Peters & Co. Limited
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Peters & Co. Limited - an independent, fully integrated investment firm which has specialized for over 49 years in investments in the Canadian oil and natural gas and oilfield services industries.

BEST EXECUTION POLICY

Our Canadian equity market is composed of multiple marketplaces which include exchanges and Alternative Trading Systems ("ATSs"). A single security can trade on multiple marketplaces. With multiple marketplaces available for the execution of orders, Peters & Co. Limited considers the increased market complexity when handling client orders to ensure that we continue to comply with our "best execution" requirements.

Peters & Co. Limited has established and maintains written policies and procedures that are reasonably designed to achieve best execution when acting for a client. It is our obligation to disclose these policies and procedures to our clients as they will have an effect in the way your trades are conducted.

Peters & Co. Limited is committed to use all reasonable efforts to ensure that our clients achieve "best execution" of their orders for securities that are quoted or traded on all marketplaces. This means that we will diligently pursue the execution of each client order on the most advantageous execution terms reasonably available under the circumstances. More specifically it means that we will take into consideration a number of general factors including but not limited to:

  • the price at which the trade would occur;
  • the speed of execution;
  • the certainty of execution;
  • the overall cost of the transaction, when costs are passed on to clients.

In addition to the above factors, consideration will be given to such important factors as:

  • the direction of the market for the security;
  • the depth of the posted market;
  • the last sale price and the prices and volumes of previous trades;
  • the size of the spread; and
  • the liquidity of the security.

When handling client orders, traders will apply their professional judgment given prevailing market conditions, while also considering:

  • the client’s needs;
  • the nature of the transaction;
  • the Security; and,
  • the routing options available.

Specific instructions and/or consents from our clients may be considered when executing their orders. Peters & Co. Limited will endeavor to execute the order in accordance with the client instructions on a best-efforts basis, while adhering to market conduct rules, regulatory requirements, and securities laws. Our regulatory and legal obligations as executing broker may prevent client instructions from being met.

To ensure best execution and compliance with the Order Protection Rule under NI-23-101, Peters & Co. Limited uses electronic "smart routers" which will seek the best marketplace(s) at the time of entry. These routers will simultaneously route to all lit marketplaces and execute against the displayed volume which match the order criteria. The "best marketplace" is the marketplace with the best bid (buy price) or ask (sell price) and the best liquidity or where Peters & Co. Limited feels the order has the highest probability of being executed.

Peters & Co. Limited trades on five protected equities Exchanges in Canada currently, the TSX, TSX Venture, Aequitas Neo Exchange Inc., NASDAQ Canada, and the Canadian Securities Exchange (CSE).

Peters & Co. Limited may route orders to one of the alternative trading platforms; Nasdaq CXC, Nasdaq CX2, Tradelogic Markets Inc. (Omega and Lynx (through algo system only)) and Aequitas Neo Lit Book, (all of which are protected marketplaces) or Aequitas Neo Book, Aequitas Neo Dark Book, MatchNow/TriAct and Nasdaq CXD all of which are unprotected marketplaces) that participate in the trading of securities listed on the above Exchanges to ensure best execution for all orders. Neither TMX Alpha nor Aequitas Neo Book or their Neo Dark Book provide automated trading functionality.

Orders for Canadian listed securities may be executed on the Toronto Stock Exchange, ("TSX"), the TSX Venture Exchange ("TSXV"), or through a number of alternative Canadian trading platforms, or on a foreign organized regulated market.

Peters & Co. Limited uses intermediaries to access US marketplaces or when it uses algorithms. Best Execution and Order Handling Policies and Procedures of our intermediaries are reviewed annually, and we are satisfied that they are reasonably designed to achieve best execution.

Peters & Co. Limited does not have conflicts of interest with any of the marketplaces, ATSs or intermediaries.

Peters & Co. Limited may pay or receive either fees or rebates when routing client orders. Neither the fees we pay nor the rebates we receive are passed to our clients. Our routing strategies are not based on fees or rebates.

Unless an exception is made or a specific client instruction is given, to achieve best execution Peters & Co. Limited will handle orders as noted below:

1. Hours of Operation for Trading in Listed Canadian Securities

Peters & Co. Limited trading staff will be available for order execution between the hours of 9:30 a.m. and 4:00 p.m., Eastern Standard Time ("EST"), Monday to Friday, not including statutory Canadian holidays. Staff may be further available before and after these hours; however, Peters & Co. Limited cannot guarantee any order taking and/or trade execution outside of the hours note above.

