The company within the scope of MIFID Services may potentially sign third party agreements with other financial institutions under which it could receive retrocession fees (inducements) for services offered. In such cases the company adheres the following principles:

1. Prerequisites

Under such agreements the Company has taken all necessary measures to adhere to any rules that derive from its non – conflict-of-interest policy. Moreover, further actions are taken as follows:

  • All agreements aim to enhance services which are offered and to bring additional value to the client.
  • The client/ targeted client is being informed well in advanced with regards to inducements.
  • At least once per year clients receive detailed statement of the charges related to any inducements that company receives.

2. Specification of additional actions

2.1 Agreements focusing on bringing additional value.

Company’s aim is to create a framework that brings additional value and benefits in favour of its clients. Since it is very hard to quantify these benefits and as such may vary from client to client, several quantitative factors taken into account are the following:

  • Redemption and subscription fees
    In case the company receives inducements with regards to redemption or subscription of funds, it takes into consideration such fees to be smaller or equal to the fees charged if such investment was done directly by the client. That is a quantitative factor from which clients can benefit.

  • Product Evaluation
    The Company, within the scope of its regulated activities, assesses third party products, considering the following factors: historic prices, size, volatility, and liquidity etc. Recently also included sustainability factors and relevant assessments from independent houses. Such services add value to its clients and protect company’s goodwill.

    On a regular basis the company monitors products from third party providers considering: annual returns, performance vs benchmark and vs peers, sustainability factors as carbon footprints, contribution to the transition of environmentally friendly society, human rights, diversity & inclusion.

  • Equal or better of total results
    Any inducement related to transaction fees or to management fees, should be agreed in such a way so the client will not bare any extra cost and eventually total cost to end up being equal or smaller compare to direct purchase of the same service from third party product providers. In such cases cost saving is measurable but may vary from client to client.

2.2 Disclosure
In case the company has third party agreements with respect to fee retrocession (inducements) that is stated in clients ‘agreement. In addition, under the same agreement, the client has the right to request in written how inducements are calculated and being charged.


2.3 Frequency of client updates
The client receives consolidated statement of his total positions at least once per year.