Order Execution Policy
Treating Customers Fairly is central to our corporate culture and ethics. We have a duty to act honestly, fairly, professionally and in the best interests of our clients when dealing with them.
In relation to order execution, we are required to take all sufficient steps to obtain the best possible result when executing client orders or when transmitting orders to other entities or venues to execute. We understand the best possible result as being the one that delivers the best possible overall price for clients (including costs) within the soonest possible execution timeframe.
When you enter into any order to Buy or Sell a CFD on our online trading platforms, you trade with us as your counterparty. LPS acts as a market maker and we are the Principal to each trade that you enter. This means that:
We are always the counterparty to your transactions. You may only close each position you trade in with us.
Your position is not transferable to any other regulated investment firm. This is a major difference to when you trade for example in Shares. In such cases, you can move your holding in Shares to be traded through another investment firm – broker. In CFDs, you can only trade / close your position with the investment firm– broker you initially opened your position with.
If you make profits on your trading, we lose. If you register losses on your trading, this means we profit.
Our Prices And Where We Source These From
We quote a two-way price for each CFD we offer. This two‐way price consists of a Bid (the lower price which is the price at which you as a client may “Sell” the CFD) and an Ask (higher price which is the price at which you as the client may “Buy” the CFD). The difference between our Bid and our Ask price is commonly referred to as our “Spread”. We aim to ensure our Spreads contribute towards delivering competitive Bid and Ask prices to you. The Spread includes our costs for the services we provide to you.
Our Spreads are variable. A variable Spread means that the Spread will vary throughout the day, depending on market volatility and available liquidity. They represent the best bid and ask prices we are able to obtain from our liquidity providers, underlying regulated markets or other data feed providers.
The Spread is in effect your cost for opening a new position/placing a new order. There are no extra commissions charged.
Best Execution is the process by which LPS seeks to obtain the best possible result when executing client orders. The definition of best possible result will vary as we may take into account a range of execution factors and determine their relative importance based on the characteristics of the respective client, the order size, the orders that we receive and the underlying Financial Instruments for which we offer trading on Contracts for Difference. Prices and costs carry the highest importance when executing transactions for our clients.
When LPS executes orders on behalf of clients, Best Execution is determined based on the total consideration paid to or by the client, unless the objective of execution of the order dictates otherwise. Total consideration is the price of the CFD in the underlying Financial Instrument and the costs related to the execution of the order, including all expenses incurred by the client which are directly related to the execution of the order such as venue execution fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. When assessing whether the best execution has been achieved, LPS does not take account of its standard charges that will be paid by the client irrespective of how the order is executed.
Although we take all reasonable efforts, where we use an external counterparty as our liquidity provider, we will not be obliged to enter into any transaction with the client if in doing so we may be at risk of exceeding the liquidity available to us in the underlying market. For larger transactions, we may add an additional mark up or mark down and/or charges to our prices. If a client undertakes repeated transactions, LPS will view them on a cumulative basis for the purpose of determining such additional mark up and/or charges.
Investing in CFDs with an underlying asset listed in a currency other than your base currency entails a currency risk. Due to the fact that when the CFD is settled in a currency other than your base currency, the value of your return may be affected by its conversion into the base currency.
Overnight Rollover (Swap)
In addition to charges defined in the Agreement, Clint is imposed to a daily overnight rollover charge which applies to each open position if it is held overnight. The overnight rollover is charged daily on all positions left open. The method of calculation of the overnight charge varies according to the type of underlying asset or Financial Instrument to which the CFD applies. Moreover, the amount of the overnight charge will vary between different assets as it is linked to interest rates related to each asset and in addition to an extra financing charge defined by us.
Execution Venues are the entities with which the orders are placed or to which the Company transmits orders for execution. For the purposes of the orders submitted to the Company by the client, as mentioned above, the Company always acts as Principal on the client’s behalf. Even where the Company transmits the orders for execution to third party liquidity providers, the Company remains the sole counterparty to your trades. Therefore, the Firm is the sole Execution Venue for clients’ orders.
By accepting this Policy, the client acknowledges that the orders placed with the Company are not undertaken or executed on a regulated market or multi-lateral trading facility (MTF) but are executed on an Over the Counter (“OTC”) basis through the Company’s trading platform and, accordingly, the client may be exposed to greater risks.
