Skyview Capital Best Execution Policy


The Nigerian Stock Exchange as a component of its Minimum Operating Standard “MOS” require stockbroking firms 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 branches covering all services rendered to our esteemed clients such services like, buying & selling shares/bonds, lien placement, certification verification, transfers etc.

The facilities available in today’s market place allows Skyview Capital to use variety of methods to execute client transactions, including the engagement 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.


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 Stock Exchange.
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 trade execution, clients both individual institutional and corporate and the instruments are equity,


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 the NSE.
ii) Bonds
This is another veritable financial instrument which is also traded along side equities on the platform of the NSE. We trade government bonds & corporate bonds.
This is a new platform for trading quoted stocks. An active plate 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 an Index but can be traded like stock. We offer balances 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.


a. 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)
b. Mandate forms are available for walk in clients at our Customer Service unit.
c. 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
d. All mandates received on weekends or public holidays will be treated as received on the business day immediately following the date of actual receipt.


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.


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 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.


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


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.


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 license, national identification card or a current international


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.

Skyview Capital Complaint Policy


This document describes the Complaint Handling Policy of Skyview Capital Limited, which has been enacted to ensure compliance with the laws and regulations relating to complaint handling. Skyview Capital Limited recognizes the right of its clients, shareholders, regulators and fellow capital market operators to lodge complaints against actions taken by Skyview Capital and omissions that may arise in the ordinary course of business.

Skyview Capital Limited has based its operations from inception on its core values of ethical dealing, integrity and professionalism. It is the philosophy of the company to encourage its stakeholders to ensure that any complaint about the company is appropriately registered. This will ensure that complaints are promptly investigated and resolved.


This Policy applies to all employees, officers, directors and advisors of Skyview Capital Limited.

Client Relationships

Skyview Capital Limited places a high premium on its relationships with clients, regulators and other stakeholders and therefore has established a clearly defined Complaints Management Process to anticipate, handle and resolve complaints from clients and other stakeholders arising from our business operations.

  1. Skyview Capital officials must have the details of every client, in line with the statutory “Know Your Customer” requirement, policies and procedures as contained in the Skyview Capital operational manual, the Rules and Regulations of the Securities and Exchange Commission pursuant to the Investment and Securities Act, and the laws of Federal Republic of Nigeria.
  2. Every client of Skyview Capital must be treated professionally, with utmost respect and is entitled to access all information regarding his/her portfolio.
  3. will be impartial to all clients.
  4. All clients must have access to official contact information such as name, telephone numbers and email addresses of relevant members of staff of Skyview Capital Limited. These will be available on the website of the Company.

Complaints/Enquires from other Market Operators

There are many other market operators whom we have to deal with in order to serve our clients effectively. There might also be situations where, due to misunderstandings or communication failures, our dealings with other market operators and regulators might be called to serious scrutiny; Skyview Capital Limited therefore requires that:

  1. Every member of staff to be conversant with the relevant policies and procedures of the company and approach his/her work with utmost professionalism.
  • All members of staff, other than support staff such as drivers etc., must be conversant with the rules and regulations of the Securities and Exchange Commission.
  • All dealings with other market operators must be in writing.
  • All communication with the Securities and Exchange Commission must be in writing and signed by authorised signatories of the company, in line with the rules and regulations of the Securities & Exchange Commission.
  • In the event that there is any ambiguity regarding the correct interpretation of any rule guiding the market, a formal legal opinion must be secured.

The following Complaint Management Process must be observed at all times.

Complaint Management Flow Chart

Reporting of Complaint

Skyview Capital Limited in line with its policy on proper documentation and record retention will at all times ensure that:

1Maintenance of Complaint RegisterCompliance OfficerShall maintain an electronic and ledger Complaints Register.   The Complaints Register shall contain the following details:   Name of the complainantDate of the complaintNature of complaintComplaints details in briefRemarks/comments   –  Update the Complaints Register monthly.   Track the resolution of complaints.   Ensure response is  sent to complainant within agreed timeframe.   Ensure appropriate reporting to the MD, EXCO, Board Audit and Risk Management Committees of the firm and the Securities and Exchange Commission.    
 2Update of Complaints RegisterCompliance OfficerUpdate the Complainant Register with relevant details and resolutions reached.Obtain a written confirmation from the complainant that proposed resolutions are acceptable.Track the implementation of the resolutions.Issue the Completion Report.
 3Liaison with Regulatory AuthoritiesMD/CEO/ Compliance OfficerStatus reports of complaints filed with the entities shall be forwarded to the SEC quarterly.provide information on complaints and complaints-handling to the relevant competent authority on a quarterly basis.All reports and information must be signed off.

Change of Procedures and Disciplinary Measures

Management must monitor the complaint log and ensure that appropriate disciplinary measures are taken if necessary and provide recommendations for change in the company’s procedures if appropriate.

Dated this 7th Day of October, 2021.

Amos Olufemi Adesiyan    Bola Omoyeni
Managing Director                     Director
  1. Letter confirming receipt of Complaint

Dear Mr/Ms. {Insert Name of Complainant – Dear Sir or Dear Madam is only acceptable where the complainant is not a client of Skyview Capital and no further details are known}

Thank you for taking time to write/call {insert as appropriate} us regarding {state complaint}. We appreciate it when clients/stakeholders {insert as appropriate} let us know when things are not right.

We are currently reviewing the complaint you made and will provide you with feedback within 10 business days (i.e. by {insert 10th business day}. In the meantime, we apologise for any inconveniences that this issue or misunderstanding may have caused you.


Insert name and signature of the Skyview Capital official responding

  • Letter proposing resolution to complaint

Dear Mr/Ms. {Insert Name of Complainant – Dear Sir or Dear Madam is only acceptable where the complainant is not a client of Skyview Capital and no further details are known}

We refer to our previous correspondence with respect to the complaint you made regarding {state complaint} and confirm that we have investigated the complaint made.

In this regard, we propose that {insert proposed resolution}.

Please let us know if you find our proposal acceptable. We expect to hear from you within the next 4 business days, failing which we will assume that you have accepted our proposal and inform the Securities & Exchange Commission accordingly.

We look forward to hearing from you. In the meantime, we apologise for any inconveniences that this error or misunderstanding may have caused you.


Insert name and signature of the Skyview Capital official responding