1. TERMS AND CONDITIONS
The information, analyses, data and prices published on this website are purely indicative and not contractual, and may be changed without notice. They do not comprise an offer to buy or to sell, nor financial advice or any sort of commitment on the part of Edmond de Rothschild (France).
The figures mentioned deal with past years. Past performance is not a reliable indicator of future performance.
Edmond de Rothschild (France) shall not be held liable for the contents, utilisation, or for the direct or indirect consequences of any utilisation of information and analysis disseminated on this website, which is regularly updated, and has been collected or compiled from sources that Edmond de Rothschild (France) believes to be reliable.
This website is principally intended for natural and legal persons under French law. Access to the products and services referred to in this website, which are subject to French law, may be subject to legal restrictions or prohibitions in certain countries. It is the responsibility of each and every person accessing these products or services to establish beforehand, with the advice of their own legal and tax advisors, that their status entitles them to subscribe to the products and services accessible through this website. In particular, the products and services mentioned on this website are not intended for investors in the United States of America, who may not carry out any transaction in the products concerned other than through a certified United States broker.
Similarly, the products, services and information mentioned on this website are not intended for persons deemed to be private customers as defined by current regulations in the United Kingdom (Securities and Futures Authority). Consultation of this website does not exempt potential investors from the need to consult their own financial, legal and tax advisors, and to form their own opinion as to the suitability of the products mentioned on the website to achieving their own investment strategies and performance objectives. This is particularly important in the case of derivative products, which are high-risk investments. We recommend consulting the detailed description of the product, such as the full prospectus, before carrying out any transaction relating to it. The holder of a personal access code, required for certain functionalities on this website, is personally responsible for the utilisation of that code, which must not be divulged to any third party.
This website is the property of Edmond de Rothschild (France), a Limited Company governed by an Executive Committee and a Supervisory Board, with a registered share capital of €83,075,820, registered with the trade and companies registry in Paris, the RCS, under the number 572 037 026, with registered head offices located at 47, Rue du Faubourg Saint-Honoré, 75008 Paris, France. The director of publication is Mr. Vincent Taupin, Chairman of the Board of Edmond de Rothschild (France). The editor-in-chief is Mr. Romain Grospiron, Director of Marketing and Communication.
The reproduction or copying of all or any part of the elements of this website (including logos, photographs, design, analyses, information, data, prices, assessments or anything whatsoever) is prohibited without prior written permission from Edmond de Rothschild (France).
Cookies and tracking: The user of this website acknowledges having accepted that, when accessing and using this website, information concerning access frequency, operations performed and material consulted is collected by Edmond de Rothschild (France).
2. CONFLICTS OF INTEREST POLICY
Edmond de Rothschild (France) takes care to ensure that the interests of its Clients take precedence over all other considerations. Accordingly Edmond de Rothschild (France) is determined to identify and prevent any conflict of interest that might arise in the course of delivering investment and related services to the Client.
It is with this in mind that Edmond de Rothschild (France) has established an organisation, dedicated procedures and measures that enable it to identify and manage such conflicts, should they arise, as well as possible.
Edmond de Rothschild (France) naturally undertakes to inform the Client of the general nature or source of these conflicts of interest, should such a situation be identified.
Further information about the conflicts of interest policy is available to Clients on request from their customer relationship manager.
3. BEST EXECUTION POLICY - BEST SELECTION POLICY
The Markets in Financial Instruments Directive (MiFID 2004/39/EC) provides as of November 1, 2007 that during the execution of an order concerning a financial instrument on behalf of a client, an investment services provider shall take all reasonable steps to obtain for its client the best execution of the order, in particular by establishing a Best Order Execution Policy and a Best Selection Policy for choice of intermediaries (collectively called The Policy).
3.1 The Bank's role in execution
The Bank may be involved in processing a client's order for a financial instrument in the following ways:
· receiving and transmitting orders to a regulated or over-the-counter market, in which case it applies its Best Execution Policy,
· executing orders on behalf of a third party in a regulated or over-the-counter market, in which case it applies its Best Execution Policy,
· executing orders on behalf of third parties where the Bank as principal acts as counterparty, in which case it applies its Best Execution Policy.