Small Investor Information Policy
The Company shall provide the client with the information on the following:
- time and venue of the order receipt, changes and withdrawal of the order;
- acceptance and rejection of the order execution, listing the reasons for the order rejection immediately after the order receipt, not later than the following working day from the day of the order receipt/rejection.
Information on Financial Instrument Protection
The Company can use financial instruments from a client’s account only upon the client’s order.
The Company has established the adequate systems for the protection of client’s ownership rights, by which the use of client’s financial instruments for account of the Company or for the account of other clients is disabled, except with an explicit client’s consent:
financial instrument accounts of the Company are separated from the clients’ accounts;
clients’ financial instruments are not the ownership and part of the Company’s assets and cannot be used for paying the obligations of the Authorized bank to the fiduciary;
clients’ financial instruments can neither be included in the liquidity and bankruptcy estate of the Company, nor used for paying its obligations;
the Company cannot pledge or alienate Financial instruments owned by the client, without his/her previous written authorization,
the Company cannot:
execute the clients’ orders in the manner which is not in accordance with the Law and act of the Commission, and the acts of the regulated market or MTP
buy, sell or borrow the same financial instruments, for its own account, that are the subject of the client’s order before acting according to the client’s order.
The Company is obliged to keep the records, receipts and correspondence concerning the client, accurately and precisely, and to adjust them regularly with the records and receipts of the third parties that hold the clients’ assets, to keep them in such a way to be able, in every moment and immediately, to differentiate the assets of one client from the assets of other clients and the assets of the very Company, when the assets of the client are kept on the clients’ account.
Client Categorization Policy
This policy stipulates the Terms and Conditions of the Investment Company (hereinafter: Company) in regard of getting the investors familiar with all businesses concerning financial instruments, that the Company performs; client categorization and the level of investor protection when it comes to their categorization; possibilities of asking to be moved to the other category, thus, the risks of investments for specific types of financial instruments, all with regard to their knowledge, experience and the financial situation.
According to the provisions of the Law and relevant regulations, the Company shall be obliged to, prior to providing investment services, categorize its investors in one of the two categories:
- Small investor category
- Professional investor category
A professional investor is an investor who has sufficient knowledge, experience and expertise required for independent decision making on investing and proper assessment of the related risks and is defined by Article 5 of this Policy.
A small investor is any investor, i.e. an investor who is not treated as a professional investor.
Investment Company shall be obliged to inform every investor through a durable medium on:
The client category he/she is assigned to;
The level of interest protection that is to be provided;
The possibility of asking to be moved to other investor category, as well as on all protection levels changes, which arise from such decision.
An investor is responsible for veracity, completeness and truthfulness of given information, necessary for investor assessment.
An investor is liable for damage caused by providing false, incomplete and untrue data.
Small investors are all investors – principals that are not considered as professional investors or qualified investors. The Company is obliged to conclude the Contract with small investors, defining the international rights and obligations.
The Company shall provide to the small investors the highest possible level of security and other rights guaranteed to the small investors by the Law on Capital Market and bylaws on the Investment Company’s acting in the best interest of an investor.
Protection that the company provides to the investors listed in the category of small investors shall, primarily, refer to the execution of orders under the most favorable conditions for the investor in accordance with Order Execution Policy, as well as interests and assets protection of the investor.
The Company is obliged to provide the small investor with complete information, both prior to and upon providing investment services.
Professional Investors And Status Change
A professional investor is every investor who has sufficient experience, knowledge and expertise for independent decision making on investing and proper assessment of the related risks. In any case, and in accordance with the provision of Article 53 of the Law on Capital Market, a professional investor is considered to be:
An entity having the work permit or supervision entity in operating in the financial markets, such as:
Other financial institutions, having a work permit or being supervising entities;
Entities for joint investments and their management companies;
Pension funds and their management companies;
Commodities and commodity derivatives traders;
Other institutional investors.
Large company meeting two of the following conditions:
To have an overall asset of, at least, €20.000.000;
To have an annual net income of, at least, €40.000.000;
To have the capital of, at least, €2.000.000.
Government, Central Bank, international organizations, such as the World Bank, International Monetary Fund, European Central Bank, European Investment Bank, and other similar international organizations;
Other investors whose predominant activity is investing in financial instruments, including the entities that deal with assets securitization or other financial transactions.
