1.1 At El-elyon Alliance & Securities Limited (“EASL”) our business is built on trust and integrity in line with our profession and as perceived by our stakeholders- clients, shareholders and regulators.
1.2 An important component of trust and integrity is ensuring that EASL conducts its business in accordance with the values, Code of Conduct and Ethics that EASL has adopted, and in compliance with applicable laws, rules, policies and standards.
1.3 EASL Best Execution Policy (the “Policy”) is designed to comply with the Nigerian Stock Exchange (NSE) Rules on Order Handling and Best Execution as well as other applicable statutory and regulatory obligations, ensuring that:
1.3.1 Best execution is sought at all times when purchasing or selling securities on behalf of EASL clients.
1.3.2 Reasonable steps are taken to obtain the best available results for EASL clients within the shortest time frame in accordance with the terms and conditions of client’s mandate.
2.1 When does this Policy apply? This Policy applies to all clients mandates.
2.2 Best Execution
2.2.1 EASL shall at all times when acting on behalf of clients on the purchase or sale of securities, adhere to this Policy by taking reasonable steps to obtain the best available results for the client within the shortest time frame in accordance with the terms and conditions of the mandate from the client.
2.2.2 EASL is obligated to deliver the best possible result when executing client mandates at all times.
2.2.3 EASL shall apply this Policy in a manner that takes into account the different circumstances associated with the execution of mandates for particular client.
2.2.4 When executing an order, EASL shall take reasonable steps to obtain the best possible results under the circumstances whilst taking into consideration the following execution factors. These include: price, costs, speed, likelihood of execution and settlement, size, nature, price improvement, market impact or any other consideration relevant to the execution of a client’s mandate.
2.2.5 EASL shall establish and implement this Policy to each client’s mandate
2.3 Client Order Handling
2.3.1 EASL shall implement process and procedures which provide for the prompt, fair and timely execution of clients’ mandates.
2.3.2 EASL shall whilst carrying out clients’ mandates, ensure that mandates executed on behalf of clients are promptly and accurately recorded and allocated.
2.3.3 EASL shall not execute a client’s mandate in aggregation with another client’s mandate.
2.3.4 EASL shall not aggregate a client’s mandate with a transaction for its proprietary account.
2.3.5 EASL shall not misuse information relating to pending client orders and shall take all reasonable steps to prevent the misuse of such information.
2.4 Notification
2.4.1 EASL shall display the Policy on its website at all times.
2.4.2 EASL shall notify its clients of the regulatory provisions of this Policy, any changes therein and its effect to their transactions.
2.4.3 EASL shall promptly inform its clients of any material difficulty relevant to the proper execution of mandates upon becoming aware of the difficulty.
2.5 Audit Trail
2.5.1 EASL shall ensure that a system for tracking and monitoring orders is established and maintained.
2.5.2 Evidence of audit trail shall be maintained.
2.6 Monitoring
2.6.1 EASL shall monitor the effectiveness of its order execution arrangements and this Policy on a regular basis in order to identify and, where appropriate, improveor correct any deficiencies.
3.1 Client Mandate/Order:
This is an authorization from a client to a firm to trade securities in its registered trading account. The client is the beneficial owner of the securities traded.
3.2 Best Execution:
“Best execution” refers to the obligation on the firm, when executing or arranging the execution of a client order, to take all reasonable steps to obtain the best possible result for its client.
