Information under Delegated Regulation (EU) 2017 /576

Capman in its capacity as an investment intermediary has adopted a policy for its clients for the execution of their orders. When executing client orders, the intermediary takes into account the following factors:


  • Customer characteristic
  • Characteristics of the place of performance
  • Best opportunity of price realization when ordering
  • Implementation costs
  • Execution speed
  • Probability of execution
  • Order amount

The intermediary has direct access to two regulated markets in the Republic of Bulgaria: BSE-Sofia and MTF Sofia and foreign markets.

  • Relationships and conflicts of interest in relation with the execution of client orders

Capman is the organizer of MTF Sofia and as such does not carry out operations on this market for his own account.

When transmitting orders to foreign markets, Capman does not receive remuneration from the accepting broker.

  • Capman executes orders on the markets that are considered basic for the given financial instrument, and where this is unavailable – on the market where the instrument realizes the largest volume and has the highest density of orders.
  • Capman does not define a different approach when targeting a market for the execution of client orders when none is specified by the client.
  • In 2020, there has been no change in the execution locations included in Capman’s client order execution policy.
  • Capman does not treat its clients differently based on their categorization.
  • In the case of operations for clients when they have not indicated a market of execution, the intermediary also takes into account the specifics of tax treatment of transactions in the Republic of Bulgaria.
  • Capman performs daily monitoring of its trading systems and order transmission channels.