Best Execution Policy AFS under MIFID I
AFS’ best execution policy is based on the Markets in Financial Instruments Directive (MIFID I) of 01/11/2007. In the Netherlands these rules have been included in the Wet financieel toezicht (Wft). The overall purpose of the policy is to provide clients with the best possible result, in line with client orders.
Formally till December 2017 AFS is obliged to follow the MIFID I best execution requirements. However, as the level two implications of MIFID II are already clear, as of January 2017 AFS will follow the best execution obligations required under MIFID II.
Products in scope
The best execution policy applies to:
- ETFs (Listed)
- Structured products (Listed)
- Warrants, Turbo’s and Speeders
Note: please refer to the exchange websites or websites of issuing parties for information about the nature and risk of the financial instruments you would like to trade.
Out of scope
Not all orders are subject to the best execution policy. The following orders are excluded:
- Orders with specific execution instructions
- Orders in instruments that fall outside the scope of MIFID I
Below are some of the most important criteria that determine best execution:
- Fees (including but not limited to exchange, clearing and settlement)
- Order type
- Probability of execution
When execution a client order AFS will take into account the nature of the financial product, the execution venue, any third party used for executing a client order and any specific instruction given by the client.
Price is one of the most determining factor when executing an order. However other liquidity drivers need to be taken into account, such as liquidity, speed and likelihood of execution, etc.
It is our aim to execute every order according to the same guidelines and procedures. However, as markets change constantly, the conditions for executing trades also changes constantly. AFS will take the changing conditions into account when executing an order.
AFS is an active member of the following markets:
- Euronext Derivatives
- BATS (for EFP crossing only)
- OMX (block trading facility only)
- AFS also holds a dormant membership on Euronext Cash.
Third party brokers
For those markets where AFS is not a member, AFS may use the services of a third party broker. The broker has been selected after a stringent due diligence process taking into account risks, costs, technology and their ability to provide best execution in the market that they service. Third party brokers’ performance and services are reviewed regularly.
Place of execution
AFS will execute your order on the market where it’s listed. If an instrument is listed on different markets then AFS will select the market on which best execution can be provided in view of the above-mentioned criteria.
AFS will execute an order in line with the specific instructions it receives. These specific instructions have priority over AFS’ best execution policy. The resulting execution might not be the best possible execution. In some cases, following the best execution policy can result in a partial execution or in no execution.
Best execution proof
Clients can request proof that the order was executed in line with the best effort execution. AFS will produce proof within a reasonable timeframe. Records are maintained for 5 years.
Clients using AFS’ brokerage services consent to this best execution policy.
AFS will use reasonable effort in finding the best execution for your order. AFS may use third parties for executing your order. The AFS best execution policy applies to eligible and professional clients.
The best execution policy is reviewed annually and with every change in regulations. We also take into consideration Possible changes in execution policy of third parties and exchanges.