Markets in Financial Instruments Directive (MiFID)
Notice regarding the implementation of the requirements of REGULATION (EU) 2019/2088 of 27.11.2019
and in conjunction with Art. 75a of the Markets in Financial Instruments Act and § 22 and § 23 of the Final Provisions to the Act Amending and Supplementing the Public Offering of Securities Act (State Gazette, issue 26 of 22.03.2020)
Dear clients,
Further to effective REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 November 2019 on sustainability‐related disclosures in the financial services sector, and the provisions of DIRECTIVE (EU) 2017/828 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2017 amending Directive 2007/36/EC as regards the encouragement of long-term shareholder engagement /Directive (EU) 2017/828/, new European rules are introduced for further encouragement of the effective management and decision-making regarding long-term investments. These rules have been transposed in the Bulgarian legislation by virtue of the Act Amending and Supplementing the Public Offering of Securities Act (“AAS POSA”), published in State Gazette, issue 26 of 22.03.2020.
In accordance with § 22, para. 1 of the Final Provisions to the AAS POSA, a new Art. 75a has been added to the Markets in Financial Instruments Act (MFIA), pursuant to which an investment firm providing the service of managing a portfolio that includes shares of companies with а registered seat in a member state admitted to trading on a regulated market in a member state, shall adopt and publish an Engagement Policy as well as information about its implementation. The requirements regarding the contents of the Engagement Policy are described in Art. 75a, para. 3 of the MFIA. At the same time, a possibility is provided for deviation from this content. Art. 75a, para. 5 allows investment firms to adopt a decision not to apply an engagement policy.
UniCredit Bulbank AD has reviewed the requirements for sustainability-related disclosures in the financial services sector, the established harmonised rules for financial markets participants and financial advisors and for services related to portfolio management, as well as the transparency concerning the integration of sustainability risks and the review of unfavourable impacts on sustainability in their processes and the provision of information related to financial products.
With regard to the above, we would like to inform you that UniCredit Bulbank AD, in its capacity as an investment firm and a credit institution, is not subject to the requirements for disclosure of information related to sustainability in the financial services sector, pursuant to Regulation (EU) 2019/2088, the POSA and the MFIA, due to the fact that it does not provide the service of managing a portfolio that includes shares of companies with а registered seat in a member state admitted to trading on a regulated market in a member state.
Based on the above, UniCredit Bulbank AD does not currently apply an Engagement Policy within the meaning of Art. 75a, para. 1 of the MFIA. In case this circumstance changes, the information will be announced in due time.
Yours sincerely,
UniCredit Bulbank AD
Execution venues
Annual information report on the quality of executed client orders for trade in financial instruments, made in accordance with
COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016.
Dear customers,
In accordance with the requirements of COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016 UniCredit Bulbank AD publishes separate reports on the top execution venues, in terms of trade volumes, as follows:
– The top five execution venues for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB has direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB does not have direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes; /this information report is not obligatory/
– The top five investment firms to which it submitted or sold client orders for execution during the previous year, depending on the class of financial instruments, classified in terms of traded volumes:
The information from the reports is published separately in accordance with the type of client – non-professional and professional
The following information is indicated in the reports:
- the class of the financial instruments;
- the name and identifier of the venue;
- the volume of the client orders executed at the respective execution venue, expressed as a percentage of the total executed volume;
- the number of client orders executed at the respective execution venue, expressed as a percentage of total executed orders; · percentage of the executed orders, which were passive and aggressive orders;
- percentage of orders, which were directed orders;
- a confirmation of whether UCB has executed an average of less than one trade per business day in the previous year in that class of financial instruments.
Short summary of the published reports:
Information summary derived from a comprehensive monitoring of the quality of client order execution achieved by the execution venues, in relation to the requirements of art. 3 of the COMMISSION DELEGATED REGULATION (EU) 2017/576 for 2024.