3.2 Scope of Best Execution Policy
The Best Execution Policy aims to select the venues and methods of execution that ensure the best possible result when executing orders, taking into account the following factors:
· trading price
· trading cost
· speed of execution
· likelihood of successful execution and settlement
· size of the order
· nature of the order
· any other consideration that might affect the execution of the order
The Bank takes the following criteria into account in determining the relative importance of the above-mentioned factors:
· characteristics of the Client, including their categorisation
· characteristics of the order concerned
· characteristics of the financial instruments concerned by the order
· characteristics of the venues where the order can be executed
Application of the Best Execution Policy
The Best Execution Policy applies to all transactions in financial instruments except in the cases specifically excluded (see below). The Bank trades with regulated markets, Multilateral Tranding Facilities, market makers, systematic internalizer or other liquidity provider.
The Bank may also trade on an over-the-counter market.
The Best Execution Policy applies to Professional and Retail Clients.
When the Bank executes an order on behalf of a Retail Client, the best possible result is determined on the basis of total cost.
The total cost is the price of the financial instrument plus the costs associated with execution, which include all expenses incurred by the Client directly in connection with the execution of the order, including the direct costs incurred at the execution venue, those in settlement and delivery and all other expenses that may be due to any third parties having taken part in the execution of the order. To this end the bank may employ direct market access (DMA).
The Best Execution Policy for Professional Clients differs depending on the category of financial instrument being traded:
For large capitalisation stocks, the main execution factors are generally trading cost and speed of execution. The Bank reserves the right to employ direct market access (DMA).
The Bank uses the DMA execution service of a broker for orders with a notional value inferior to €100,000. In this case, the broker checks the liquidity (<1% of the Accumulation/Distribution/Volume (ADV) 20 days) and the market impact (<0.10%) of the order. A backup broker will intervene in case of system failure from the first one.
For mid-capitalisation stocks, the main execution factors are generally the trading price and likelihood of successful execution and settlement. For small capitalisation stocks or stocks from emerging markets, the main execution factors are generally the likelihood of successful execution and settlement and the size of the order.
· Negotiable debt securities
For sovereign debt securities, the main execution factors are generally trading cost, order size and swiftness of execution. For corporate debt securities, the main execution factors are generally the trading price and likelihood of successful execution and settlement.
· Currency instruments
For currency instruments the main execution factors are generally the size and nature of the order and swiftness of execution. Nearly all currency trades are executed with the Bank as principal acting as counterparty.
· Derivative instruments
For derivative instruments traded on regulated markets, the main execution factors are generally trading cost and speed of execution.
For derivatives traded over-the-counter, where the Best Execution Policy applies, the main execution factors are generally the trading price and the likelihood of successful execution and settlement. The over-the-counter derivatives trades may be executed with the Bank as principal acting as counterparty.
Where an order is executed on a financial instrument that does not require the choice of a venue or method of execution, as in some primary market transactions, the trade is automatically considered to have obtained the best possible result.
NB: When processing certain orders, traders check the counterparties' limits defined by the bank or by the client, in order to avoid any overruns of the authorized limits.
Non-application of the Best Execution Policy
A Client can give specific instructions on how to execute their order. Where specific instructions are given the Bank may disregard the measures set out in the Best Execution Policy for the items covered by these instructions. The Bank is therefore exempted from its obligation to obtain the best possible result for those factors covered by the specific instructions issued by the Client. If a Client requests a quote from the Bank for a transaction involving a particular financial instrument, which leads to the Bank publishing a price, and a Client agreeing to this published price, the Bank shall not apply the Best Execution Policy as such, as the transaction will then come under the specific instruction regime.
For transactions relating to structured or complex products issued by the Bank and traded over the counter with a Client, the Bank shall not apply the Best Execution Policy as such since the factors and criteria defined above need to be adapted to the context and the type of instrument concerned. As a result, the price offered by the Bank will take into account the costs of its economic model, notably the costs of setting up the sales and monitoring processes, but also including the cost of hedging the transaction or the use of its capital for this transaction, including the cost of credit risk.