2. Principal Marketplace

Unless otherwise notified by Peters & Co. Limited, the principal marketplace for all securities will be the Exchange on which the security is listed whether or not the security is trading on various other alternative marketplaces. There are six equities Exchanges in Canada currently, the TSX, TSX Venture, Aequitas Neo Exchange Inc., TSX Alpha, the Canadian Securities Exchange (CSE) and NASDAQ Canada.

For orders executed on one or more marketplaces, the client trade confirmation may state that the purchase or sale was made "on multiple markets, details are available". Full details of specific marketplace execution are always available to clients upon request.

Unless otherwise agreed to between an Investment Advisor of Peters & Co. Limited and the client:

  • an order received prior to 9:30 a.m. will book to the pre-opening of the principal marketplace for execution on the opening even if other markets may be available; and,
  • an order received after 4:00 p.m. will be entered the next business day to the pre-opening of the principal marketplace even if other markets may be available.

Opening Orders are entered for main market open to help prevent predatory pricing in pre-open sessions.

3. Standard Routing of Orders

Day Orders

A Day Order is an order that is only valid on and for the day it is entered. Day Orders will only be valid between the hours of 9:30 am. and 4:00 p.m. EST. A Day Order received prior to the opening of the principal marketplace at 9:30 a.m. EST will not route to an alternative marketplace. Instead, the order will route into the opening sequence of the principal marketplace. If received after the opening of the principal marketplace, the order will be routed for trading via a Smart Order Router ("SOR"). This will ensure that any immediately executable portion of the order will trade against the best price available on any protected marketplace Peters & Co. Limited has access to and/or can access for the purpose of best execution. The unexecuted portion of the order will then book on a marketplace according to the specific SOR settings or according to parameters as selected by the trader. Any untraded portion of a day order will expire at 4:00 p.m. (unless otherwise agreed to between the client and Trader/Investment Advisor of Peters & Co. Limited.

Special Terms Orders

Special Terms Orders (STO) are orders with specific terms that are not immediately executable in the regular marketplace. STO orders will only post to the Special Terms Market of the principal marketplace unless they are immediately executable on an alternative marketplace at the time of entry and they will only be live between 9:30 a.m. and 4:00 p.m., at which time they expire unless "Good til" instructions are applied to the order at the time of entry.

Open or Good Till Cancelled Orders

Good Till Cancelled Orders (GTC) are orders that the client wants to remain open until a specified date of expiry. These orders will be routed for trading via an SOR. This will ensure that any immediately executable portion of the order will trade against the best price available on any protected marketplace Peters & Co. Limited has access to and/or can access for the purpose of best price and best execution. Any unexecuted portion of the order will then book on a marketplace according to the specific SOR settings or according to parameters as selected by the trader. The order will remain in the system until it is executed, or it expires.

Market Orders

A Market Order is when the client has instructed a dealer to buy or sell at whatever prices available are in the marketplace to help ensure a complete and full fill. These orders require immediate completion. If the trader or Investment Advisor determines, based on market conditions, that immediately trading the entire order would not be in the best interest of the client then the client will be consulted, and trade desk will manage the order accordingly. A market order received prior to the opening of the principal marketplace at 9:30 a.m. will not book to an alternative marketplace. Instead, it will book into the opening sequence of the principal marketplace. If received after the opening of the primary marketplace the order will be routed for trading via an SOR. This will ensure that any immediately executable portion of the order will trade against the best price available on any protected marketplace Peters & Co. Limited has access to and/or can access for the purpose of best execution. The order will expire, if not filled in full, on the market where the last portion of the order remains live until that marketplace closes. In the case of an order where the last portion remains on the TSX, this will expire at 4:00 p.m. EST.

Market on Close Orders

A Market on Close order must trade on the close, at the calculated closing price, of the principal marketplace. Currently the TSX and the TSXV are the only marketplaces that offers a Market on Close facility. All Market on Close orders will therefore be entered into the TSX/TSXV, as the principal marketplace. This is an anonymous price facility and therefore, you do not know the price at which you will be expected until after execution has been completed. Limit orders are allowed but may, by the nature of a limit order, negate execution. For further details of this facility, please contact you Investment Advisor.

Limit Orders

A limit order has a specific minimum sale price or maximum purchase price provided by the client. A limit order received prior to the opening of the principal marketplace at 9:30 a.m. will not book to an alternative marketplace. Instead, they will book into the opening sequence of the principal marketplace. On or after 9:30 a.m., a limit order will be routed for trading via an SOR. This will ensure that any immediately executable portion of the order will trade against the best price available on any protected marketplace Peters & Co. Limited has access to and/or can access for the purpose of best execution. The unexecuted portion of the order will then book on a marketplace according to the specific SOR settings or according to parameters as selected by the trader. Any untraded portion of the order will expire at 4:00 p.m. (unless otherwise agreed to between the client and the Trader/Investment Advisor of Peters & Co. Limited.).