1. All client orders placed with the Bank were of the ‘’directed order’’ type;
2. UniCredit Bulbank AD is a minority shareholder in the Bulgarian Stock Exchange AD, operator on the Bulgarian Stock Exchange Sofia market;
3. There were no special arrangements with execution venues, regarding the payments that were made or received, discounts, rebates or any received non-monetary benefits;
4. For regulated markets other than Bulgarian Stock Exchange Sofia AD, UniCredit Bulbank AD, in its capacity as an investment firm, submits client orders to brokers for execution, in accordance with the instructions included with the orders.
5. In complying with the requirements an update of the list of execution venues was made, with regard to UniCredit Bulbank AD’s ability to ensure access to the listed execution venues on the basis of arrangements made with third parties.
6. With regard to the type of orders received in the 2024 period – directed order, the execution was performed regardless of the client’s category, strictly adhering to the instructions of the client.
7. The output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU was not used.
Dear customers,
In accordance with the requirements of COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016 UniCredit Bulbank AD publishes separate reports on the top execution venues, in terms of trade volumes, as follows:
– The top five execution venues for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB has direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB does not have direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes; /this information report is not obligatory/
– The top five investment firms to which it submitted or sold client orders for execution during the previous year, depending on the class of financial instruments, classified in terms of traded volumes.
The information from the reports is published separately in accordance with the type of client – non-professional and professional
The following information is indicated in the reports:
· the class of the financial instruments;
· the name and identifier of the venue;
· the volume of the client orders executed at the respective execution venue, expressed as a percentage of the total executed volume;
· the number of client orders executed at the respective execution venue, expressed as a percentage of total executed orders; · percentage of the executed orders, which were passive and aggressive orders;
· percentage of orders, which were directed orders;
· a confirmation of whether UCB has executed an average of less than one trade per business day in the previous year in that class of financial instruments.
Short summary of the published reports:
Information summary derived from a comprehensive monitoring of the quality of client order execution achieved by the execution venues, in relation to the requirements of art. 3 of the COMMISSION DELEGATED REGULATION (EU) 2017/576 for 2023.
1. All client orders placed with the Bank were of the ‘’directed order’’ type;
2. UniCredit Bulbank AD is a minority shareholder in the Bulgarian Stock Exchange AD, operator on the Bulgarian Stock Exchange Sofia market;
3. There were no special arrangements with execution venues, regarding the payments that were made or received, discounts, rebates or any received non-monetary benefits for 2023;
4. For regulated markets other than Bulgarian Stock Exchange Sofia AD, UniCredit Bulbank AD, in its capacity as an investment firm, submits client orders to brokers for execution, in accordance with the instructions included with the orders.
5. In complying with the requirements an update of the list of execution venues was made, with regard to UniCredit Bulbank AD’s ability to ensure access to the listed execution venues on the basis of arrangements made with third parties.
6. With regard to the type of orders received in the 2023 period – directed order, the execution was performed regardless of the client’s category, strictly adhering to the instructions of the client.
7. The output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU was not used.
Execution venues
Annual information report on the quality of executed client orders for trade in financial instruments, made in accordance with
COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016.
Dear customers,
In accordance with the requirements of COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016 UniCredit Bulbank AD publishes separate reports on the top execution venues, in terms of trade volumes, as follows:
– The top five execution venues for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB has direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB does not have direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes; /this information report is not obligatory/
– The top five investment firms to which it submitted or sold client orders for execution during the previous year, depending on the class of financial instruments, classified in terms of traded volumes:
The information from the reports is published separately in accordance with the type of client – non-professional and professional
The following information is indicated in the reports:
· the class of the financial instruments;
· the name and identifier of the venue;
· the volume of the client orders executed at the respective execution venue, expressed as a percentage of the total executed volume;
· the number of client orders executed at the respective execution venue, expressed as a percentage of total executed orders; · percentage of the executed orders, which were passive and aggressive orders;
· percentage of orders, which were directed orders;
· a confirmation of whether UCB has executed an average of less than one trade per business day in the previous year in that class of financial instruments.
