This Policy is issued pursuant to, and incompliance with, Canadian Investment Regulatory Organization (“CIRO”) Rules3119-3129 concerning best execution of client orders and National Instrument23-101 Trading Rules (“NI 23-101”). In relation to order execution,IntelligentInvesting Securities Inc.(“”IISI” or “we”) is required to obtain themost advantageous execution terms reasonably available under the circumstanceswhen executing client orders. IISI isrequired to take into account a range of execution factors and determine theirrelative importance based on the characteristics of our clients, the ordersthat we receive and the markets in which we operate. As a non-executing CIRODealer Member, IISI engages another Dealer Member to provide execution serviceson its behalf.
This Policy applies to trading on behalf ofclients conducted on IISI’s app-basedOEO trading platform, and includes all securities traded on that platform.
Best Execution represents IISI ’sobligation to seek the most advantageous execution terms reasonably availableunder the circumstances when executing a transaction on your behalf. We willconsider execution factors such as price, speed, likelihood of execution &settlement, and costs.
IISI has entered into a routing agreement with Independent Trading Group Inc.(“ITG”), a CIRO Dealer Member. Pursuant to that routing agreement, IISI ispermitted to electronically transmit orders through ITG’s order managementsystems for automatic onward transmission to marketplaces and executiondestinations. IISI has reviewed ITG’s Best Execution Policy and has determinedthat it is a reasonable best execution policy, designed to comply with CIRORules relating to best execution and NI 23-101. ITG’s best execution policyincorporates trade-through protections for protected Marketplaces (the OrderProtection Rule, or “OPR”) as prescribed by NI 23-101. As prescribed by OPR,ITG connects to all “protected” marketplaces, and in the interest of providingadditional sources of liquidity and ensuring best execution, ITG connects toand considers quotes from all Canadian marketplaces (both protected andunprotected) when routing its client orders. ITG uses smart order routers thatcheck for better prices on all marketplaces and alternative trading systems(“ATSs”), including dark liquidity sources, before executing an order.
Orders for Canadian-listed securities maybe executed by ITG on the listing exchange, an ATS which trades the security,or on a foreign organized regulated market. Trade confirmations issued to IISIwill indicate whether some or all of an order executed on multiple marketplacesin Canada, the United States or both. Additional details, such as themarketplace of execution for each underlying trade, are available to IISI byITG upon request.
Orders submitted after 5:00 p.m. EST priorto 8:30 a.m. EST will be queued and executed between 8:30 a.m. EST and 5:00p.m. EST.
The “Primary Marketplace” for allsecurities listed on the Toronto Stock Exchange, TSX Venture Exchange, CanadianSecurities Exchange or Aequitas NEO Exchange, will be the exchange on which thesecurity is listed, whether or not the security is trading on other alternatemarketplaces.
IISI may also route trades to otherexecuting brokers, including National Bank Financial Inc. (whose Best ExecutionPolicy can be found here) and CI Investment Services (whose Best ExecutionPolicy can be found here). IISI has determined that these best executionpolicies are likely to effectively achieve best execution for IISI’s clients.
All orders will be routed to either thePrimary Marketplace or alternative marketplaces as follows, unless IISIprovides ITG with specific instructions:
Market Orders are executed upon entry to amarketplace at the best available request or bid price.
Limit Orders will be executed at or better than a specified maximum or minimum price set by IISI, as specified by IISI’s client. If a limited order is not immediately executable, ITG will route this order to a marketplace. These orders will remain on the market until the order is filled, corrected, canceled, or expired.
Each of the Canadian marketplaces supports a variety of order types and features. These include order types or designations required by the regulators, as well as types or designations which impact how an order may trade. A summary document which outlines the order types and features available at each trading venue is available to IISI’s clients upon request.
IISI will review its best execution policy and procedures at a minimum annually, and specifically whenever there is a material change to the trading environment or market structure that may impact IISI’s ability to achieve best execution for its clients, such as the launch of a new market or a material change to the functionality of an existing market.
In the annual review, IISI considers thefollowing:
An annual review of ITG’s best execution policies and procedures relevant to IISI is performed to ensure they continue to provide reasonable assurance of the best execution of IISI client orders. A review may be called outside of the annual review if IISI receives notice of any material changes to those policies and procedures or becomes aware of any material changes to the best execution rules governing the correspondent broker.
IISI obtains an annual attestation from ITG that it has complied with and tested its policies and procedures on best execution in accordance with CIRO Rules 3119 through 3129. If IISI identifies trade execution results that are inconsistent with ITG’s best execution disclosure, it will follow up with ITG and document the results of its inquiry.
Like all brokers, IISI is incentivized tominimize its trading costs. Unlike many brokers, IISI does not charge itsclients commission to trade on the IISI platform. ITG offers IISI an attractivecost structure for trading through it. This may incentivize IISI to prefer ITGover other executing brokers. To control this potential conflict, IISIevaluates ITG’s execution against objective criteria on an annual basis inorder to ensure that the execution it provides constitutes the best executionas defined by applicable CIRO Rules.