If a company from the previous Article is an investor of the Company, it is obliged to inform investor in writing that based on available data, it can be considered a professional investor, and thus, it shall be treated as such investor, with a lower level of protection, unless agreed otherwise.
Qualified principals are the investment companies, investment funds and their management companies, authorized credit institutions, insurance companies, pension funds and their management companies, other financial institutions, public authorities, including public debt management authorities, central banks, international organizations and other authorized bodies.
Treatment Of Small Investors And Status Change
Prior to the conclusion of the Contract on the provision of services with a small investor, the Company is obliged to collect, i.e. request from the investor, the data about their knowledge and experience in the investment field that is of importance for the financial instrument or service being offered or requested, in order to assess to what extent that financial instrument or service is suitable for the investor.
Information regarding the investor's knowledge and experience, corresponding to the type of investor, type and scope of the service, type of transaction, including complexities and risks, particularly include:
The type of service, transaction and financial instruments known to the investor,
Type, quantity and frequency of investor's transactions with financial instruments and the period in which they are conducted;
The level of education (professional qualification), the profession, i.e. occupation and the title of the investor.
If the Company considers that, based on the information from paragraphs 1 and 2 of this Article, the product or service is not suitable for the investor, it is obliged to warn the investor.
The investment company can rely on information obtained from the investor as true and complete and it is not held liable for the damage in case the information obtained is not true or complete, except when it was known or should have been known that the data given by the investor was outdated, incorrect or incomplete.
Should investor wish not to provide data from paragraph 2 of this Article, or he/she has not given sufficient data on his/her knowledge and experience, the Company shall warn him/her in writing that it is not possible to determine whether the envisaged services and products are suitable for him/her, or not.
Price List Policy
This Policy defines the amounts/percentages of the commission (fees) for providing the services, that is, the fees that the Company charges to their clients in performing regular activities.
Brokerage commissions are commissions charged by the Company for the order execution for the account of the client, or the receipt and transfer of orders to be executed, which relate to financial instruments.
Commissions could be defined as follows:
- By number of lots;
- As a fixed amount of money;
- Are expressed in percentages, without the minimum fee.
- Overnight rollover (SWAP) changes
Commissions by number of lots
Commissions by the number of lots are charged from 0 USD to 45 USD.
Commission as a fixed amount of money
Commission as a fixed monthly amount of money corresponding to the costs that the company has for providing services to the client, plus the margin calculated and charged by the company to the client
Commission in percentage
The minimum commission is 0% (without commission), while the maximum amount is 1%. The percentages refer to the total market value of the transaction when it comes to transferable securities, money market instruments and investment units. The above mentioned percentages, when it comes to derivatives (options, futures, swaps, contracts for differences (CFDs), etc.), refer to the total value of the underlying assets contained in the derivative, not the total value of the derivative itself.
Overnight rollover (SWAP) charges
A daily overnight rollover charge may apply to each FX/CFD open position at the closing of LPS’s trading day. If such a charge is applicable, it will either be requested to be paid by you directly to us or it will be paid by us to you, depending on the type of FX/CFD and the nature of the position which you hold. The method of calculation of the rollover charge may vary according to the type of FX/CFD to which it applies.
To avoid swap fees you need to close your positions at the end of the day.
The provision is charged only for the orders that have been executed.
The criteria for determining provisions depend on the potential costs of the Company in order to realize orders for the account of the client, such as costs for the market organizers. Provisions depend on the type of the financial instrument and the market traded on, its liquidity, accessibility, type of instrument.
While concluding the contract with each client the exact amount of the commission that applies to broker services of certain financial instruments, depending on the criteria for determining it, is determined in advance.
Commissions for portfolio management services are management and performance commissions:
The management commission is a fixed amount expressed in percentages, defined by a contract with the client that relates to the annual level and is calculated on a daily basis in relation to the total market value of the client's portfolio that the Company manages at a given moment.
The annual amount for the management commission is fixed and can range from minimum 0% to maximum 3%.
The criteria for determining the commission amount depend on the type of the product i.e. the investment strategy for which the client decides, on the client's wish in terms of risk and expected return and on the amount of the performance commission.