Short summary of the published reports:
Information summary derived from a comprehensive monitoring of the quality of client order execution achieved by the execution venues, in relation to the requirements of art. 3 of the COMMISSION DELEGATED REGULATION (EU) 2017/576 for 2022.
1. All client orders placed with the Bank were of the ‘’directed order’’ type;
2. UniCredit Bulbank AD is a minority shareholder in the Bulgarian Stock Exchange AD, operator on the Bulgarian Stock Exchange Sofia market;
3. There were no special arrangements with execution venues, regarding the payments that were made or received, discounts, rebates or any received non-monetary benefits;
4. For regulated markets other than Bulgarian Stock Exchange Sofia AD, UniCredit Bulbank AD, in its capacity as an investment firm, submits client orders to brokers for execution, in accordance with the instructions included with the orders.
5. In complying with the requirements an update of the list of execution venues was made, with regard to UniCredit Bulbank AD’s ability to ensure access to the listed execution venues on the basis of arrangements made with third parties.
6. With regard to the type of orders received in the 2022 period – directed order, the execution was performed regardless of the client’s category, strictly adhering to the instructions of the client.
7. The output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU was not used.
Execution venues
Annual information report on the quality of executed client orders for trade in financial instruments, made in accordance with
COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016.
Dear customers,
In accordance with the requirements of COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016 UniCredit Bulbank AD publishes separate reports on the top execution venues, in terms of trade volumes, as follows:
– The top five execution venues for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB has direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB does not have direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes; /this information report is not obligatory/
– The top five investment firms to which it submitted or sold client orders for execution during the previous year, depending on the class of financial instruments, classified in terms of traded volumes:
The information from the reports is published separately in accordance with the type of client – non-professional and professional
The following information is indicated in the reports:
· the class of the financial instruments;
· the name and identifier of the venue;
· the volume of the client orders executed at the respective execution venue, expressed as a percentage of the total executed volume;
· the number of client orders executed at the respective execution venue, expressed as a percentage of total executed orders; · percentage of the executed orders, which were passive and aggressive orders;
· percentage of orders, which were directed orders;
· a confirmation of whether UCB has executed an average of less than one trade per business day in the previous year in that class of financial instruments.
Short summary of the published reports:
Information summary derived from a comprehensive monitoring of the quality of client order execution achieved by the execution venues, in relation to the requirements of art. 3 of the COMMISSION DELEGATED REGULATION (EU) 2017/576 for 2021.
1. All client orders placed with the Bank were of the ‘’directed order’’ type;
2. UniCredit Bulbank AD is a minority shareholder in the Bulgarian Stock Exchange AD, operator on the Bulgarian Stock Exchange Sofia market;
3. There were no special arrangements with execution venues, regarding the payments that were made or received, discounts, rebates or any received non-monetary benefits;
4. For regulated markets other than Bulgarian Stock Exchange Sofia AD, UniCredit Bulbank AD, in its capacity as an investment firm, submits client orders to brokers for execution, in accordance with the instructions included with the orders.
5. In complying with the requirements an update of the list of execution venues was made, with regard to UniCredit Bulbank AD’s ability to ensure access to the listed execution venues on the basis of arrangements made with third parties.
6. With regard to the type of orders received in the 2021 period – directed order, the execution was performed regardless of the client’s category, strictly adhering to the instructions of the client.
7. The output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU was not used.
Annual information report on the quality of executed client orders for trade in financial instruments, made in accordance with
COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016.
Dear customers,
In accordance with the requirements of COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016 UniCredit Bulbank AD publishes separate reports on the top execution venues, in terms of trade volumes, as follows:
– The top five execution venues for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB has direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB does not have direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes; /this information report is not obligatory/
– The top five investment firms to which it submitted or sold client orders for execution during the previous year, depending on the class of financial instruments, classified in terms of traded volumes:
The information from the reports is published separately in accordance with the type of client – non-professional and professional
The following information is indicated in the reports:
· the class of the financial instruments;
· the name and identifier of the venue;
· the volume of the client orders executed at the respective execution venue, expressed as a percentage of the total executed volume;
· the number of client orders executed at the respective execution venue, expressed as a percentage of total executed orders; · percentage of the executed orders, which were passive and aggressive orders;
· percentage of orders, which were directed orders;
· a confirmation of whether UCB has executed an average of less than one trade per business day in the previous year in that class of financial instruments.
