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

NNEK takes all reasonable measures to achieve the best result for its customers in case of orders. In doing so, NNEK follows its order execution policy. This order execution policy describes how NNEK will try to achieve the best possible result for you when we place orders with or transmit orders to third parties for execution on your behalf. When you enter into an agreement concerning your investments with NNEK, you agree to our order execution policy.

NNEK considers the following criteria important for optimal order execution: price, cost, speed, likelihood of execution and settlement, size, nature and all other aspects relevant to order execution.

For both listed and unlisted investment funds (as referred to in subparagraph c of the definition of 'financial instrument' in Article 1:1 of the Financial Supervision Act), given the above criteria, buying and selling orders are in principle sent to the administration office selected by the fund provider. Settlement will in principle take place on the basis of the net asset value of the fund. The selected administration office may charge fees, for example when exchanging currencies. Normally, it is only possible to trade once a day at the net asset value applicable on that day.

In order for clients to enter and exit, the fund incurs costs. This is because the fund has to buy or sell investments. The fund is entitled to pass on these costs to clients who enter and exit. The clients pay these costs through a mark-up or markdown on the price. The price then becomes slightly higher or lower than the actual value of the fund. Normally, trading can be done only once a day at the net asset value prevailing on that day. In the case of listed investment funds, if possible, an order is sent directly to the administration office selected by the fund provider.

In case an order is to be executed through a regulated market, NNEK -given the above criteria- has selected Saxo Bank, a trading name of BinckBank N.V., a Dutch bank which is part of the Saxo Bank Group, with a banking licence, covered by the Dutch deposit guarantee scheme ("Saxobank") and InsingerGilissen N.V. ("InsingerGilissen") as order executing parties.

In the case of orders in financial instruments other than investment funds, NNEK -given the above criteria- selected Saxobank and InsingerGilissen as order executing parties.

The main criteria underlying the choice of Saxobank and InsingerGilissen are price, speed and quality of order execution and service level. Saxobank and InsingerGilissen have an independent legal obligation to take all reasonable measures to achieve the best possible result for their clients. Saxobank and InsingerGilissen have order execution policies to which NNEK conforms. The order execution policies of Saxobank and InsingerGilissen are attached to this order execution policy of NNEK.

Client orders in the same type of instrument will in most cases be aggregated. If an aggregated order from several clients is only partially executed, the executed volume will be divided pro rata among the clients in the order.

Orders, from customers holding an investment account with the investor giro, will first be netted off against the orders of other investment account holders with the investor giro. To the extent that an order remains after netting, it will be executed in accordance with this order execution policy. When securities can only be traded in whole units or only with a minimum trading volume, a transaction may result in a residual position which NNEK's investor giro holds in a rounding account. In a subsequent order, the residual position may first be settled in the rounding account before the order is offered to the fund provider's administration office or on a regulated market.

The price determined for a transaction mentioned above is equal to the price established for the relevant fund on the relevant day through the fund provider or on a regulated market.

Annually, NNEK evaluates the effectiveness of the Saxobank and InsingerGilissen order execution policies, or as much earlier if there is a material change in the Saxobank or InsingerGilissen order execution policies. NNEK also evaluates annually whether the choice of Saxobank and InsingerGilissen still leads to the best possible result for NNEK's clients.

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

This order execution policy was last reviewed and updated in November 2022.