 |
| About us |
|
Who We Are
Interfin Trade (Overseas) Ltd. is a part of the financial group ‘Interfin Trade Group’ providing a diverse range of financial and investment products and services to individuals and corporate customers.
Interfin Trade (Overseas) Ltd. provides access to the Russian stock exchanges via NetInvestor Internet-trading system.
Our Licenses
Interfin Trade (Overseas) Ltd. is a Cypriot Investment Firm, with authorisation of the Cyprus Securities And Exchange Commission No 043/04 for provision of the following investment services and activities:
- Reception and transmission of orders in relation to one or more financial instruments:
- Transferable securities.
- Money-market instruments.
- Units in collective investment undertakings.
- Options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields, or other derivatives instruments, financial indices or financial measures which may be settled physically or in cash.
Ancillary services:
2. Foreign exchange services (related to the provision of investment services).
Summary of Order Execution Policy
Introduction
Following the implementation of the Markets in Financial Instruments Directive (MiFID) in the European Union and in accordance with the Investment Services and Activities and Regulated Markets Law of 2007 (Law 144(I)/2007) in Cyprus, the Company is required to establish an Order Execution Policy (hereinafter the “Policy”) and to take all reasonable steps to obtain the best possible result (or “best execution”) on behalf of its Clients when receiving and transmitting orders for execution. The Company is required to provide appropriate information to its Clients on its Policy.
Scope
The Policy applies to Retail and Professional Clients.
The Policy applies where the Company receives and transmits Client orders with respect to the following financial instruments:
- Transferable securities
- Money market instruments
- Units in collecting investment undertakings (“UCITS”)
- Options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields, or other derivatives instruments, financial indices or financial measures which may be settled physically or in cash
Best Execution
The Company takes into account the following criteria, when carrying out Clients’ orders:
(a) the characteristics of the Client including the categorization of the Client as Retail or Professional
(b) the characteristics of the Client order
(c) the characteristics of financial instruments that are the subject of the order
(d) the characteristics of the execution venues to which the order can be directed
The Company takes all reasonable steps to obtain the best possible result for a Client taking into account price, costs, speed, likelihood of execution and settlement, size nature or any other consideration relevant to the carrying out of the order. Nevertheless, whenever there is a specific instruction from the Client the Company carries out the order following the specific instruction.
Where the Company carries out an order on behalf of a Retail Client, the best possible result is determined in terms of the total consideration, representing the price of the financial instrument and the costs related to carrying out the order, which include all expenses incurred by the Client which are directly related to the carrying out of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the carrying out of the order.
Execution Venues
Execution venues are the entities with which the orders are placed or to which the Company transmits orders for execution.
For the purposes of delivering best execution where there is more than one competing venue to carry out an order for a financial instrument, in order to assess and compare the results for the Client that would be achieved by carrying out the order on each of the execution venues listed in the Company's carrying out/execution order policy that is capable of carrying out that order, the Company's own commissions and costs for carrying out the order on each of the eligible execution venues are taken into account in that assessment.
Finally, as a safeguard for best execution, the Company does not structure or charge their commissions in such a way as to discriminate unfairly between execution venues.
Reception and Transmission of Orders
The Company obtains the best possible result for its Clients, in respect of each class of instruments. Especially, in respect of the entities to which, the Company transmits orders for execution. The entities identified have the necessary execution arrangements that enable the Company to comply with its obligations when it places or transmits orders to that entity for execution. The policy of the Company includes the provision of the appropriate information to its Clients.
Monitor and Review
The Company monitors on a regular basis the effectiveness of the Policy and, in particular, the execution quality of the entities identified in the Policy and, where appropriate, corrects any deficiencies. In addition, the Company reviews the Policy annually. Such a review is also carried out whenever a material change occurs that affects the ability of the Company to continue to obtain the best possible result for their Clients.
Consent
The Company is required to obtain the Client’s prior consent to its order execution policy. The client will be deemed to have provided such consent when giving an Order after 1 November 2007.
Summary of Conflicts of Interest Policy
Introduction
Following the implementation of the Markets in Financial Instruments Directive (MiFID) in the European Union and in accordance with the Investment Services and Activities and Regulated Markets Law of 2007 (Law 144(I)/2007) in Cyprus, the Company is required to establish a Conflicts of Interest Policy (hereinafter the “Policy”) and take all reasonable steps to identify and prevent conflicts of interest situations between the Company, the Company and its Clients or between its Clients during the course of the provision of investment and ancillary services.
General Principles
The Company’s conflicts of interest policy, in general is to:
(a) identify with reference to the investment and ancillary services carried out by the Company, the circumstances which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Clients
(b) specify procedures to be followed and measures to be adopted in order to manage such conflicts
The Company ensures that the procedures and measures taken are designed to ensure that the relevant persons engaged in different business activities involving a conflict of interest, carry on those activities at a level of independence appropriate to the size and activities of the Company and to the materiality of the risk of damage to the interests of Clients.
The procedures that are followed and the measures adopted are the necessary and appropriate for the Company to ensure:
(a) effective procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more Clients
(b) the separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, Clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company
(c) the removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities
(d) measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out the provision of investment and ancillary services
(e) measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate activities where such involvement may impair the proper management of conflicts of interest
Disclosure
Before the Company provides any services, the Company discloses to the Client or potential Client the general nature and any conflicts of interest potentially present (including in terms of business). This is made in a durable medium and includes sufficient detail, taking into account the nature of the Client, to enable the Client to take an informed decision with respect to the investment or ancillary service in the context of which the conflict of interest arises. |
