and a customer or between two customers, situations where the conflicts of interests cannot be avoided or managed according to internal independent policy. In this case, the Intermediary does not have to provide financial investment services as a counter party of the customer, or in the name of the customer to which it is, directly or indirectly, in a conflict of interests, taking into consideration including the interest which derive from transactions within the group he belongs to, unless it previously disclosed to the customer the nature and depth of the interst, in either written form or via telephone and only in the situation the customer agreed to close a transaction under the conditions presented. Customer information and his agreement have to be recorded by the company, included on magnetic support, if the communication is performed telephonically.
Any additional information regarding .S.I.F. Blue Rock Financial Services S.A. conflict interest policy will be made available to customers, any time, at its request on a durable media.

S.S.I.F Blue Rock Financial Services S.A. holds a separate record of the activity performed on customer’s behalf and on his own. The funds and financial instruments held in the name of each client are separately recorded by the ones which are held by the company in its own name and separately by other customers.
Customers who have not updated their personal data through the documentation provided by SSIF Blue Rock Financial Services S.A. or they could not be contacted and had in custody S.S.I.F. Blue Rock Financial Services S.A. money funds and / or financial instruments are informed that the financial instruments have been transferred in section I of the Central Depository, and the money funds transferred to an “escrow” type account opened at the Romanian Commercial Bank. For any further information you can contact SSIF Blue Rock Financial Services S.A., the Central Depository or the Romanian Commercial Bank.

Investor’s Compensation Fund has as its exclusive main activity the collection of member’s contribution and compensation of the investor’s debts originating from the incapacity of a member to return the funds and/or financial instruments owned or belonging to investors, which are held and/or managed on their behalf while providing financial investment services, within the established thresholds.

The compensation is provided by the Fund for the customers of a credit institution, member of the Fund, only for cash funds and financial instruments entrusted on the base of a financial investment services agreement.

The Fund will compensate equally and without discrimination the investors within the limit of a maximum threshold representing the RON equivalent of 20.000EUR starting 1st of January 2012.

The RON equivalent of the compensation threshold is calculated to the NBR’s reference rate from the date when the situations mentioned at paragraph 47 from Law No. 297/2004 regarding capital market.

Information regarding Investors Compensation Fund you can find at: http://www.fond-fci.ro/en/

In accordance with FSA Regulation no. 4/2016 on the organisation and functioning of the Alternative Dispute Resolution Entity in the financial non-banking (SAL-FIN) and GO no. 38/2015 on alternative dispute resolution between consumers and traders, we inform our customers about their right to appeal to alternative dispute resolution.
Customers can address these cases to SAL-Fin – ADR entity in the financial non-banking institutions,whose contacts and additional information can be found at:  http://www.salfin.ro