An SI is an investment firm which deals in specific financial instruments on an organised, frequent, systematic and substantial basis on own account and outside a trading venue.
As an SI we have certain obligations to provide firm quotes to our clients and to make such firm quotes public. The obligations depend on the nature and liquidity of the financial instrument in question and the size of the quote.

Our obligation to provide firm quotes applies to financial instruments that are admitted to trading on trading venues.

Equity instruments
In liquid equity instruments such as shares and ETFs we have an obligation to provide firm bid and offer prices to our clients. This means that as a client you will have the possibility of trading with us by accepting the SI quotes that we make available.

Normal trading hours – equity instruments

Our normal trading hours for trading instruments in which we are SI are the normal trading hours for continuous trading on the relevant regulated market where the relevant share or ETF is traded:

Danish instruments 09:00 – 16:55 (CET)

Swedish instruments 09:00 – 17:25 (CET)

Norwegian instruments 09:00 – 16:20 (CET)

Finnish instruments 09:00 – 17:25 (CET)

Finnish instruments 10:00 – 18:25 (local time in Finland)

Non-equity instruments
In liquid non-equity instruments such as bonds and derivatives we are not obliged to provide firm quotes to our clients. But when we accept to provide a firm quote to a client we shall, subject to the limitations described below, provide the same quote to other clients and make the quote public.

Our obligation to provide quotes only applies up until certain trade sizes which are defined under the MiFID II rules.

For equity instruments, the relevant size is the Standard Market Size (SMS). The SMS is based on the average value of transactions in the equity instrument in question. For instance, if the average value of transactions in the specific equity instrument is less than EUR 20,000, then the SMS will be EUR 10,000.

In liquid equity instruments, we will provide firm bid and offer prices up until SMS.

We may provide firm quotes in larger trade sizes.

For liquid non-equity instruments, the SI obligations apply to sizes up until the so-called Size Specific to The financial Instrument (SSTI). For some financial instruments, the SSTI is defined at a fixed size in the MiFID II rules, whereas for other financial instruments the SSTI is calculated by the Competent Authorities based on actual trading sizes in the instruments.

SI financial instruments
Via the below link you can find the financial instruments or classes of financial instruments where we are SI.

Learn more here.

How to trade

Our firm quotes in liquid equity instruments are published to the BATS APA (

In addition, you may have access to firm SI quotes via the webbank solution which we offer to you.

Our firm quotes in liquid non-equity instruments are published to the TRAX APA (

In addition, you may have access to firm SI quotes via the webbank solution which we offer to you.

We may withdraw our quotes under exceptional market conditions.

Our prices (quotes) in equity instruments are firm prices meaning that the quoted price is the price that you can accept and that will then become the transaction price. In addition to that you may have to pay a transaction fee/a commission.

In non-equity instruments we will show the all-in price, meaning the price provided to the client who requested the quote. This means that the price that we quote may include client-specific elements such as for instance credit charges which may vary depending on the specific client. Therefore, if you as a client want to trade based on a quote solicited by another client these client specific elements may be different for you. This can both raise and lower the all-in price that you have to pay to trade based on the same quote.

Please contact us if you would like to hear more about client specific elements.

Publication of quotes
We are obliged to make our firm quotes in liquid instruments public. The public will be able to see our quotes on BATS APA (liquid equity instruments) and TRAX APA (liquid non-equity instruments).

Firm quotes in non-liquid equity instruments will not be made public or shown to other clients.

Firm quotes in non-liquid non-equity instruments will not be made public. However, on request from a client we will disclose our most recent quotes in such instruments which that we have provided on the day of such request.

When we provide a firm quote in a liquid non-equity instrument, we will only enter into one transaction based on that quote. This means that if the client who requested the firm quote does not trade against it (or only executes part of it) then other clients may trade against it (or the remaining part of it).

The reason for this limitation is that as an SI we trade against our proprietary capital and that the above non-discriminatory limit assures that providing firm quotes to clients does not entail a financial exposure for us in excess of the quote provided.

However, being an SI we see ourselves as being in the business of providing liquidity to the market. We will therefore as a rule be willing to provide additional quotes to our clients and such additional quotes as well will have to reflect prevailing market conditions.

In respect to equity instruments and where multiple clients have requested to execute against the same quote we may decline to execute some later requests if execution would contravene our internal risk management procedures.

The SI obligations do not apply to primary market transactions such as issuance, allotment or subscription for securities and the creation and redemption of units in ETFs.

Publication of Commercial Policy
The most recent version of this Systematic Internaliser Commercial Policy will be made available on our website: MiFID II. This Systematic Internaliser Commercial Policy may be changed at any time.