Scope & Objectives
The best execution and best selection policy details the mechanism for selecting and evaluating the entities used by Shares Financial Assets ("SFA" or the "ISP" or “we”) to execute orders and/or provide financial research, where applicable. It also specifies the due diligence carried out by SFA prior to entering into a relationship with an intermediary.
This policy applies to all financial instruments referenced by SFA, whether the transaction takes place on or off a trading platform. It applies to orders placed by SFA’s clients. These clients are categorised as non-professionals under the applicable regulations.
Regulatory framework
SFA takes all measures to obtain the best possible result for its clients.
SFA does not execute orders and is not a market participant, and as such the company does transmit orders to one or more intermediaries for execution.
SFA therefore selects, for each of its activities and for each financial asset class, partners/intermediaries to which orders will be transmitted for execution.
These entities identified have implemented order execution mechanisms enabling SFA to comply with its obligations regarding placement and respecting the interests of its clients.
For its service of reception and transmission of orders (or "RTO"), SFA undertakes to cover the following services according to the characteristics of each of the financial instruments offered.
- Monitoring of the best execution/best selection process
- Due diligence on selected counterparties
- Annual monitoring and review of counterparties
Selection Policy
Principles
SFA's policy is to select, on behalf of its clients, intermediaries that have taken all steps to obtain the best possible result throughout the execution of the orders transmitted to them.
Third parties are selected by SFA taking into account price, cost, speed, likelihood of execution and settlement, size, nature of orders or any other consideration relating to the execution of orders.
This counterparty selection process follows principles based on the documentation of the entire process and the review at least once a year and per event of the selection made, which may lead, if necessary, to the suspension of a referenced counterparty and its removal, under the conditions described below.
New relationship
A new entity may be approached at the request of a SFA executive or upon proposal from the Group Operations Director.
The Compliance Department is then responsible, along with the Operations Department, for carrying out due diligence and the initial assessment of the intermediaries concerned, with regards to the selection criteria defined below.
Selection criteria
The main criteria used to select and evaluate intermediaries and counterparties are :
- total cost of intermediation for “mass” and “retail” processing
- quality of execution on the markets concerned
- speed of execution (average reported)
- probability of execution and settlement (non-execution rate reported)
- compatibility with the size and type of orders transmitted via SFA
- compatibility with the financial instruments handled by SFA
- quality of administrative processing
- clarity of information transmitted during execution
- quality of IT and technical developments, as well as their interconnectivity, within the precise framework of our platform and its qualitative and technical requirements
- sound financial situation (balance sheet, profit and loss account, etc.)
- quality of commercial support
- reputation and experience in the functions required
- operations in the main financial centres offered by SFA to its clients
- international offering available
- synergies
- involvement for rapid launch
In accordance with AMF Recommendation 2014-07 - Guide to best execution, it is specified that the total cost criterion takes precedence in the selection/execution policy for professional clients. However, all the quantitative and qualitative criteria set out above will be taken into account when selecting intermediaries.
These criteria are used for each financial instrument processed by SFA, i.e. :
- EU listed shares
- US-listed shares
- fractional EU or US shares.
Due Diligences
SFA Compliance Department, in conjunction with the Operations Department, gathers at least :
- The intermediary execution policy
- The intermediary's policy for preventing and managing conflicts of interest
- The intermediary procedure for combating money laundering and the financing of terrorism.
SFA Compliance Department, with the Operations Department, may request any document deemed useful as part of the due diligence carried out on third parties in order to ensure that :
- execution factors such as price, cost, speed and probability of execution, as well as any other relevant factor, are taken into account by the said third parties in order to obtain the best possible result for the customer
- The entity selected has a sound financial position (shareholder rating, balance sheet, income statement, etc.)
- The entity is able to provide references in terms of reputation
- The entity must be able to operate in the main financial centres offered by SFA to its clients
Assessment
The assessment of each intermediary is the subject of a summary report by SFA Compliance. All the results of the due diligence are compiled and give rise to an overall assessment which makes it possible to retain or not an entity for execution. This summary also includes a rating for the market intermediary concerned.
A market intermediary is only rated once due diligence procedures have been carried out and a file has been compiled.
Any commercial partnership with a new intermediary must then be submitted to Group Management for its opinion. The latter makes its decision on the basis of the summary sheet and the file compiled. The Operations Department and the Compliance Department attend meetings of this committee to answer any questions that may arise.
The decision to sign the new partnership is the responsibility of SFA management, after consultation with the Brokerage Committee. Shares SAS is informed of this for referencing at Group level, under the conditions set out in the SHARES Group Outsourcing - Subcontracting Policy. The best selection is made on the basis of a list of counterparties validated at Group level.
Agreement
Once the entity has been selected, an agreement is signed between the two parties. As part of this agreement, SFA is classified by the intermediary in the appropriate MiFID II category. The entity contractually undertakes to comply with best execution obligations.
Record-keeping
The administrative file consists of the following documents:
- Rating and summary sheet
- Approval by the Brokerage Committee
- Intermediary execution policy
- The intermediary policy for preventing and managing conflicts of interest
- The intermediary anti-money laundering and anti-terrorist financing procedures
- Any other documents collected
- The follow-up documents specified below.
SFA then reserves the right to request any other document and any update of documents or information that it deems useful as part of its monitoring of the entity selected.
Responsibilities
SFA will at all times take reasonable steps to seek the best possible execution of all orders placed on behalf of its clients. However, this does not constitute an obligation of result.
SFA shall not be liable for non-compliance or partial compliance with this policy as a result of "force majeure" circumstances that prevent SFA from fulfilling its obligations. Finally, SFA shall not be liable for any negative consequences of the execution of an order resulting from the execution of specific client instructions.
