Disclosures and Reports

Pillar III Disclosures 2015, 2016, 2017, 2018, 2019, 2020, 2021

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.

Information on the top five execution venues and brokers RTS 28

In accordance with the Investment Services and Activities and Regulated Markets Law of 2017 L.87(I)/2017, as subsequently amended or replaced from time to time (“the Law”), ZEMBLANCO INVESTMENTS LTD (“the Company”) is required to take all sufficient steps to act in the best interest of its Clients when receiving and transmitting Client Orders for execution and when executing client orders to achieve best execution results and to comply, in particular, with the principles set out in the Law when providing investment services. The Company has obligations under MiFID II and specifically under Commission Delegated Regulation 2017/576 (RTS 28) with respect to the publication of the annual Execution Quality Summary Statement (EQSS) which you should release to the public (via website) by the end of April each year for the previous year.

The Company is required to make public on an annual basis, for each class of financial instruments, the top five execution venues in terms of trading volumes where it executed client orders in the preceding year and information on the quality of execution obtained. Similar information will be reported with respect to the top five investment firms (e.g. brokers) where the Company transmitted or placed client orders for execution in the preceding year.

Quality of Execution Report RTS 27

Directive 2014/65/EU of the European Parliament on markets in financial instruments and Regulation (EU) 2017/575 supplementing Directive 2014/65/EU set regulatory technical standards concerning the data to be published by execution venues on the quality of execution of financial instruments.

In order to provide both the public and investment firms with relevant data on execution quality to help them determine the best way to execute client orders and in order to fully assess the extent of the quality of execution of transactions that take place in the European Union, it is appropriate that execution venues which may be selected by investment firms to execute client orders have to comply with requirements on data to be provided by execution venues in accordance with Regulation 2017/575. To this effect, these execution venues should include regulated markets, multilateral trading facilities, organized trading facilities, systematic internalisers, market makers and other liquidity providers.

Zemblanco Investments Ltd in accordance with its authorization may act as execution venue for clients orders traded OTC, hence in order to comply with abovementioned Directive and Regulation, the Company has to publish a quarterly report that contains data of the execution quality (i.e. details about price, costs and likelihood of execution for every individual financial instrument offered) based on the relevant regulatory requirements.





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