Order execution policy

Learn how your orders are transmitted and executed.

  • This order execution policy summarises the steps that NNEK, the firm who manages your investments, takes to execute your orders.
  • This policy is important as NNEK wishes to obtain the best possible results for you.
  • The aim is to ensure that your orders are transmitted and executed promptly.
  • More information can be found on NNEK's website (only in Dutch).

The policy

When executing orders, NNEK takes all reasonable measures to achieve the best possible result for its clients. This order execution policy describes the method of order execution and how NNEK will try to achieve the best possible result for you when we pass on orders to third parties for execution. By entering into an agreement with NNEK regarding your investments, you agree to our order execution policy.

NNEK classifies its clients as non-professional investors. NNEK only passes on orders for its clients in both listed and unlisted investment funds (including ETFs, also known as trackers). NNEK considers the following criteria to be important for the optimal execution of orders: price, costs, speed, the likelihood of execution and settlement, the size, the nature and all other aspects relevant to the execution of the order.

Method of order execution

First, orders from clients who hold an investment account with the investors' giro are balanced with the orders of other holders of an investment account with the investors' giro. The price determined for a transaction as described above is equal to the price established for the relevant investment fund on the relevant day via the investment fund provider or on a regulated market. Any order remaining after netting is executed in accordance with the provisions of this order execution policy.

If securities can only be traded in whole units or with a minimum trading volume, a residual position may arise in a transaction, which the Investors' Giro will hold in a rounding account. In the case of a subsequent order, the residual position in the rounding account may first be settled before the order is passed on for execution to the administrative office of the investment fund provider or to another party selected by NNEK.

For both listed and unlisted investment funds (as referred to in sub c of the definition of “financial instrument” in Article 1:1 of the Financial Supervision Act), the above criteria mean that, in principle, purchase and sale orders are sent to the administration office selected by the investment fund provider. Settlement is in principle based on the net asset value of the investment fund. The selected trust office may charge costs, for example when exchanging currencies. Normally, trades can only be executed once a day at the net asset value applicable on that day. An investment fund has a custodian that is responsible for the custody and administration of the securities held by the investment fund.

An investment fund incurs costs when customers enter and exit the fund, as the investment fund must then buy or sell investments. The investment fund is entitled to pass on these costs to the customers who enter and exit the fund. Customers pay these costs via a surcharge or discount on the price. The price then becomes slightly higher or lower than the actual value of the investment fund.

In the case of orders in both listed and unlisted investment funds offered by InsingerGilissen Asset Management B.V., NNEK InsingerGilissen N.V. (hereinafter: ‘InsingerGilissen’), a trading name of and therefore part of Quintet Private Bank (Europe) S.A. InsingerGilissen, as the party to pass on the orders. These investment funds are tradable once a day at the price issued by the manager on that day.

In the case of all other orders in investment funds that must be executed via a regulated market, NNEK has selected InsingerGilissen as the preferred party to pass on the orders, taking into account the above criteria. InsingerGilissen offers a wide range of both markets and products, so that orders can in principle always be executed. In order to guarantee the best possible execution of orders, NNEK opts in principle for market orders.

NNEK may also choose to pass on an order that must be executed via a regulated market to Saxo Nederland, which is part of Saxo Bank A/S (hereinafter: ‘Saxo’). Saxo offers a wide range of markets and products, so that orders can in principle always be executed. In order to guarantee the best possible execution of orders, NNEK opts in principle for market orders.

The main criteria underlying the choice of InsingerGilissen and Saxo are price, speed and quality of order execution and level of service. NNEK has a long-standing relationship with both InsingerGilissen and SAXO and is therefore well acquainted with their order execution arrangements and procedures. InsingerGilissen and SAXO each have an independent legal obligation to take all reasonable measures to achieve the best possible result for their clients. InsingerGilissen and SAXO each have an order execution policy with which NNEK complies in this order execution decision. The order execution policies of InsingerGilissen and SAXO are attached to this order execution policy of NNEK.

Orders from clients in the same type of instrument will in most cases be aggregated. If an aggregated order from multiple clients is only partially executed, the executed volume will be distributed pro rata among the clients in the order.

NNEK evaluates the effectiveness of the order execution policy of InsingerGilissen and SAXO annually, or sooner if there is a material change in the order execution policy of InsingerGilissen or SAXO. NNEK also evaluates annually whether the choice of InsingerGilissen or SAXO still leads to the best possible result for NNEK's clients.

NNEK's most recent order execution policy is always available at www.nnek.nl.

This order execution decision was last evaluated and updated in May 2025.