Policies on Multiple Market Places & Best Execution

With the introduction of multiple marketplaces in Canada, Jennings Capital Inc. (“Jennings”) would like to advise our clients of the policies and procedures that will affect the handling of orders for the purchase and sale of Canadian-listed securities. 

Orders on Toronto Stock Exchange (“TSX”) and Toronto Stock Exchange Venture (“TSX-V”) listed securities may be executed on the TSX, TSX-V and a number of alternative Canadian electronic marketplaces, or on a foreign organized regulate market. 

Jennings Capital Inc. is committed to use all reasonable efforts to ensure our clients achieve the “best execution” of their orders for securities that are quoted or traded on all marketplaces. 

If you have any questions regarding this policy please contact your Registered Representative. 

1.  Principle Marketplace

Unless advised by Jennings the Principle Marketplace for all securities listed on the TSX and TSX-V, whether or not the security is trading on other alternate marketplace, will be the TSX and the TSX-V.

The TSX and TSX-V operate between 9:30 a.m. (EST) and 4:00 p.m. (EST), Monday through Friday, not including statutory holidays in Ontario.  All references to time in this policy are in EST. 

2.  Hours of Operation for Trading in Listed Canadian Securities

Jennings advisors, trading staff and systems will be available for order execution during Principle Marketplace hours.  Staff may be available outside of Principle Market place hours; however Jennings will not guarantee order taking and/or trade execution outside of the hours of 9:30 a.m. to 4:00 p.m. EST. 

3.  Trade Routing

Orders received will be routed as follows:

  1. An order received prior to Principle Market place opening (9:30 a.m. EST) will be entered on the Principle Marketplace for execution on the opening.  Orders received prior to the Principle Marketplace opening will not be route to an alternative marketplace.
  2. An order received after the Principle Marketplace close (4:00 p.m. EST) will be entered to the pre-openings of the Principle Marketplace on the following business day.  Orders received after the Principle marketplace close will not rout to an alternative marketplace;
  3. An order received during the Principle Marketplace operating hours will be entered into the best market at the time of entry.  The “best market” is the marketplace with the best bid (buy price) or ask (sell price) or where Jennings feels the order has the highest probability of being executed.  The may be any market place that Jennings has access to and/or can access for the purpose of best execution;
  4. Any portion of an order that cannot be immediately filled will be entered on the Principle Marketplace and will remain in the Principle Marketplace order book until the order is filled, expired, changed or cancelled; and
  5. Changes to an outstanding order, or portion of an outstanding order, will be handled the same as a new order received and will be treated according to routing conditions ( c ) and (d) above.

4.  Order Execution

Certain types of orders have specific handling implications in a multiple marketplace environment. 

  1. Day Orders
    A Day Order is an order to trade that expires if it is not executed the day that it is booked to the marketplace.  Day Orders will be handled in accordance with the “Standard Order Routing Conditions”  All Day Orders expire, if not filled in full, upon the close of the marketplace where the last portion of the order remains effective, unless otherwise agreed to between the client and the Registered Representative.
  2. Good Til Cancelled (Open) Orders
    Open orders are orders that will remain valid until a specified date of expiry.  These orders will be entered in the Principle Marketplace if they are not immediately executable on an alternative marketplace at the time of entry.  The order will remain in the Principle Marketplace until executed or expiry, whichever comes first.
  3. Market Orders
    A Market Order is an order to buy or sell a security at whatever prices are available in the marketplace to help ensure a complete full fill.  Upon entry to the marketplace, these orders require immediate completion.  Market Orders will be handled in accordance with the “Standard Order Routing Conditions”.  These orders will expire, if not filled in full, on the marketplace where the last portion of the order remains live, at the close of the marketplace.
  4. Limit Orders
    A Limit Order is an order for a security at a specific minimum sale price or a maximum purchase price that is not to be exceeded.  Limit Orders will be handled in accordance with the “Standard Order Routing Conditions”.  The order will expire if not filled in full, upon the close of the marketplace where the last portion of the order remains live.
  5. Special Terms Orders
    Special Terms Orders are orders with specific terms that are not executable in the regular marketplace.  Special Terms Orders will only post to the Special Terms Market of the Principle Marketplace, unless they are immediately executable on an alternative marketplace at the time of entry.  Special Terms Orders will expire at the close of the Principle Marketplace.
  6. Stop Loss Orders
    Stop Loss Orders are orders that become limit order when a board lot is traded at, or superior to, the stop loss price on the marketplace in which the order has been booked.  These orders will only be directed to the Principle Marketplace and will remain there until the order is executed or expires, whichever comes first.

5.  Extenuating Circumstances

In the event of technical or other issues that limit Jennings’ access to specific marketplaces, or limit access to routing automation, order received will be directed to either the Principle Marketplace or an alternative marketplace as circumstances warrant and as determined by Jennings. 

6.  Disclosure of Marketplace

An order executed on one or more marketplaces or alternative marketplace will generally be reported to the client using separate confirmation slips for each marketplace on which the order was filled.  The Marketplace on which the order was filled will generally be identified by name on the confirmation slip. 

7.  Amendments

Changes to this policy may be made at the discretion of Jennings Capital Inc.