The performance commission is calculated once a year and represents a percentage of the generated income for the client's account. The minimum commission amount is 0%, while the maximum amount is 25% of the generated income for the client's account in that calendar year.
The criteria for determining the commission amount depend on the type of the product or investment strategy for which the client decides, on the client's wish in terms of risk and expected return, and on the amount of the management provision.
In the contract concluded with each client the exact amount of the commission that applies to the portfolio management services, depending on the criteria for designating them, is determined in advance.
The Company shall charge a commission defined by the contract concluded with the client for performing activities of the investment consultant.
The Company drafts the daily financial reports in the area of the investment for the client with a professional market analysis. The report contains an assessment of the financial instruments as well as market assessment and analysis in order to provide information to the client, which will enable it to properly implement the set investment goals.
The minimum commission amount per one daily report is €50, while the maximum amount of the commission amount per one daily report is 500€, depending on the criteria for determining the commission.
The criteria for determining the commission amount for performing investment consulting activities are as follows:
Type of client
Scope of analyzed data
The size of the portfolio that is being analyzed (number of financial instruments, sectors, markets, macroeconomic analysis ...)
The time frame that is being observed in the analysis
Number of used indicators, ratios and relevant factors in making the analysis
Length (comprehensiveness) of the report
In the contract concluded with each client the exact commission amount that applies to the investment consulting services provided to that client, depending on the criteria for determining them, is determined in advance.
The Executive Director of the Company has the right to determine lower rates of the commission and fees, or can, in some cases, exclude them, depending on the interests of the Company and its clients and market movements.
Risk Disclosure Statement
Trading CFDs is highly speculative, involves a significant risk of loss and is not suitable for all investors but only for those customers who:
Understand and are willing to assume the economic, legal and other risks involved;
Are experienced and knowledgeable about trading in derivatives and in underlying asset types;
CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. The high degree of leverage can work against you as well as for you. Before deciding to trade any such leveraged products you should carefully consider your investment objectives, level of experience, and risk appetite. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money. CFDs are not appropriate investments for retirement funds. CFD transactions are among the riskiest types of investments and can result in large losses. Customer represents, warrants and agrees that Customer understands these risks, is willing and able, financially and otherwise, to assume the risks of trading CFDs and that the loss of Customer’s entire account balance will not change Customer’s lifestyle.
The possibility exists that you could sustain a loss of some or all of your initial investment and therefore you should not invest money that you cannot afford to lose.
You should be aware of all the risks associated with trading on margin and seek advice from an independent financial advisor if you have any doubts.
You understand that commissions, fees and other charges may be applicable, and as such these charges will affect/reduce the profit (if any) or increase the loss. Before trading in financial instruments, you should make yourself aware of all charges for which you will be liable, whether such charges are at a predetermined amount or variable.
When trading CFDs with us, such transactions will not be executed on a recognized or designated investment exchange and are known as OTC transactions. All positions entered into with us must be closed with us and cannot be closed with any other entity. OTC transactions may involve greater risk because there is no exchange market on which to close out an open position. It may be impossible to liquidate an existing position, to assess the value of the position arising from an OTC transaction or to assess the exposure to risk. Bid prices and ask prices may not be quoted by us, based on best execution policies applicable in the market. There is no central clearing and no guarantee by any other party of Limit Prime Securities payment obligations to the Customer.
No Guarantees Of Profit
There are no guarantees of profit nor of avoiding losses when trading CFDs. Customer has received no such guarantees from any of its representatives. Customer is aware of the risks inherent in trading CFDs is financially able to bear such risks and withstand any losses incurred.
There are risks associated with utilizing an Internet-based deal execution trading system including, but not limited to, the failure of hardware, software, and Internet connection.
Since Limit Prime Securities does not control signal power, its reception or routing via Internet, the configuration of your equipment or reliability of its connection, we cannot be responsible for communication failures or delays when trading via the Internet.
Any opinions, news, research, analyses, prices, or other information contained on this website and social media is provided as general market commentary, and does not constitute investment advice.
Limit Prime Securities will not accept liability for any loss or damage, including without limitation to, any loss of profit, which may arise directly or indirectly from use of or reliance on such information.
