I. General Information Corresponding to PEGASUS SECURITIES INVESTMENT SERVICES S.A.  

II. The Policy of Identifying and Managing Conflicts of Interest  

III. Risks of Investments in Financial Instruments  

IV. Company Measures for Safeguarding the Clients’ Financial Instruments & Assets held by the Company  

V. Charges & Commissions  

VI. Orders’ Execution Policy  

Individual Clients  

Customers that fall under the category of Individual Clients are provided with the highest degree of protection as to the implementation of professionalism during the course of investment services’ provision, as well as in relation to the terms dictating the Clients’ execution of orders.  

A Client formerly classified as “individual”, with terms & provisions of article 3 par. 3 of Law 3606/2007 being in force, who wishes to change its categorization as he/she considers that our Company could perceive him/her as a “professional client” on one or more types on investment or products or transactions, or one or more investment services, will have to contact our Company and file a relevant written petition, in order for our Company to examine whether conditions set by law are, indeed, met. In every case, even if conditions set by law are met in order for the Client to be classified as professional, our Company holds the right to deny the Client’s petition, especially if it considers – bearing in mind the content of transactions the Client wishes to make and the investment services that he/she will be provided – that the lessening of the degree of protection the Client would receive would not be in accordance to the Client’s experience, expertise and knowledge on issues relating to investment decisions.  

Should the Client be classified as “professional”, the lessening of the degree of protection he/she is provided will concern the following:
*Our Company will have limited obligations as to the provision of pre-transactional information. Our Company, in particular:

a) Will inform the Client with limitations as to i) the characteristics and risks of the financial instruments traded by the Client and ii) the ways of keeping and securing Clients’ financial instruments by our Company or, where this is possible, by a third party.

b) Will not inform the Client beforehand on i) the charges of services provided and the transactions completed through the Company, ii) our Company, in general, iii) the kind of services our Company is licensed to provide, iv) the way that the Client-Company correspondence is implemented and v) the policies set and applied by our Company in order to prevent situations of conflict of interests, with the exception (as to aforementioned point iv) of the Client having submitted to our Company a relevant written petition.

* Whenever an evaluation of the compatibility or appropriateness of a transaction of a financial product or service in relation to the Client is necessitated, our Company will be in position to consider as given that the Client holds the necessary experience, expertise and knowledge in order to comprehend the risks involved (and which are relevant to the type of transactions made by the Client that the latter has asked to be considered as “professional”).
* Our Company holds the right to apply to professional investors different orders’ execution policy than the one applied to individual investors.
* Our Company is not obligated to send the professional client an analytical statement as to the Client’s executed orders, in contrary to the information sent to individual clients, which takes place a working day after the transaction at the latest.  

Conditions of article 7, par. 3 of Law 3606/2007  

Prior to accepting the resignation from the degree of protection provided to individual clients, an investment firm is obliged to take any possible measure in order to confirm that the Client wishes to be treated as professional and that he/she indeed fulfills at least two of the below-mentioned criteria:

(a) The Client has performed in the relevant market on a quarterly basis an average of ten (10) transactions of an adequate volume, during the course of the last four quarters,

(b) The Client’s portfolio, including the cash and financial instruments held, is worth more than five hundred thousand euros (€ 500,000),

(c) The Client holds or held for a period of one (1) month at least a financial institution position that requires knowledge of scheduled transactions or services.  

Professional Clients  

Customers that fall under the category of Professional Clients, some of the terms of the investment firms’ professionalism provisions are not in force, as they have been set in order to provide protection to individual (non-professional) clients and mainly relate to the pre-transactional as well as to the post-transactional information provided to them. 

A Client that has been classified as Professional holds the right to file a petition in order to change his/hers categorization in order to achieve higher levels of degree protection, as to one or more kinds of financial instruments or transactions in one or more investment services. In every case, our Company holds the right to deny the Client’s petition.  

Should during the course of the Client’s co-operation with our Company, Client-related data change, thus possibly affecting the Client’s categorization and his “Professional” status – indicatively, not to belong in any of the categories of Professional Clients mentioned below –, the Client should timely inform our Company in writing.  

ΚΑΤΑΛΟΓΟΣ ΕΠΑΓΓΕΛΜΑΤΙΩΝ ΠΕΛΑΤΩΝ  

Under Law 3606/2007, professional clients for every type of investment service & activity and for every financial instrument are considered to be the following clients:

a) The below-mentioned companies obliged to hold a license of operations or mandatory liable to auditing procedures and rules in order to perform specific operations in financial markets, irrespective of whether they hold a license of operations from a country-member in accordance and compliance with the EU legislation, or hold a license and are liable to auditing procedures & rules of a county-member without to an EU directive, or companies that hold licenses or are liable to auditing procedures & rules of a third country:

i) Credit institutions,

ii) Investment firms,

iii) Other financial institutions,

iv) Insurance companies,

v) Mutual funds and their managing companies,

vi) Pension funds and their managing companies,

vii) Commodities exchanges and derivatives markets’ delegates,

viii) Local companies, usually acting as investment firms’ intermediaries,

ix) Portfolio investment companies and institutional investors.

b) Large corporations who satisfy at least two of below-mentioned size criteria:  

• Total balance sheet figures standing at 20,000,000 euros,
• Turnover standing at 40,000,000 euros,
• Total equity standing at 2,000,000 euros.

 c) National and Peripheral governments, state authorities that manage the public deficit, central banks, international organizations as the World Bank, the International Monetary Fund, the European Central Bank and the European Investment Bank.

d) Other institutional investors whose main activity is investment on financial instruments, including entities whose exclusive scope of operations is the securitization of assets or other financial transactions.

Chosen Counterparties