MiFID II

MiFID II is a package of regulations adopted by the European Parliament in 2014, including the Directive and Regulation of the European Parliament and of the Council on markets in financial instruments, as well as European and national implementing rules

‍

Key Legal Acts:

• Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU)
• Commission Delegated Directive (EU) 2017/593 of 7 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards the collateralisation of financial instruments and cash held by customers, product management obligations and rules applicable to the offer or acceptance of remuneration, commissions or other monetary or non-monetary benefits
• Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Regulation (EU) No 648/2012
• Commission Delegated Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and business conditions for investment firms and the concepts defined for the purposes of that Directive
• Act of 29 July 2005 on trading in financial instruments (Journal of Laws of 2005 No. 183 item 1538)

‍

Objectives of MiFID II

The main objective of MiFID II is to ensure that investors, particularly retail investors, are provided with adequate levels of investor protection, fair competition in the financial sector, and transparency in the operations of investment firms and banks in financial markets within the European Union.

‍

MIFID II in relations with the individual client

Actions Taken by a Brokerage House Before Providing Brokerage Services:

• Classification of the client to determine the level of investor protection to which they are entitled.
• Conducting an assessment of the suitability of products and services.
• Providing the client with information about financial instruments and investment services.
• Entering into an agreement with the client regarding the provided investment service.

Actions Taken During the Provision of Brokerage Services:

• Verifying whether the client is within the target group for a specific product when acquiring the product.
• Executing orders while ensuring the client’s best interest.
• Providing the client with confirmations of executed transactions and statements of stored or recorded assets.
• Managing potential conflicts of interest related to transactions or services provided for the client.
• Addressing complaints.

‍

Details

Information on Trigon Dom Maklerski SA and the services provided to Clients under agreements with Trigon Dom Maklerski S.A. [PL]‍

Information on Trigon Dom Maklerski SA and the services provided to Clients under agreements with Trigon Dom Maklerski S.A. [EN]

‍

Agent of Trigon Brokerage House S.A.

Information about the agent of an investment company performing brokerage activities for Trigon Domu Maklerskiego S.A.

Trigon Brokerage House S.A. classifies Clients into three categories:

• Retail Client
• Professional Client
• Eligible Counterparty

‍

‍

Furthermore, we would like to note that the information regarding the classification assigned by Trigon Brokerage House S.A., the annual information for the Client, and information regarding transaction confirmations have been provided to Trigon Brokerage House S.A. clients via postal or electronic correspondence.

Details

Client categorisation policy of Trigon Dom Maklerski S.A. [PL]

Client categorisation policy of Trigon Dom Maklerski S.A. [EN]

Information on the Trigon Dom Maklerski S.A. policy on dealing with professional Clients [PL]

Information on the Trigon Dom Maklerski S.A. policy on dealing with professional Clients [EN]

Request to be treated as a Retail Client (submitted by a Professional Client) [PL]

Request to be treated as a Retail Client (submitted by a Professional Client) [EN]

Request to be treated as a Retail Client (submitted by an Eligible Counterparty) [PL]

Request to be treated as a Retail Client (submitted by an Eligible Counterparty) [EN]

Request to be treated as a professional Client (submitted by an Eligible Counterparty) [PL]

Request to be treated as a professional Client (submitted by an Eligible Counterparty) [EN]

Request to be treated as a professional Client (submitted by a Retail Client) [PL]

Request to be treated as a professional Client (submitted by a Retail Client) [EN]

Trigon Dom Maklerski S.A. may condition the provision of a service or the offering of a specific product to a Client based on the Client's classification (based on the analysis of the information available about the Client) to the relevant target market of end clients for whom the Brokerage House provides the given service or offers the given product.

Trigon Dom Maklerski S.A. may refuse to provide a particular service or offer a specific product to Clients whose needs, characteristics, and objectives do not align with the product or service, according to the knowledge held by Trigon Dom Maklerski S.A.

Trigon Dom Maklerski S.A. provides Clients or potential Clients with a general description of the nature of financial instruments and the risks associated with investing in these financial instruments, in a manner that allows the Client to make informed investment decisions, adjusting the scope of this information to the type of financial instrument and the category to which the Client belongs..

Trigon Dom Maklerski S.A. informs that investing in financial instruments involves the risk of losing part or all of the invested funds, as well as the possibility of the Client incurring losses exceeding the value of the invested assets. Therefore, when making investment decisions, the Client should, in particular, take into account the risks associated with investing in a particular class of financial instruments, the expected return or the potential loss they are willing to accept, and analyze various external factors affecting the price or liquidity of the financial instrument, such as the stability of the legal and tax systems, economic conditions, the prospects for economic growth, or the likelihood of force majeure events.

Trigon Dom Maklerski S.A. informs the Client that the historically high rate of return on investment achieved by a given financial instrument does not guarantee the achievement of a similar result in the future.