3.3 Scope of Best Selection Policy
The Best Selection Policy is designed to select the venues and market intermediaries who provide the best possible result when trading orders where the bank acts as receiver and transmitter of orders (RTO).
Factors taken into consideration by the Bank when selecting execution venues are:
· coverage of financial instruments
· security of the settlement/delivery system
· trading cost
· ancillary services, particularly notifications to market regulators
Factors taken into consideration by the Bank when selecting market intermediaries are:
· compliance of the intermediary's execution Policy and/or trading execution mechanisms with the Bank's Best Execution Policy
· geographical coverage of execution venues
· execution price
· cost of intermediation
· quality of the investment decision support services
· quality of execution services
· quality of trade confirmation and reconciliation services
· ancillary services, particularly notifications to market regulators
· relationships with the Bank's group
· Access of execution venues (regulated markets, multilateral trading facilities, over-the-counter markets)
· any other consideration that might affect the execution of the order or post-execution monitoring
Application of the Best Selection Policy
The Best Selection Policy applies to all transactions in financial instruments except in the cases specifically excluded (see below).
The Best Selection Policy applies to Professional and Retail Clients.
The Bank has in place procedures for monitoring execution venues and market intermediaries so that it can regularly assess the relevant factors and introduce or remove venues or intermediaries from the selection.
Where an order is transmitted for execution on a financial instrument that does not require the choice of an execution venue or of a particular market intermediary, as in some primary market transactions, the trade is automatically considered to have obtained the best possible result.
Non-application of the Best Selection Policy
A Client can give specific instructions as to the execution venue or intermediary to be used for its order. Where specific instructions are given the Bank may disregard the measures set out in the Best Selection Policy for the items covered by these instructions. The Bank is therefore exempted from its obligation to obtain the best possible result for those factors covered by the specific instructions issued by the Client.
3.4 Execution venues
Execution venues means a regulated market, a multilateral trading facility, a systematic internaliser, a market maker, any other liquidity provider, or an entity that performs similar tasks in a country that is not party to the European Economic Area agreement.
Hereafter are listed the Bank's main execution venues:
· Regulated markets: Nyse Euronext, Nasdaq OMX, Hong Kong Stock Exchange, London Stock Exchange, Deutsche Börse Xetra, Borsa Italia, Virt X…
· Multilateral Trading Facilities (MTF) such as BATS, CHI-X, Instinet Blockmatch, GS Sigma X MTF, Turquoise, UBS MTF
· Market makers
· Any internal liquidity of financial counterparty such as systematic internalisation, natural bloc crossing, etc
· Other liquidity providers
This is not an exhaustive list and other execution venues may be used.
3.5 Grouped orders
By the regulatory provision and when the conditions provided for by the regulations in force, the Bank may need to group its client's orders. Through this policy the customer is aware that grouping orders may have an adverse impact.
3.6 Obligation of means Updates to the policy
The Bank takes all reasonable measures to implement the Policy. These measures could not be an obligation of result. The Bank's obligation in respect of the Policy is an obligation of means.
The Buy-side trader retains a degree of flexibility regarding the daily application of this policy mainly when market conditions and environment are taken into account.
The best execution and best selection will not apply to each individual transaction but on a basis of all transactions completed, over a given period.
3.7 Client consent
As a provider of investment services, the Bank cannot transmit or execute an order on behalf of a Client if the Client has not given their prior consent to the Policy. Client consent is a general agreement which covers all provisions of the Policy and is therefore valid for all transactions carried out with the Bank.
A client is considered to have accepted the Policy once he has submitted its first request to transmit or execute an order. This acceptation shall constitute a general and preliminary agreement to execute orders on a regulated market or MTF.
3.8 Updates to the policy
This Policy is reviewed by the Bank as and when necessary and at least once per year, and can be amended at any time without notice.
This Policy is available on the Bank website under the following address: www.edmond-de-rothschild.fr/France/fr/legal-information/terms-and-conditions
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