1.0 INTRODUCTION & SCOPE
The Nigerian Exchange Limited (NGX) as a component of its Minimum Operating Standard “MOS” requires Trading License Holders to send information on their execution policy (“best execution”) for their clients.
This document sets out information on the execution policy of Skyview Capital Limited and all its representative offices covering all services rendered to our esteemed clients. Such services which include but not limited to, buying & selling shares/bonds, lien placement, certification verification, transfers.
The facilities available in today’s market place allows Skyview Capital to use variety of methods to execute client transactions, including the engagement of latest technology – Order management system “OMS” that enables clients determine the full cycle of a trade from anywhere in the world and the inclusion of more professionals to give quality service to teaming customers.
In essence, the following terms and conditions apply to facilitate effective and efficient delivery of our professional service to customer.
2.0 DEALING/BUSINESS VENUES & COUNTERPARTIES
Skyview Capital will consider a number of factors in seeking to obtain best execution. These may include speed, costs, price, size of the business and likelihood of execution and settlement.
Our dealing/Business venues are the platform and methods of doing business on a day-to-day basis;
a) The trading floor of the Nigerian Exchange Limited (NGX).
b) The NASD OTC trading platform
c) Our business offices in Lagos, Abuja and Port Harcourt.
d) Through our Order Management System “OMS”
Also clearly stated above are the criteria’s for choosing counterparty. They are those that partner with us in trade execution, clients both individual, institutional and corporate and the instruments are equity, bonds, fund raising – private placement, public offerings, bonds, advisory services etc.
3.0 CLASSES OF FINANCIAL INSTRUMENT & CURRENCY
Best execution applies to all types of financial instruments and each client order or request is perfected using different approach and instrument depending on the request.
i) Equities
We buy and sell shares for customers with specific instructions via their mandates. We manage portfolios for clients and engage in Propriety Trading through our platform at NGX.
ii) Bonds
This is another veritable financial instrument which is also traded alongside equities on the platform of NGX. We trade government bonds & corporate bonds.
iii) NASD OTC
This is a new platform for trading quoted stocks. An active place for medium and small-scale enterprises to engage in equities trading which Skyview Capital is a major player.
iv) ETF’s
The Exchange Traded Fund is a fund that trades on Index but can be traded like stock. We offer balances in alternative to our diverse clientele in the classification of financial instruments e.g. Gold, Silver, Commodities.
Furthermore, the acceptable legal tender for all transaction in Nigeria is the Naira(N) except for the ETF’s that cut across the globe at the same time.
4.0 MANDATE INSTRUCTION
a. Skyview Capital Limited shall be solely responsible for the accuracy of orders entered into the Trading system while acting on a client’s instruction.
b. Skyview Capital Limited shall not access a client’s account without a confirmed mandate.
c. All orders entered for clients must contain the following: Date and time of entry, the security name and quantity to be traded and the terms and validity period of such order.
d. Client enquiries, stock purchase and sale mandates and payment advice can be handled via: electronic means (e-mail or our dedicated email address – info@skyviewcapitalng.com)
e. Mandate forms are available for walk in clients at our Customer Service unit.
f. The daily transaction deadline for the receipt of stock exchange purchase mandate, stock sale mandate and payment advice is 4pm of the business day preceding the date such instructions are to be executed
g. All mandates received on weekends or public holidays will be treated as received on the business day immediately following the date of actual receipt.
Execution Parameters
In the absence of a specific instruction or instructions from a client, Skyview will take into account the following parameters when executing an order on behalf of a client:
- Price;
- Speed of execution;
- Size of order;
- Likelihood of execution and settlement;
- Nature of your order;
- Any other relevant factor (including market liquidity, availability of market information and market volatility).
Execution Criteria: Areas of consideration here includes:
- Your characteristics (e.g. a retail or an institutional investor/professional counterparty);
- The nature of the order which you have given us;
- The characteristics of the relevant financial instrument; and
- The characteristics of the execution venues to which your order can be directed (including the ability of the venue to manage complex orders, the creditworthiness of the venue and the quality of any related clearing and settlement facilities).
The above Execution parameters are listed in the order of importance that will normally be applied to an order that Skyview executes on your behalf. However, it may change the order of importance assigned to the Execution parameter if, in its opinion, you will receive a better outcome.
Specific Client Instructions
Where you give us a specific instruction as to the execution of an order, Skyview will execute the order in accordance with those specific instructions. Where your instructions relate to only part of the order, we will continue to apply our order execution policy to those aspects of the order not covered by your specific instructions.