Conflict Of Interests Management Policy
The Company, relevant persons and persons directly or indirectly related to the Company are obliged to, while performing their tasks, act responsibly, honestly, conscientiously and impartially, representing the interests of the client, and arranging not to harm their reputation and the trust of the Company and Company’s clients.
Employees of the Company (hereinafter: employees) must not use the Company's activities for their own interests and benefits, nor can they be dependent on persons that could affect their objectivity in any way.
Relevant persons are obliged to work in accordance with the principles of responsibility, truthfulness, efficiency, transparency, and act in good faith with business partners, clients of the Company and other employees of the Company. They are also obliged to professionally perform the tasks to which they are deployed and promote the business interests of the Company.
In order to prevent the conflict of interests between employees and the clients of the Company, special attention will be paid to preventing the following situations:
- The exchange of confidential information between employees, working in different departments or sectors, or unnecessary disclosure of confidential and inside information and data obtained through the performance of work tasks;
- Inappropriate influence of any person from the group to which the Company belongs or outside it, in the manner in which the employee provides the investment services;
- Using inside information for the purpose of entering employees' orders into the trading system before the client’s orders (front running);
- Purchase of the financial instruments for their own name, consequently raising the purchase price for the account of the clients' portfolio;
- Raising the purchase price for the account of clients' portfolio, consequently selling financial instruments for own account;
- Unequal treatment of the portfolio clients while selecting financial instruments and/or prices;
- Closing transactions within the Company, and between an employee who manages the client's portfolio and the client's portfolio;
- Trading for the portfolio clients motivated by the commission,
- Purchase of the financial instruments of an employee who made a recommendation on his/her behalf immediately prior to the distribution of the recommendation on the purchase of a given financial instrument,
- Selling the financial instruments of an employee who made a recommendation for own account immediately prior to the distribution of the recommendation on the sale of a given financial instrument, etc.
The Company has an independent function to monitor business compliance with the regulations whose tasks include, among other things, the identification, prevention and management of the risks.
The relevant persons are prohibited to perform the following activities:
To conclude their personal transactions if:
- This involves abuse or disclosure of inside or other confidential information related to a client or transactions with a client or for the client’s account
- The conclusion of such a transaction is in conflict or is likely to face conflict with the Company's obligations;
To advise or encourage the other person to conclude transactions with financial instruments in a manner that exceeds the authority of the relevant person or is not set forth by the contract on providing the services;
To disclose to the other person any information or opinions, except under the authority or within the framework of a contract on providing the services, if the relevant person knows, or should be aware, that such actions would affect that other person:
- Conclude a transaction with financial instruments,
- Advise or encourage a third party to conclude such a transaction.
Product Governance and Approval Policy
This policy ensures that Limit Prime Securities A.D. Podgorica hereinafter the “Company” manufactures financial products targeting a particular group of Clients, so that the product meets their interests, needs and objectives (target market). The Company shall also identify a group of end-Clients where these products may not be offered due to the Company’s assessment that the product does not meet their interests, needs and objectives (negative target market). Moreover, the Company for each target market shall identify appropriate distribution channels/venues and media of marketing so that the product is offered to the target market (to a possible extent).
Finally, the Company with this policy identifies information and practices that will enable to assess each individual end-Clients’ compatibility with its products.
Financial Product Approval
The General Manager/CEO shall convene on ad-hoc basis to propose new designs on offerings by the Company. The General Manager/CEO shall take into account the following when designing new products:
Short Description regarding the product and its features;
Conflicts of interest must be identified and taken into account during the product development to ensure the features of the product benefit the end-client and not the Company assessing the risks of poor outcome for end-Clients;
Scenario Analysis: During the product development, a scenario analysis of the different outcomes of the product should be undertaken;
The charging structure proposed for the financial instrument;
Target Market Identification;
Negative Target Market;
Risk Management Policy
Financial instruments, including the purchase and sale of financial instruments, carry certain risks. By assigning the Order and / or the Contract on the performance of brokerage operations, the Client confirms that he is aware of the risks associated with the capital market, that the Company made available to him the data and information he requested and that the company answered in a satisfactory manner to all the questions he asked about the market conditions and financial instruments to which the Order are related.
The Company is exposed in its business especially to the following risks:
Exposure risks to one person or a group of related parties,
Market risks are: risk of price changes, risk of settlement of liabilities and counterparty risk, risk of exceeding allowed exposure limits, currency risk.