‍

Details

General description of financial instruments and the risks associated with investing in these financial instruments

General description of the nature and risks of financial instruments

Trigon Dom Maklerski S.A. applies principles that prevent conflicts of interest from arising and ensure their effective management if they occur. These principles are outlined in the Conflict of Interest Management Policy at Trigon Domu Maklerskim S.A.

‍

In accordance with this Policy, the Client's interest always takes precedence over the interests of Trigon Dom Maklerski S.A. and its employees. This approach ensures both the protection of Clients' interests and their equal treatment.

‍

Details

Conflicts of interest policy of Trigon Dom Maklerski S.A. [PL]

Conflicts of interest policy of Trigon Dom Maklerski S.A. [EN]

‍

Trigon Dom Maklerski S.A. implements the “Order execution policy and best execution policy of the Client in Trigon Domu Maklerski S.A.”, which defines detailed rules of conduct in order to obtain the best possible results for the Client in connection with the execution of the order.

The policy is applied in connection with orders executed as part of brokerage services:

• Executing orders for the purchase or sale of financial instruments,
• Receiving and transmitting orders for the purchase or sale of financial instruments,
• Providing portfolio management services for financial instruments.

The policy applies to both retail and professional clients. It does not apply to eligible counterparties. All actions taken by Trigon Dom Maklerski S.A. as defined in this policy do not guarantee that a Client’s order will be executed with the best possible outcome for the Client in every case and under all circumstances.

The obligation to take sufficient steps to achieve the best possible results for the Client should not be regarded as an obligation for Trigon Domu Maklerskiego S.A. to consider all available order execution systems.

Details

Order execution policy and best execution policy.

Order execution policy and best execution policy.

Trigon Dom Maklerski S.A. records and archives documents, recordings, and registers on electronic media other information carriers, including statements prepared or received in connection with the brokerage services provided. It also prepares, on a durable medium, protocols, notes, or recordings of conversations held in the direct presence of the Client, made via electronic channels, related to the conclusion, amendment, termination, and execution of a brokerage agreement.

The Client and potential Client have the right, and Trigon Dom Maklerski S.A. is obliged, to record all telephone conversations or correspondence transmitted in any other form agreed upon by Trigon Dom Maklerski S.A., which directly or indirectly relate to placing an order or concluding a transaction. The recorded materials may serve as evidence of actions taken therein in the event of proceedings to determine issues related to specific orders or transactions before a court or another authority designated to hear and resolve disputes. Trigon Dom Maklerski S.A. will, upon the Client's or potential Client's request, provide them with the recording or correspondence related to the order or transaction concluded, for a period of 5 years from the date of placing the order or concluding/settling the transaction, and, if requested by the competent authority, for up to 7 years.

Trigon Dom Maklerski S.A. provides Clients with additional ex ante information about the costs of example transactions, their impact on investment returns, and forecasts of cost fluctuations. The purpose of presenting ex ante costs for brokerage services is to provide Clients with tools that explain the effect of cumulative transaction costs on the final financial outcome of the Client's investment.

Trigon Dom Maklerski S.A. provides Clients with ex post information about the costs and fees associated with the provision of brokerage services once a year. The information provided covers the costs and fees related to brokerage services and financial instruments.

The purpose of this information is to present the total cost incurred in connection with the provided service and financial instruments, as well as the concentrated impact on investment returns.

Trigon Dom Maklerski S.A. conducts brokerage activities in a reliable and professional manner, in accordance with the principles of fair trade and in the best interests of the Clients.

In connection with the provision of brokerage services, the Brokerage House may accept or transmit:

• Fees, commissions, and non-monetary benefits received from the Client or a person acting on their behalf, or transmitted to the Client or a person acting on their behalf;
• Fees or commissions necessary for providing a specific brokerage service to the Client;
• Fees, commissions, and non-monetary benefits to improve the quality of the brokerage service provided to the Client.

Trigon Dom Maklerski S.A. has implemented internal procedures under which the Brokerage House analyzes the benefits transmitted in connection with the execution of brokerage services to ensure their compliance with applicable legal regulations, particularly with regard to their impact on improving the quality of brokerage services provided to Clients, as well as ensuring compliance with Trigon Dom Maklerski S.A.'s obligation to act in a reliable and professional manner and in the best interests of the Client

‍

Details

Information on fees, commissions and non-cash benefits received by employees of Trigon Dom Maklerski S.A. in connection with brokerage services provided to clients [PL]

Information on fees, commissions and non-cash benefits received by employees of Trigon Dom Maklerski S.A. in connection with brokerage services provided to clients [EN}

In accordance with Regulation No 1286/2014 of the European Parliament and of the Council of 26 November 2014 on key information documents for retail collective investment products and insurance investment products (PRIIPs)PRIIP Regulation“) creators of investment instruments whose valuation depends on other assets/instruments (e.g. futures, options, ETFs, structured products) are required to prepare a so-called key information document (KID). KID is a standardized document containing key information about the financial instrument that is the subject of the Client's order.

