Summary analysis and conclusions from detailed monitoring of the quality of execution

(a) The NBI Investments takes special attention to the order execution factors for both retail and professional customers:

• (a) For retail customers – price and costs of execution are of particular importance, as for the clients sensitive to lack of market information and expertise. These customers are more concerned with the potential short term loss, that’s why the importance of the absence of additional charges is of value to this category.
• (b) For professional clients – the likelihood and speed of execution are of value due to higher knowledge and experience of these client group. The propensity to place the market price orders also stresses the Importance of the speed and likelihood of the execution for this client category.

(b) In 2017 NBI Investments had only three execution venues which were:

• Ronin Europe Limited (LEI 213800Z6ZVP4TNER8851)
• Bank Otkritie Financial Corporation (LEI 253400D1T9WFNN3BTT91)
• SOVA Capital Limited (LEI 213800T9OJMZA69QDM04, former Otkritie Capital International Limited)

All these three execution venues have no close links or common ownerships with NBI Investments
(c) There was no rebates or incentives received by any of the execution venues involved
(d) There were no changes in the list of Execution venues in 2017.
(e) Due to the fact that there are few professional clients in the overall customer base there was no special treatment of the professional clients because there was no heavy order flow at any time.
(f) Price and costs were the primary criteria while executing the retail client orders.
(g) The firm used DMA trading system provided by OCIL for market liquidity information as well as for quality of execution check.
(h) The investment firm has not used output of consolidation tap provider established under Article 65 of Directive 2014/65/EU.

Information Disclosure (Table 1, 2 , 3)