Credit risk is the risk of loss resulting from failure to meet the financial obligation of a person to a Company. Credit risk is reflected in the fact that the issuer of a financial instrument is unable to pay the contractual interest or principal on its debt obligations. In assessing the credit risk of certain financial instruments, the Company will use rating agencies' ratings if applicable for a specific credit risk assessment. If not applicable, the Company will use its own valuation techniques of both financial instruments and clients, which are internally developed techniques of fundamental analysis.
Liquidity risk is the risk of the possibility of adverse effects on the Company's financial result and equity due to the Company's inability to meet its due liabilities. On the daily level, the Company measures liquidity by comparing the balance of its liquid assets and current liabilities.
The investment company is obliged to calculate on a daily basis the amount of liquid capital in money, risks, exposure and qualifying holding.
Operational risk is the risk of loss due to errors, interruptions or damage that may occur due to inadequate internal procedures, the treatment of persons, systems or external events, including the risk of changing the legal framework.
The Company's exposure to a single entity is the total amount of receivables relating to that person or group of related parties (loans, investments in debt securities, equity investments and shares, issued guarantees and etc.).
Other risks include: the risks of competition and the financial crisis and the reduction in demand for services.
By opening an account or by using the LPS website, you give your consent to the collection and use of personal information by LPS as explained in this Privacy Statement. We are committed to being open and transparent about how we manage your personal information. Where our documents or interactions with you ask for personal information, we will generally state the purposes for its use and to whom it may be disclosed.
Collection of Personal Information
The fees and commissions of the investment company may be determined in cash or in a percentage, depending on the type of service provided by the company.
The information LPS collects may include:
- Application information
Personal information you provide us in your application, such as your name, address, date of birth, email address, employment details, income level and income source etc. are used in order to facilitate the assessment of your application. The information that you provide us are also used for the purposes of communicating with you.
- Transaction information
Information to assess your trading experience and suitability of performing transactions using our products and services as well as information about the anticipated volume and value of your transactions with us is used to enable the construction of your economic profile. When you trade with us we are also collecting information about the volume and value of your transaction performed with us.
- Verification information
Information necessary to verify your identity is collected from you, such as an identification card, passport copy, passport number, confirmation of address. This also may include background information we receive about you from public records or from other entities not affiliated with LPS.
Please note that we record telephone conversations or electronic communications relating to concluded transactions and the provision of client order services that are related to the reception, transmission and execution of client orders.
We may make inquiries as to your identity(ies) and other personal details, as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2018 ("Official Gazette of Montenegro, no. 033/14 od 04.08.2014, 044/18 od 06.07.2018) Your personal information will be treated strictly in accordance with the Personal Data Protection Act.
Use of Personal Information and Disclosure
The data we collect will only be used for the purpose of providing our services or for other purposes for which you have given your consent, except in cases where the law prescribes otherwise. Moreover, this information helps us to improve services, establishing and managing your account, reviewing your ongoing needs, enhancing customer service, customize your browsing experience and inform you of additional products, services or promotions relevant to you. If you do not want to receive information of this nature for any reason, please contact us at the following email address email@example.com
According to the Law on Capital market, we store collected personal data for a period of at least five years.
LPS reserves the right to disclose personal information to third parties where required by law, regulatory, law enforcement or other government authority of a competent jurisdiction in order to protect our rights and/or to comply with such legal proceedings. Under such circumstances, LPS shall expressly inform the third party regarding the confidential nature of the information. We may disclose your personal information to:
- other companies who provide financial and other services for LPS and their clients;
- our related bodies corporate, agents, employees and representatives;
- Capital Market Authority, Administration for Prevention of Money Laundering and Terrorist Financing, and other reference institution;
- financial institutions and other similar organizations in connection with our corporate activities or that are nominated by you;
- external service providers and professional advisers that provide services to us such as account processing, fulfillment, Client service, Client satisfaction surveys or other data collection activities relevant to our business;
- credit providers, collection agencies, courts, tribunals and regulatory authorities as agreed or authorized by law;
- any organization which you request us to or any persons acting on your behalf, including your financial adviser, broker, solicitor or accountant;
- partners, affiliates and alliances and introducing brokers with whom we have a mutual relationship;
- where you have been introduced to us, the person responsible for the introduction may have access to your information. You hereby unambiguously and unequivocally consent to the sharing of information with such a person; and
- anyone authorized by an individual, as specified by that individual or the contract.
