Best Execution Policy

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The procedure for the execution of the best price for the customer pursuant to Law no. 62/2020 "On Capital Markets"

1. BEST EXECUTION FACTORS
  1. Price: It is the unit price of the financial instrument.
  2. Speed: It is time to fulfill the customer's request.
  3. Size: It is the number of units of the financial instrument that the client will trade.
  4. Liquidity of the financial instrument: It is the ease of trading the required financial instrument
2. ACCEPTED CLIENTS
The bank can offer the execution of orders to its customers, but it is obliged to complete the suitability test for the customer.
 
3. THE ORDER OF EXECUTION
Customers of the bank have priority in the execution of orders. After this execution, the Bank can execute orders in its favor. If there are several customers, they are served on a first-come, first-served basis.
 
4. INFRASTRUCTURE USED
To get the best quotation in the market, BKT uses licensed platforms in the international market of financial instruments such as:
  1. Bloomberg and Refinitiv.
  2. Platform of licensed brokers in the international market of financial instruments as they are INTERACTIVE BROKER, STONEX etc.
  3. Direct contacts with licensed banks and brokers in the international market of financial instruments, such as Intesa SPA, Commerzbank, SOCGEN, JP MORGAN, DEUTSCHE BANK, DZ BANK, etc.
BKT enters a financial transaction with counterparties/brokers after conducting an in-depth analysis such as KYC, AML, etc. and setting a trading limit. The brokers and banks with which BKT cooperates are licensed in the EU and are subject to compliance with the MIFID II regulation, which indicates that they respect the best price procedure.
 
5. GETTING THE BEST PRICE
Financial instruments are traded in the international market and in the domestic market:
  1. Financial instruments that are traded in the international market BKT, through its communication infrastructure, Bloomberg and Refinitiv communicates with a minimum of 3 brokers and selects the best price. In cases where BKT trades from/for its own portfolio, it must provide the best quoted price in the international market plus a profit margin that is suitable for the bank.
  2. Financial instruments that are traded in the domestic market BKT, through its communication infrastructure, Bloomberg and Refinitiv communicates with local banks and selects the best price. In cases of sale/purchase by/for own account, the price is calculated by interpolating the results of the last auctions and adding a profit margin that is suitable for the bank.
 
6. SETTLEMENT OF THE TRANSACTION
BKT enters transactions to meet the requirements of its clients with banks and brokerages, which have passed the process of KYC and AML and the establishment of a trading limit. Payments are settled according to the "Delivery Versus Payment (DVP)" principle. BKT takes care that the DVP process is carried out on time and in accordance with the agreed conditions for the sale/purchase of the financial instrument.

If the DVP process fails due to the client's inability to pay or the inability to find the financial instrument, BKT with the experience it has will try to resolve this impasse so that all parties remain satisfied.

7. TRANSPARENCY
When entering a sale/purchase transaction of a financial instrument, the customer can ask the bank to confirm that he has received the best price. In this case, the bank is obliged to show:
  1. In the case where the bank acts as an intermediary between the buyer and the seller, the bank shows the communications with the different brokerages (minimum 3 brokerages) 
  2. In the case when it sells from its own portfolio, the bank indicates (if any) the quotes that have different contributors for the financial instrument to be traded.