This document sets out the Policy and approach to providing best execution. GRUENE CAPITAL LIMITED (‘GRUENE” ‘OR the Company) is expected to take all reasonable steps to obtain the best possible result for its clients, taking into account price, costs, speed, likelihood of execution and settlement, size, nature and/or any other relevant order execution consideration, whether we are executing orders on behalf of clients .
This Policy establishes the principles and guideline for standards which Gruene Capital will adopt when managing client orders, executing trades, or arranging for an approved third party to do so on the Firm’s behalf. In particular, this Policy sets out the key aspects applicable to the execution process, namely:
It applies only to all clients (Retail clients and Professional/Wholesale clients/Corporate) of Gruene Capital, dealings in Financial Instruments available in Nigerian Capital Market. Best Execution is only owed when Gruene Capital accepts an order to execute a transaction on clients’ behalf or in other circumstances where it has otherwise expressly agreed to accept such Best Execution obligation.
The Rules and Regulations of The Exchange and its implementations places obligations on Gruene Capital amongst other things to protect the interests of our clients, when providing stockbrokerage services and the service of portfolio management and to comply with the obligation to act in accordance with the best interests of our clients when executing placed orders . This policy sets out the approach and procedure to comply with the obligation. The policy is being used as guidance on how to achieve Best Execution and sets out our policy on order handling, and aggregation and execution.
Subject to any specific instructions that the clients may give, we will take all reasonable steps to obtain the best possible result when executing orders, taking into account the factors affecting execution stated below. We will determine the relative importance of each of these factors by using our commercial judgement and experience in light of market information available. The factors we take in consideration when executing orders are as follows:
When preparing to execute transactions, we are required to identify in this policy the venue where these transactions will be executed according to each class of financial instrument. The venues that enable us to obtain best execution on a consistent basis are as follows:
| Asset Class | Venue |
|---|---|
| Equity |
|
Where client gives us a specific instruction as to the execution of an order, for example, asking us to deal at a specific price, we will execute it in accordance with that instruction. Where the instruction relates to only part of the order, we will apply our order execution policy to the parts of the order not covered by the specific instructions. Providing specific instructions may prevent us from taking the steps set out in our order execution policy to obtain the best possible result for those elements covered by those instructions.
Best Execution obligations do not apply in the following situations:
Gruene Capital is required to ensure that client orders are executed in a prompt, fair and expeditious manner for the type of order in question. We satisfy this requirement by policies and procedures that ensure:
We will review our order execution policy annually or whenever a material change occurs that affects our ability to obtain the best possible result for the execution of orders consistently. We will also monitor the effectiveness of our order execution policy regularly to identify and, where appropriate, correct any deficiencies. Where we are arranging transactions in client orders we are required to monitor the execution quality of the execution broker's representatives we have chosen to pass orders on to as well as monitor the approach to execution that each broker's representatives takes. It is not necessary, or practical, for monitoring to cover every transaction, but rather to be based on sampling. For trades where there are high levels of liquidity and much trade data is available, a relatively small sample of transactions might be sufficient for monitoring. On the other hand, trades in less liquid stocks will need more detailed monitoring and hence larger samples.
Where clear cases of poor execution are identified, we will investigate promptly and take appropriate remedial action where necessary, which include requiring the executing broker representative to amend the transaction price if appropriate.