Integrity and Protection of Personal Information
Whilst we attempt to ensure that all the information we hold about you is current, accurate and complete, we urge you to promptly notify us of any changes to the personal information that LPS holds about you. Personal Information is safely stored on secure servers that only authorized personnel has access to, via password. LPS encrypts all personal information as it is transferred to us and thus, makes all necessary efforts to prevent unauthorized parties from viewing any such information.
Statistical Information and Cookies
LPS is using cookies in order to collect statistical information about visitors to our websites. Collected data are: the number of visitors, pages viewed, types of transactions conducted, time spent online, documents downloaded, the name of your Internet service provider, the IP address, the date and time of access, the difference in the time zone relative to the GMT, the access status / HTTP status for the amount of downloaded data, the browser, the language, the browser version, the operating system and the screen surface, the website linked you to our site, the web pages you have visited from our site. This information is used to evaluate and improve the performance of our websites. Other than statistical information, we do not collect any information about you through our website unless you provide the information to us. LPS may share website usage statistics with reputable advertising companies and with its marketing companies. The information collected by the advertising company is not personally identifiable.
Access to Information and amendments
The Executive Director of the Company has the right to determine lower rates of the commission and fees, or can, in some cases, exclude them, depending on the interests of the Company and its clients and market movements.
Restriction of Responsibility
By accessing this website or by submitting an application to open an account with LPS, you give your consent to LPS to collect, maintain, use and disclose personal information about you and provided by you or by another person as described above.
Amendments to This Privacy Statement
Information about financial instruments
Investiciono drustvo Limit Prime Securities AD Podgorica provides existing and potential clients with detailed information about the characteristics and risks of financial instruments, appropriate categorization of the client as a small or professional investor, which will enable the client to make the appropriate investment decision.
Risk information includes, in particular:
1) risks associated with the type of financial instrument, including the clarification of the financial leverage and its effect, as well as the risk of loss of investment;
2) volatility of the price of a financial instrument and possible restrictions on the existing market for these instruments;
3) financial and other additional obligations of the investor in the event of a transaction with those financial instruments;
4) information about the margin and other obligations related to the financial instrument.
In accordance with the Law on Capital Market, financial instruments are:
investment units, in terms of the law governing the establishment and operation of investment funds and investment funds management companies;
derivatives, i.e. commodity derivatives, including:
options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields, emission allowances or other derivatives instruments, financial indices or financial measures which may be settled physically or in cash;
options, futures, swaps, forwards and any other derivative contracts relating to commodities that must be settled in cash or may be settled in cash at the option of one of the parties other than by reason of default or other termination event;
options, futures, swaps, and any other derivative contract relating to commodities that can be physically settled provided that they are traded on a regulated market and/or MTF and/or OTF except for wholesale energy products traded on an OTF that must be physically settled;
options, futures, swaps, forwards and any other derivative contracts relating to commodities, that can be physically settled not otherwise mentioned in sub-item c) of this item, and not being for commercial purposes, which have the characteristics of other derivative financial instruments;
Derivative instruments for the transfer of credit risk;
Financial contracts for differences;
Options, futures, swaps, forward rate agreements and any other derivative contracts relating to climatic variables, freight rates or inflation rates or other official economic statistics that must be settled in cash or may be settled in cash at the option of one of the parties other than by reason of default or other termination event, as well as any other derivative contracts relating to assets, rights, obligations, indices and measures which have the characteristics of other derivative financial instruments, which are traded on a regulated market, OTF, or an MTF; and
An investment firm shall also regularly review financial instruments it offers or markets, taking into account any event that could materially affect the potential risk to the identified target market, to assess at least whether the financial instrument remains consistent with the needs of the identified target market and whether the intended distribution strategy remains appropriate.
Client's Funds Statement
We shall treat money held by Limit Prime Securities on your behalf as Client Money. We treat money received from you or held by us on your behalf in accordance with the provisions of the Applicable Laws and Regulations regarding holding clients’ money.
