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MIFID Directive: communications to Customers
The Directive 2004/39/CE of the European Parliament on markets in financial instruments (i.e. MIFID Directive) and the relevant regulations implemented by the Italian Institutions effective from 1/11/2007, requires us to:
- define and carry out measures for the execution and transmission of orders that allow us to have more favourable conditions for our Customers' orders (i.e. best execution policy);
- give appropriate information to our Custumers on the aforementioned strategy .
- General Information on strategies of execution and transmission
The factors identified by the regulations as possible elements of strategic differentiation in the way of transmission/execution of orders (price , costs , speed and likelihood of execution , size of the order...) can not in any way change Directa's order management , because Directa does not want it to be at its own discretion and accepts orders from its Customers only with specific instructions about how to execute and transmit them.
The only form of discretion is one that may be required in the event that a extended technical issue would prevent the timely forwarding of the order, along the normal route, to the destination indicated by the Customer: Directa may therefore use an alternative route, usually another interconnected broker , to reach , whenever possible , the same venue of execution , providing explicit documentation in the Information sheet and without additional costs to the Customer.
In summary Directa SIM SpA uses the following "strategy of execution and transmission " of orders :
Timely forwarding to the market , the Organized Trading Systems/ Multilateral Trading Facility or broker chosen by the Customer: except that in case of technical issues , any discretion for-warding and, in any case , any internalization of order is excluded.
- Information on strategies for direct execution of orders
Directa SIM SpA directly transmits orders to the following markets and Organized Trading Systems:
- Electronic markets organized and managed by the Italian Stock Exchange and BATS Chi-X Europe.
- Derivatives foreign markets : Eurex and Chicago Mercantile Exchange.
- Organized Trading Systems (Multilateral Trading Facility ): Trading After Hours Market and AiM Italia-MAC of the Italian Stock Exchange
- Information about transmission of orders to the recipient other than a market or an organized trading system
For orders that cannot be forwarded directly to a market Directa SIM SpA relies on the support of the leading brokers listed below , which allow a remote management of orders and a timely execution :
- For the market organized and managed by Deutsche Boerse (Xetra ): Dero Bank AG (previously VEM Aktienbank AG) or Banca IMI
- For regulated U.S. markets like NYSE, AMEX, NASDAQ, ECN - and the OTC: ViewTrade Securities
- For LIFFE and EuroTLX markets (securities not deposited in Monte Titoli): Banca IMI
- For LMAX MTF: LMAX Exchange.
In line with its strategy of execution , in the case where financial instruments are traded on several execution venues , Directa will ask the Customer to indicate his choice , which will be considered as a binding instruction on how to perform/transmit orders.
Please note that the above-mentioned "special instructions " may prevent to obtain the "best execution " as defined by the current legislation.
Directa SIM SpA periodically examines its strategy of execution and transmission of orders and gives timely notice of the changes that might be necessary.
Therefore we require your consent on::
- the abovementioned strategies of execution and transmission of orders;
- the fact that in some cases your instructions will execute an order outside of an Organised Trading System (in particular the U.S. OTCs);
- the use of interconnected brokers (in particular U.S. brokers)
who are not obliged to display on their order book price limits orders, not immediately executed, on securities listed in an organised market.