The factors that Golden Broker will consider in order to obtain the best possible conditions will be the price and cost of operations, the speed and probability of execution and settlement, volume, nature or any other relevant consideration.
For the purpose of determining the relative importance of the factors set out above, Golden Broker will take into account the nature of the customer - non-professional (unqualified), professional (qualified) or eligible counterparty investor - together with the nature of financial instruments which are the subject of the order and also the negotiating structures for which the order can or should be addressed.
In pursuit of the best conditions for customers, Golden Broker will, as a priority, pay the global monetary consideration, represented by the price of the financial instrument and the costs related to its execution, including all expenses incurred by the customer and directly related to the execution of the order , such as commissions of trading facilities, settlement or clearing commissions and any other commissions paid to third parties involved in the execution of the order. However, Golden Broker may take into account other factors, where this is imposed by the lack of liquidity in the trading structure in which the order is to be executed, by the type of instructions given by customers as to the period of validity and execution of the orders. their orders and, as well, when customers expressly indicate that they are other factors that must be considered relevant in the execution of their instructions.
In the latter case, any specific instructions from a customer may prevent Golden Broker from taking the measures provided for in its Transmission and Order Execution Policy in order to obtain the best possible results in relation to the execution of those orders, as regards the elements covered by these instructions.
Without prejudice to the consideration of the factors identified above, in the treatment of orders received from its customers, Golden Broker also considers the following factors: Golden Broker is not a member of any regulated market, so all orders received from customers with a view to the trading of securities traded on such markets shall be transmitted to other financial intermediaries, domestic or foreign, with a view to their execution, except where customers expressly indicate that their order should be executed outside such a market and clearly identify the respective counterparty ; in accordance with the agreements entered into with the financial intermediaries who will carry out the orders transmitted by Golden Broker, they have been obliged to adopt a Order Execution Policy aimed at achieving the best execution conditions; in any case, in the case of orders on transferable securities or other financial instruments traded on regulated markets, such intermediaries may execute them on a regulated market, in a multilateral trading system or through a mechanism for the systematic internalisation of orders.
Golden Broker executes or transmits in the cases referred to in the previous paragraph the orders received from its customers through Trading Platforms that are made available to it by highly reputable financial intermediaries, so that it will be at the level of the conditions made available in such Trading Platforms in order to obtain the best execution conditions for its customers; In the case of customers who have direct access to the Golden Trader Trading Platform, without prejudice to the duty of supervision and control over Golden Broker, the determination of the order execution conditions is the responsibility of the customers; In seeking the best execution conditions, Golden Broker will not compare the results obtained by observing its execution policy and commission structure with those that could be reached by other financial intermediaries in accordance with its execution policy and structure. commissions.
In the scope of the portfolio management activity, the investment decisions adopted by Golden Broker will preferably be carried out by Golden Broker itself, in the terms indicated above for the brokerage activity.
In addition, Golden Broker may transmit such investment decisions to other intermediaries and financial institutions, national or foreign, whenever this proves necessary for the correct execution of the operations to be performed for the clients' portfolio. In such cases, Golden Broker will also endeavor to obtain from these intermediaries the link to a Order Execution Policy aimed at achieving the best execution conditions; in any case, in the case of orders on securities or instruments dealt in on regulated markets, such intermediaries may execute them on a regulated market, in a multilateral trading system or through a mechanism for the systematic internalisation of orders.
Golden Broker periodically evaluates its order execution policy and communicates to customers any changes that may be made. At the clients' request, Golden Broker provides information on the specific Trading Platforms used by them for the trading of each of the financial instruments.