Funds on client account do not belong to our company and are not part of our assets, nor are they a part of our assets, its liquidation or bankruptcy estate, nor may they be the subject of the execution for the purpose of settling a claim against our company.
Limit Prime Securities keeps and maintains books and accounting records of the Client Money held on behalf of its Clients. The provisions related to client money, are subject to the terms and conditions of the banks and credit institutions with which such funds are held and through which such funds are transferred.
Subject to the relevant Margin requirements, the minimum deposit amount which must be standing to the credit of your Account will be set out on our Website from time to time and will in any case not be lower than USD 100 or EUR 100.
We do not charge fees for deposits or withdrawals of money transferred into or out of your Account with us. It remains however your responsibility to be aware at all times, of the transfer fees and/or any other fees and charges which are charged by the bank, payment service providers and any other service providers which you use for the transfer of funds to and from us.
When you transfer money to your Account with us, the time taken for the funds to appear on your Account depends on the method used for transferring such funds.
We deposit Clients’ money held on behalf of our clients in an account and/or accounts opened with bank (credit institution). We can also receive Clients’ money through payment institutions. We are obliged to exercise all due care, skill and diligence in the selection and appointment of banks and payment institutions, in accordance with Article 298 Law on Capital Markets (Montenegro). We shall take into account the expertise and reputation of the bank or the payment institution, as well as the legal and regulatory requirements or market practices related to the holding of Clients’ money that could adversely affect the protection afforded to the clients’ money.
We shall take all necessary measures in order to ensure that any clients’ money deposited with a bank are identifiable separately from the cash belonging to the Company by means of differently titled accounts on the books of the bank(s). Similarly, as per the requirements of the Applicable Laws and Regulations, we, on receiving any clients’ funds, shall promptly place those funds into one or more accounts denoted as “clients’ accounts”.
Where necessary, we shall apply diversification as to where clients’ money is held, through the maintenance of accounts with several banks.
You agree that we shall not be liable for any default of any counterparty, bank, payment processing company, custodian or other entity which holds money on your behalf or with or through whom transactions maybe conducted.
We are required to follow the Applicable Laws and Regulations concerning money laundering, bribery, corruption and financial crime prevention (“AML Laws”).
To ensure compliance with standard AML regulations, we require you to submit the following documentation:
Proof of Identification: a valid copy of your passport, national ID card, driving license
Proof of address: Valid proof of address issued in the last three months
Photo of client using proof of identity
Filled and signed PEP form
Additionally, we need information about your employment, profession, annual income, saving and investments, about the purpose and nature of your trading with us, source of the funds with which you will trade with us, information about your trading experience…
All deposits and withdrawals must be made in your own name and must match the submitted documents.
If you deposit more than 15.000 USD you will be requested to complete the statement about your source of funds and to attach all relevant supporting documents for the purpose of justifying your statements.
If you have any questions, please feel free to contact us via email: firstname.lastname@example.org
The complaints could be submitted in one of the following manners:
1. Directly submitting of written complaint in the headquarters of the Company,
2. Sending it by post;
3. Sending the scanned complaint via e-mail: email@example.com
4. Filling a complaint request electronically on the Client's profile
Complaints shall be submitted in writing and must contain the following information:
Personal data of the person submitting the complaint, namely: name and surname, or name of the legal entity, unique personal registration number, address, contact e-mail and contact phone number
Date of filing the complaint
Description of the subject matter of the complaint and evidence
Signature of the complainant in case it is not submitted electronically (via the Client's portal).
Upon receipt of the complaint, we will investigate the complaint and get back to you with the outcome/ decision within the 8 days of receipt of the complaint.
In compliance with the Anti-money laundering regulation, requested withdrawals could be directed only to the banking accounts which are in the name of our client-account holder (name and surname of the client indicated on his/her identification document, need to be exactly the same as the name and surname of the account holder).
Upon the approved withdrawal request, Limit Prime Securities will proceed with the execution of that request within 2 business days. Limit Prime Securities will direct the approved amount directly to the client's banking account via banking wire and will use the “SHA option of transaction fees” for such transfer.
Please be informed that banking wire transfers can take up to 6 days and therefore Limit Prime Securities cannot be responsible for any potential delays in crediting the funds on the banking account of the client.
The Client can fill in the withdrawal order on his portal.