The KID is drawn up separately for each product, and the uniform format and content of the KID document allows the investor to compare many products offered by different entities in all Member States of the European Union.

The client placing an order for an instrument belonging to the PRIIP category will each time receive a message asking him to confirm his knowledge of the delivered current version of the KID. In the absence of confirmation in orders placed by telephone and via the Internet, the Customer will be able to confirm that he has been informed that the delivery of the KID before placing the order is not possible and may withdraw from placing the order for the time necessary to familiarize himself with the KID but he does not agree to withdraw from placing the order and will familiarize himself with the delivered KID immediately after placing the order. orders.

In this case, the delivery of the KID takes place depending on the consent given for the delivery of the KID document via the website in the form of a link to the KID document, when the consent is granted or with a redirect to the branch of Trigon Domu Maklerskiego S.A. in the absence of such consent.

For instruments listed on the Warsaw Stock Exchange, current documents are published on:

• Derivatives — www.gpw.pl/options-standards-trading-terms
• Structured products — www.gpw.pl/structured-products‍
• ETFs — www.gpw.pl/etfy

This information applies only to Clients that are legal entities.

Every Client that is a legal entity (any entity other than natural persons, not conducting business activities) must have a valid LEI code starting from January 3, 2018. The absence of an LEI code will prevent the submission of orders or instructions.

The LEI requires an annual fee, and failure to pay the fee will result in the code becoming invalid.

‍

2023

Summary of the analysis and conclusions of the detailed monitoring of the obtained quality of order execution in the order execution systems for 2023

Best Execution 2023 Report — Retail Client

Best Execution 2023 Report — Professional Client

2022

Summary of the analysis and conclusions of the detailed monitoring of the obtained quality of order execution in the order execution systems for 2022

Best Execution 2022 Report — Retail Client

Best Execution 2022 Report — Professional Client

2021

Summary of the analysis and conclusions of the detailed monitoring of the obtained quality of order execution in the order execution systems for 2021

Best Execution Report 2021 — Retail Client

Best Execution Report 2021 — Professional Client

2020

Summary of the analysis and conclusions of the detailed monitoring of the obtained quality of order execution in the order execution systems for 2020

Best Execution 2020 Report — Retail Client

Best Execution 2020 Report — Professional Client

2019

Summary of the analysis and conclusions of the detailed monitoring of the obtained quality of order execution in the order execution systems for 2019

Best Execution Report 2019 — Retail Client

Best Execution Report 2019 — Professional Client

2018

Summary of the analysis and conclusions of the detailed monitoring of the obtained quality of order execution in the order execution systems for 2018

Best Execution Report 2018 — Retail Client

Best Execution Report 2018 — Professional Client

Information about the Investment Firm Agent Performing Intermediary Activities on Behalf of Trigon Dom Maklerski S.A.

Trigon Dom Maklerski S.A., with its registered office in Kraków ("Brokerage House"), address: ul. Mogilska 65, 31-545 Kraków, registered by the District Court for Kraków – Śródmieście in Kraków, 11th Economic Division of the National Court Register under KRS number 0000033118, NIP 676-10-44-221, with a fully paid-up share capital of 13,500,000 PLN, operating based on the authorization granted by the Polish Securities and Exchange Commission on November 26, 2002, No. KPWiG 4021-21/2002, informs that:

The company Starfunds sp. z o.o. with its registered office in Poznań ("Agent"), address: ul. Nieszawska 1, 61-021 Poznań, entered into the Register of Entrepreneurs of the National Court Register, maintained by the District Court Poznań – Nowe Miasto i Wilda in Poznań, 8th Economic Division of the National Court Register, under KRS number 0000515685, with a fully paid-up share capital of 759,400 PLN, NIP: 7831714562, acts as an agent of the investment firm and performs the following intermediary activities related to brokerage services on behalf of the Brokerage House:

• Providing information about the products and services of the Brokerage House, including presenting the Brokerage House's portfolio management offer,
• Concluding Investment Agreements,
• Receiving and transmitting orders to the Brokerage House for the purchase or sale of financial instruments,
• Receiving statements concerning the granting, changing, or revoking powers of attorney related to brokerage services provided by the Brokerage House through the Agent and transmitting them to the Brokerage House,
• Recommending the Brokerage House to clients or potential clients of the Agent as an entity providing brokerage services.

A list of employees of Starfunds sp. z o.o. authorized to perform the activities of an investment firm agent on behalf of the Brokerage House is available at the Brokerage House’s office, at the customer service phone numbers: 801 292 292, +48 126 292 292, +48 122 887 878, and via email: bok@trigon.pl.

‍