The MiFID

The Markets in Financial Instruments Directive (MiFID) is a European Union Directive implemented in Cyprus as of the 1st of November 2007, which provides a harmonized regulatory regime for investment services across the European Economic Area. The main objectives of the Directive are to increase competition and consumer protection in investment services.

1) CLIENT CATEGORISATION

a) "Retail" clients (highest levels of protection)
b) "Professional clients"
c) "Eligible Counterparties"

a) Retail client is every other client except a Professional Client.
Clients classified as Retail clients have the highest level of investor protection. In order to provide proper protection to Retail client, WINDSOR shall, prior to providing any service, request information about the client's market knowledge and experience regarding a specific type of product. Should the client wish to carry out a transaction that WINDSOR does not believe to be appropriate, taking into account the client's knowledge and experience, client may be advised but will not be limited to trading. Status as a Retail client also requires a right to receive information whereas WINDSOR will inform the client about the financial instruments in question and the risks relating to these, the trading systems and marketplaces WINDSOR uses, and the costs of transactions.

Opportunity to be reclassified
Retail clients may request, in writing, to be treated as Professional clients provided more detailed conditions are met. Such a reclassification results a lower level of investor protection.

The fitness test
Retail client can be treated as a professional client if he meets at least two of the following requirements:
1. the client has carried out transactions, in significant size, on the relevant market at an average frequency of 10 per quarter over the previous four quarters,
2. the size of the client's financial instruments portfolio, defined as including cash deposits and financial instruments, exceeds EURO 500,000,
3. the client works or has worked in the financial sector for at least one year in a professional position, which requires knowledge of the transactions or services envisaged

b) Professional Client
Professional client is a client who is presumed to possess market knowledge and experience and is capable of making his own investment decisions and understands the risks involved. Professional client receives a lower level of protection than the retail client.

b1) Entities authorized or regulated to operate in the financial markets and are regarded as professionals in relation to all investment services and activities and financial instruments:
• Credit institutions;
• Investment firms;
• Other authorized or regulated financial institutions;
• Insurance undertakings;
• Collective investment schemes and management companies of such schemes;
• Pension funds and management companies of such funds;
• Commodity and commodity derivatives dealers;
• Local entities;
• Other institutional investors.

b2) Large undertakings can also be classified as professional clients if they meet at least two of following requirements:
• Balance sheet total minimum EUR 20,000,000
• Net turnover minimum EUR 40,000,000
• Own capital minimum EUR 2,000,000
b3) National or regional governments, central banks, International Monetary Fund or similar international organizations.

Professional clients are responsible to keep WINDSOR continuously informed of any change that may affect their classification.

Opportunity to be reclassified
Professional clients may request, in writing, to be reclassified as Retail clients, therefore achieve a higher level of investor protection, or as eligible counterparties, therefore achieve a lower level of investor protection.
It is the professional client's duty to request a higher level of protection when the client feels unable to make a correct risk assessment.
Professional clients that are legal entities may also request to be reclassified as eligible counterparties.

c) Eligible Counterparty (ECP)
An Investment Firm authorized to receive and transmit orders or/and to execute orders on behalf of clients or/and to deal on own account, may bring about or enter into transactions with Eligible Counterparties. Eligible Counterparties are considered the entities that fall within a category of Professional clients.
Eligible counterparties receive the lowest level of protection whereas WINDSOR is not required to apply the 'best execution' rules.

Opportunity to be reclassified
Eligible counterparties may request, in writing, to be reclassified as professional clients therefore achieve a higher level of investor protection.

Note: WINDSOR is not obliged to agree with clients' request to reclassify their account status.

2) BEST EXECUTION:

Windsor takes all reasonable steps to obtain, when executing orders, the best possible result for its clients taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.