The Company Policies are presented below:



Post Trade Transparency:

According to the Law 144(I)/2007, as amended and ratified from time to time, of the Cyprus Securities and Exchange Commission (“CySEC” or “Commission”), an Investment Firm which, either on its own account or on the behalf of clients, concludes transactions in financial instruments admitted to trading on an EU regulated market outside a regulated market or MTF (i.e. OTC transactions), must make public the volume and price of those transactions and the time at which they were concluded. This information must be made public no later than three minutes after the transaction has been executed, on a reasonable commercial basis, and in a manner, which is easily accessible to other market participants.

On January 3, 2018, the Markets in Financial Instruments Regulation (Regulation (EU) 600/2014, known as MiFIR), came into force. MiFIR widens the scope of the post-trade transparency requirements to non-equity, equity and equity-like instruments, places the reporting obligation of OTC trades through an Approved Publication Arrangement (APA) upon seller (unless the counterparty is not regulated under MiFID/ MiFIR, or the counterparty is a Systematic Internaliser) and sets stricter post-trade publication timeframes.

From January 3, 2018 Zemblanco Investments Ltd makes public relevant transactions through an authorised and approved APA.