Short summary of the published reports:
Information summary derived from a comprehensive monitoring of the quality of client order execution achieved by the execution venues, in relation to the requirements of art. 3 of the COMMISSION DELEGATED REGULATION (EU) 2017/576 for 2020.
1. All client orders placed with the Bank were of the ‘’directed order’’ type;
2. UniCredit Bulbank AD is a minority shareholder in the Bulgarian Stock Exchange AD, operator on the Bulgarian Stock Exchange Sofia market;
3. There were no special arrangements with execution venues, regarding the payments that were made or received, discounts, rebates or any received non-monetary benefits for 2020;
4. For regulated markets other than Bulgarian Stock Exchange Sofia AD, UniCredit Bulbank AD, in its capacity as an investment firm, submits client orders to brokers for execution, in accordance with the instructions included with the orders.
5. In complying with the requirements an update of the list of execution venues was made, with regard to UniCredit Bulbank AD’s ability to ensure access to the listed execution venues on the basis of arrangements made with third parties.
6. With regard to the type of orders received in the 2020 period – directed order, the execution was performed regardless of the client’s category, strictly adhering to the instructions of the client.
7. The output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU was not used.
Dear customers,
In accordance with the requirements of COMMISSION DELEGATED REGULATION (EU) 2017/576 of 8 June 2016 UniCredit Bulbank AD publishes separate reports on the top execution venues, in terms of trade volumes, as follows:
– The top five execution venues for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB has direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes;
– The top five execution venues to which UCB does not have direct access for all executed orders of clients during the previous year, depending on the class of financial instruments, which instruments have been classified in terms of traded volumes; /this information report is not obligatory/
– The top five investment firms to which it submitted or sold client orders for execution during the previous year, depending on the class of financial instruments, classified in terms of traded volumes.
The information from the reports is published separately in accordance with the type of client – non-professional and professional
The following information is indicated in the reports:
· the class of the financial instruments;
· the name and identifier of the venue;
· the volume of the client orders executed at the respective execution venue, expressed as a percentage of the total executed volume;
· the number of client orders executed at the respective execution venue, expressed as a percentage of total executed orders; · percentage of the executed orders, which were passive and aggressive orders;
· percentage of orders, which were directed orders;
· a confirmation of whether UCB has executed an average of less than one trade per business day in the previous year in that class of financial instruments.
Short summary of the published reports:
Information summary derived from a comprehensive monitoring of the quality of client order execution achieved by the execution venues, in relation to the requirements of art. 3 of the COMMISSION DELEGATED REGULATION (EU) 2017/576 for 2019.
1. All client orders placed with the Bank were of the ‘’directed order’’ type;
2. UniCredit Bulbank AD is a minority shareholder in the Bulgarian Stock Exchange AD, operator on the Bulgarian Stock Exchange Sofia market;
3. There were no special arrangements with execution venues, regarding the payments that were made or received, discounts, rebates or any received non-monetary benefits for 2019;
4. For regulated markets other than Bulgarian Stock Exchange Sofia AD, UniCredit Bulbank AD, in its capacity as an investment firm, submits client orders to brokers for execution, in accordance with the instructions included with the orders.
5. In complying with the requirements an update of the list of execution venues was made, with regard to UniCredit Bulbank AD’s ability to ensure access to the listed execution venues on the basis of arrangements made with third parties.
6. With regard to the type of orders received in the 2019 period – directed order, the execution was performed regardless of the client’s category, strictly adhering to the instructions of the client.
7. The output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU was not used.