4. Disclosure of Marketplace

An order executed using one or more marketplaces or alternative marketplaces in either Canada or the United States will be reported to the client using a trade confirmation that will read (not limited to the following); "we confirm the following purchase/sale for your account traded on Multiple Marketplaces".

Should you receive such a confirmation, you are free to contact your Investment Advisor or any member of Peters & Co. Limited’s Compliance Department, and we will ensure full details are provided for all purchases/sales done to complete your order.

5. Fair Pricing of Over-the-Counter Securities

When transactions are not executed through a marketplace (over-the-counter) we shall make a reasonable effort to obtain a price for the client that is fair and reasonable in relation to prevailing market conditions. When determining best execution, the price, as well as any commission or mark-up are considered in the client’s over-all price. Mark-ups and mark-downs in the case of principal transactions, and commissions or service charges in the case of agency transactions, are an important factor in arriving at an aggregate fair price for a client. To obtain an aggregate transaction price for the client including any mark-up or mark down which is fair and reasonable we will consider the following factors:

  • 1) When acting as principal:
    • All transactions for our own account with a client will be done at an aggregate price (including any mark-up or mark-down) that is fair and reasonable, taking into consideration all relevant factors, including:
    • The fair market value of the securities at the time of the transaction and of any securities exchanged or traded in connection with the transaction;
    • The expense involved in effecting the transaction;
    • The fact that we are entitled to a profit; The total dollar amount of the transaction; and
  • 2) When acting as agent for a client for a commission or service charge we will ensure the amount is fair and reasonable taking into consideration all relevant factors including:
    • The availability of the securities involved in the transaction;
    • The expense of executing or filling the client’s order;
    • TThe value of the services we have rendered; and
    • The amount of any other compensation received or to be received in connection with the transaction.

In addition to over-the-counter trading of fixed income securities and debt instruments, Peters & Co. Limited is very active in the grey market trading of private companies for which we have previously acted as lead underwriter on a financing. We act more as market makers for these private companies using our experience and in-depth knowledge of the issuer to assist us in determining a fair and reasonable price.

In accordance with IIROC Rule 2800C, all OTC debt transaction details are reported to IIROC for full transparency. These reports are reviewed by IIROC market surveillance for fair pricing and include all pricing, mark-ups, and commission details.

6. Foreign Organized Regulated Marketplaces

Under certain circumstances, Peters & Co. Limited may make a determination that, in order to achieve best execution, all or part of a client order must be transacted on a foreign organized regulated marketplace. In making this determination, we may consider factors including but not limited to the speed of execution, available liquidity displayed on a marketplace relative to the size of the client order, the extent of trading in the particular security on the foreign organized regulated marketplace and the extent of exposure to settlement risk or fluctuations in foreign currency exchange.

Orders executed outside of Canada will be executed through an intermediary broker. These orders will be required to be executed in accordance with local rules and regulations applicable to the executing broker and may result in the executing broker applying different criteria to the assessment of execution quality. The executing broker may also have acted as principal or agent and may have derived compensation from the transaction. Stamp fees and/or foreign levies may be passed along to clients for execution into these foreign markets.

Peters & Co. Limited’s intermediary broker(s) attests that their policies and procedures, and those of their foreign intermediaries are reasonably designed to attain best execution.

7. Training

All employees involved in the execution of client orders have obtained the appropriate expertise and regulatory registrations in order to accept and trade client orders. All traders are supervised by senior management and are subject to continuing education which includes best execution obligations. Continuing Education is completed both at the Firm level as well as mandated by our regulators. Annual training sessions are mandatory for each registrant where new rules, policies and procedures, guidance notices and amendments are reviewed and discussed to ensure each registrant understands both the regulatory issue and our Firm policies and procedures.

8. Extenuating Circumstances

In the event of technical or other issues that limit Peters & Co. Limited’s access to specific marketplaces, or limit access to routing automation, orders received will be directed to either the Default Marketplace or an alternative marketplace as circumstances warrant and as determined at the sole discretion of Peters & Co. Limited.

9. Ongoing Monitoring for Best Execution

Our Compliance Department randomly selects a number of order tickets each month and compares the audit trail information from ticket to market quotes and trade information provided by our market data and trade desk service providers to ensure best execution is being achieved overall.

From time-to-time changes may be made to these policies as required and will be available on our website www.petersco.com. Please contact your investment advisor should you have any questions about these updates.

Last updated April 30, 2021


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