You should be aware that providing specific mandates to Skyview in relation to the execution of a particular order may prevent her from taking the steps set out in our order execution policy to obtain the best possible result in respect of the elements covered by those mandates.
Order Execution Process
Below are the basic processes that will be followed towards the execution of an order:
a. Individual and Institutional Client Trade Orders
- For a purchase mandate, operations team confirms authenticity of client’s mandate, availability of funds in customer’s stockbroking account, prepares the jobbing sheet and passes it across to our brokers for onward execution in line with client’s
- For a sales mandate, the operations team will confirm client’s instruction against the already existing details in the database by confirming email, signature and availability of stock(s) in clients account before presenting to the brokers through a summarized jobbing sheet.
- Upon completion of sale or purchase mandate, the client is advised within 24hours via a contract note which usually contains, the breakdown of charges on his/her transaction.
SKYVIEW will monitor the effectiveness of its order execution arrangements on an ongoing basis to identify and implement any appropriate improvements and will undertake a review of the Best Execution Policy on at least an annual basis. SKYVIEW will notify you of any material changes to the above description of its order execution arrangements and the Policy.
B. Consent
SKYVIEW is required to obtain your consent to the Best Execution Policy. By giving an order to SKYVIEW, you confirm your acceptance of this Policy.
5.0 SALE/BUY TRANSACTIONS
a. In mandates consisting of purchase instruction, the execution of such mandate will be dependent on sufficient cleared funds.
b. Where a stock purchase mandate is dependent on the sale proceed of stock, the stock purchase mandate will not be executed until the sales transaction has been fully executed, the stock purchase mandate will be executed for five business days subsequent to the actual date.
c. Where the stock for purchase is still not available after these five working days, the stock sale mandate will be set aside and the customer will be advised accordingly.
6.0 EXECUTION OF MANDATES
a. In the execution of clients’ mandate, Skyview Capital acts as stockbroker in an execution capacity and not as a financial advisor. We will therefore discharge our responsibility to BUY or SELL stock on your behalf on the floor of The Nigerian Stock Exchange
b. Skyview Capital will execute transactions based on the current market price of the stock exchange on the date of execution
c. Skyview Capital will apply its professional expertise and best efforts in executing mandates. We however cannot guarantee that a mandate will be executed at the market price indicated on such mandates, as market prices are subject to marginal daily changes.
d. Mandates will only be attended to when presented in the standard format acceptable to Skyview Capital which can be downloaded from our website or may be forwarded to our email.
e. Skyview capital does not accept a range of price for the purchase/sale of stocks. Only one price may be indicated
f. On execution of your mandate, a notification e-mail will be sent to update you of your transaction.
7.0 ACCOUNT TRANSFERS
Where stock was purchased through another stock broking firm before the client transferred his account to skyview capital, the clients should ensure that the resident stock broking firm has sent his/her specimen signature (on transfer forms) to the respective registrars
8.0 CERTIFICATE LODGEMENT
a. To facilitate prompt verification of certificates, clients should endeavor to attach copies of application form, dividend warrants and banker’s confirmation of the client’s signature as the case demands.
b. Skyview capital will not be responsible for verification delay due to incomplete documentation, irregular signature issue or any other reasons outside its sphere of control
9.0 ORDER OF PAYMENT
a. Transaction settlement on the Nigerian Stock exchange is done on a trading day plus three days (i.e., T+3). In compliance with this regulation, payment for sales transaction is on a trading day plus four working days consideration
b. Skyview capital pays in crossed cheques written in the name of the beneficiary whose name appears on the share certificate or account holder. The acceptable means of identification here is a current driver’s lice se, national identification card or a current international passport.
10.0 BROKERS ASSESSMENT & MONITORING
a. Traders are not allowed to trade on their own account or those of their immediate family or relations except with the approval of Management.
b. Separation of jobbing from trade execution: clients’ mandates for sales and purchases are processed for jobbing only by the back-end office operations staff; brokers are not permitted to have prior knowledge of such orders until only the hours of trading for execution on the trading machine.
c. Large institutional mandates e.g., PFAs are handled by a dedicated or assigned broker who is not a party to the Company’s proprietary trading account or member of the company’s investment committee to prevent taking undue advantage of such orders.
d. Personnel assigned to manage clients’ portfolio with discretionary mandates must not have access to information contained in other clients’ orders with non-discretionary mandates to prevent using such information to the benefit of the portfolio which they manage.
e. Under no circumstances should research analysts seek to directly or indirectly obtain unpublished confidential information which is price sensitive and material to a listed company.
f. The trade/research analysts are prohibited from accepting any gift or inducement from any client, capable of calling into questioning their integrity and independence