Rules and procedures addressing order execution policy

Intercapital Invest adopts all due technical, organisational, procedural and staff related measures required for accomplishing the best possible results for its clients, in relation to trading operations, considering price, costs, speed and probability of carrying out and of settlement, volume and nature of the transaction and any other relevant characteristics for exectution of the Orders received. Should the client be conveying a specific instruction, Intercapital Invest carries out the order in keeping with that instruction.

All operations addressing order receiving by brokers, entry, execution and reporting, in relation to orders and transactions are conducted in full compliance with all laws, norms and legal regulations in force, as well as applicable ethical norms. The carrying out of transactions has to be conducted cost effectively for clients, which means the best execution prices (the highest possible sale prices, and the lowest possible buying prices), the best order entry and carrying out times, strict compliance with the clients' instructions and parameters of their investment strategies in terms of prices, volumes, amounts and risks.

Trading operations are only conducted by persons appointed by the company board specifically for this task and previously authorised as financial investment service agents by CNVM, and as agents in the markets where they act, by the aforementioned market operators. The persons responsible for trading are responsible for the accuracy of the orders entered from their own stations and for observing the terms from the orders sent by the client or by the broker, following the client instructions. The orders received are entered on the market depending on the time of receiving, based on the principle first come, first served.

The orders received by the company are executed on Romanian trading markets. Intercapital Invest does not carry out orders through other brokerage companies. Intercapital Invest monitors the effectiveness in execution of the orders and order execution policy, with the purpose of identifying and remedying any flaw, if there is necessary. The mandatory information required by the legislation in force to be provided to the clients is posted on the web site www.intercapital.ro and/or in the company presentation document, the clients being informed about this.

The current procedures are completed with all the provisions applicable from the regulations issued by CNVM and by the trading markets where Intercapital Invest is active in.

Intercapital Invest establishes and implements a policy by which they secure compliance with the obligations related to achieving the best result for clients. This policy will identify, for each category of financial instruments, the entities where the orders have been placed with. The entities identified need to have carrying out means that would enable the brokerage company to undertake the obligations provided by CNVM Regulation no. 32/2006 when they place or convey orders to be carried out by that entity. The brokerage company will supply adequate information to its clients, in relation to the policy established, in keeping with the previous provisions. The brokerage company will regularly monitor the efficiency of the policy established in keeping with the previous provisions and, mainly, the quality of the carrying out operations performed by the entities identified in that policy, and if necessary, will adjust any deficiency.

The company will revise annually or whenever there is an important amendment, for the purpose specified by law, the order carrying out policy as well as the procedures addressing order carrying out, and it will amend the current procedures should this be necessary.