MiFID II / Regulatory Framework

Investor Information

Regulatory documents, policies and disclosures in accordance with Law 4514/2018 (MiFID II), the SFDR Regulation and applicable legislation.

MiFID II Policies

Mandatory policies under Law 4514/2018 and Regulation (EU) 2014/65 (MiFID II).

Client Categorization Policy
Classification of clients as retail, professional or eligible counterparties, and the corresponding levels of protection.
MiFID II
Best Execution Policy
Measures to achieve the best possible result when executing client orders in financial instruments.
MiFID II
Conflict of Interest Policy
Identification, prevention and management of potential conflicts of interest between the Company and its clients.
MiFID II
Pre-Contractual Information Package
Information provided to clients prior to entering into an investment services agreement.
MiFID II
Execution Venues
Report on execution venues and quality of execution analysis (RTS 28).
MiFID II · RTS 28
Target Market Determination
Criteria for determining the target market of clients for the financial instruments distributed by the Company.
MiFID II
Complaints Management

The Company maintains an internal complaints handling procedure in accordance with applicable legislation.

Complaints Management Policy
Internal procedure for receiving, evaluating and resolving client complaints within defined timeframes.
Submit a Complaint
Send an email to info@northsec.gr with subject “Client Complaint” or send a written document to our offices.
Supervisory Disclosures & Sustainability

Supervisory information and disclosures under Regulation (EU) 2019/2088 (SFDR).

Supervisory Disclosures
Annual disclosure of capital adequacy information and supervisory indicators as required by the Hellenic Capital Market Commission.
Supervisory
Sustainability Disclosure (SFDR)
Statement on sustainability risks and adverse impacts on sustainability factors (ESG), under Regulation (EU) 2019/2088.
SFDR
Data Protection & Legal
Personal Data Protection Policy
Data processing and protection policy in accordance with the General Data Protection Regulation (GDPR).
GDPR
Website Terms of Use
General terms and conditions for use of the northsec.gr website.

Sustainability Disclosure — Regulation (EU) 2019/2088 (SFDR)

On 10.03.2021, Regulation (EU) 2019/2088 of 27.11.2019 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation — SFDR) entered into force. This regulation requires financial market participants, including investment firms providing order reception and transmission and investment advisory services, to publish information regarding the consideration or non-consideration of the adverse impacts of investment decisions on sustainability factors.

Northern Greece Securities S.A. falls within the above categories as a provider of Order Reception & Transmission and Investment Advisory services, and therefore has the relevant obligations.

Sustainability factors are defined as environmental and social issues, personnel matters, respect for human rights, and anti-corruption and anti-bribery matters.

A. Statement of Non-Integration of Sustainability Risks in Investment Decisions and Investment Advice

In accordance with Article 3 of the SFDR Regulation: Financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process and investment advice.

The Company discloses that it has NOT established a policy on the integration of sustainability risks in its investment decision-making and investment advisory processes, although it endeavours to take sustainability risks into account by seeking and utilising relevant information from every available reliable source. The Company will review its decision in line with regulatory developments.

B. Statement of Non-Consideration of Adverse Impacts of Investment Decisions and Investment Advice on Sustainability Factors

In accordance with Article 4 of the SFDR Regulation, Northern Greece Securities S.A. discloses that:

The Company currently does NOT consider the impacts of sustainability and social policy (ESG) for the following reasons:

  1. The size, nature and volume of the Company's activities are limited and it is not currently in a position to obtain (availability problem) and/or assess (standards problem) the required information in a functional, simple and cost-effective manner.
  2. The total volume of the Company's activities is too small for the investment decisions and choices made to be considered as having significant impacts on sustainability and social policy (ESG) factors at EU level.
  3. In the context of the markets in which the Company operates (Greek Money and Capital Market), information regarding sustainability and social policy (ESG) matters is not sufficiently available from the issuers of the respective financial instruments.

Due to the above, Northern Greece Securities S.A., for the purposes of order reception and transmission and investment advisory services, has decided and discloses that it does NOT consider, when making investment decisions or providing investment advice, the adverse impacts of investment decisions on sustainability factors. The Company will review its decision in line with regulatory developments.

Important Notice: The above documents are provided for informational purposes only and do not constitute investment advice. Northern Greece Securities S.A. is authorised and supervised by the Hellenic Capital Market Commission (licence no. 3/6/1990). For any enquiry, please contact us at info@northsec.gr or +30 210 647 5300.
+30 210 647 5300