Information for investors
MIFID II Directive
The initial Directive of the European Parliament and of the Council on markets in financial instruments (hereinafter MiFID) came into force in 2007. This directive is binding for all the European Union member states and its aim is to make financial markets more efficient, resilient and transparent, and to ensure the highest level of investor protection.
On 3 January 2018, the MiFID II Directive came into force with additional requirements aimed at improving the efficiency of the financial markets, transparency and strengthening the protection of investors.
The Law on Financial markets of the Republic of Latvia ensures MiFID II compliance in Latvia.
MiFIR Regulation
Regulation of the European Parliament and of the Council on markets in financial instruments (hereinafter MiFIR) is binding for all the European Union member states. MiFIR contains rules and guidelines for transaction execution and financial instrument trade transparency.
If you use, have used or plan to use any of the investment services offered by the bank, MiFID II, MiFIR and the national legislation influences your cooperation with our bank as well. In order to ensure as transparent and effective cooperation related to financial instruments as possible, Luminor invites you to familiarize yourself with the information provided herein.
Client Classification Rules, valid from February 7, 2025
Policy for execution of orders in financial instruments
Summary of policy for execution of orders in financial instruments
Summary of Conflict of Interest Management Policy
Description of financial instruments and related risks valid from May 1, 2024
Information on the investment service provider and services provided
Inducement Policy for the Provision of Investment and Ancillary Services
Order execution venues
Ex-ante Costs & Charges disclosure
Summary of Policy for Securities Allocation in the Primary Market valid from March 15, 2024
The statement on principle adverse sustainability impacts and indicators of Luminor
| 3M | 6M | 12M | |
|---|---|---|---|
| FX Forward EURGBP | Buy Sell |
Buy Sell |
Buy Sell |
| FX Forward EURPLN | Buy Sell |
Buy Sell |
Buy Sell |
| FX Forward EURSEK | Buy Sell |
Buy Sell |
Buy Sell |
| FX Forward EURUSD | Buy Sell |
Buy Sell |
Buy Sell |
| FX Swap EURGBP | Buy Sell |
Buy Sell |
Buy Sell |
| FX Swap EURPLN | Buy Sell |
Buy Sell |
Buy Sell |
| FX Swap EURSEK | Buy Sell |
Buy Sell |
Buy Sell |
| FX Swap EURUSD | Buy Sell |
Buy Sell |
Buy Sell |
Interest Rate Swap - EURIBOR3M 5Y
Interest Rate Cap - EURIBOR3M 5Y
Interest Rate Collar - EURIBOR3M 5Y
Commodity Swap - Natural Gas
What is Client Classification Policy?
In line with MIFiD requirements, the Client Classification Policy stipulates that a status of a Retail customer, a Professional customer or an Eligible counterparty should be assigned to each client. The aim of the Client Classification Policy is to define the criteria of clients’ classification, the order of changing the status, as well as the level of protection corresponding to each client’s status. Clients which are classified as Retail customers are provided with the highest level of investors’ protection.
What is Order Execution Policy?
The Order Execution Policy defines the guidelines for order execution, so that clients’ orders are executed on the most favourable conditions for the client. The policy also describes the order execution procedure of the bank. The client must give his consent to the bank’s Order Execution Policy to trade financial instruments.
What is Conflicts of Interest Policy?
The Conflicts of Interest Policy stipulates all necessary and possible actions to identify and mitigate possible conflicts of interest, which could be harmful to clients’ interests in transactions related to investment services and/or ancillary investment services.
Luminor informs you that it receives payments from third parties (inducements) for clients’ investments in specific investment products. Bank emphasizes that the aim of these payments is to increase the value of service provided to clients and they do not influence the bank’s obligation to achieve the best possible results for clients when providing investment services to them. The list of investment funds and the amount of inducements that Luminor receives for the distribution of investment fund shares can be found in Inducement Policy for the Provision of Investment and Ancillary Services.
2023
Top 5 Execution Venues
| Retail Clients | PDF |
 Excel |
| Professional Clients | PDF |
Excel |
Top 5 Execution Entities
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
2022
Top 5 Execution Venues
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
Top 5 Execution Entities
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
2021
Top 5 Execution Venues
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
Top 5 Execution Entities
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
2020
Top 5 Execution Venues
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
Top 5 Execution Entities
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
2019
Top 5 Execution Venues
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
Top 5 Execution Entities
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
2018
Top 5 Execution Venues
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
Top 5 Execution Entities
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
2017
Top 5 Execution Venues
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
Top 5 Execution Entities
| Retail Clients | PDF |
Excel |
| Professional Clients | PDF |
Excel |
Statement on integration of sustainability risks into investment process regarding Luminor Bank AS’s discretionary portfolio management service
General business terms for Investment Services Rendered via Luminor Trading Platform
General terms for the Discretionary Portfolio Management Service Agreement valid since 01.03.2021.
Regarding implementation of the Law on Markets in Financial Instruments
The statement on principal adverse sustainability impacts and indicators of Luminor, valid from 04.2023 to 06.2023
General terms for the Discretionary Portfolio Management Service Agreement valid till 01.03.2021.
Key Information Documents:
Commodity Swap – Diesel 10ppm CIF NWE, 2019 02 21
Commodity Swap – Fuel Oil 3.5% FOB Barges ARA, 2019 02 21
FX Forward - EURRUB 1Y, 2019 02 21
FX Forward - EURUSD 1Y, 2019 02 21
FX Swap - EURUSD 1Y, 2019 02 21
Interest Rate Cap (bought) - 5Y 3M EURIBOR, 2019 02 21
Interest Rate Swap - 5Y 3M EURIBOR, 2019 02 21;
Interest Rate Swap - 5Y 6M EURIBOR, 2019 02 21
Description of financial instruments and related risks, valid from 02.01.2019 till 29.04.2024
Client Classification Policy:
Effective till 06.02.2025
Effective till 01.01.2019
Effective till 31.01.2018
Effective till 01.10.2017
Effective till 18.03.2013
Effective till 6.05.2014
Conflict of Interest Management Policy:
Effective till 14.05.2024
Effective till 10.01.2024
Conflicts of Interest Policy:
Effective till 02.07.2020
Effective till 27.05.2019
Effective till 01.01.2019
Effective till 14.02.2018
Effective till 01.10.2017
Effective till 6.05.2013
Effective till 18.03.2013
Policy for execution of orders in financial instruments:
Effective till 01.10.2023
Effective till 19.06.2021
Effective till 01.01.2019
Effective till 31.01.2018
Effective till 01.10.2017
Effective till 03.08.2016
Effective till 16.06.2015
Effective till 06.05.2013
Effective till 18.03.2013
Summary of policy for execution of orders in financial instruments:
Effective till 19.06.2021
Order Execution Venues:
Effective till 01.01.2019
Effective till 31.01.2018
Effective till 01.10.2017
Effective till 03.08.2016
Effective till 04.06.2014
Luminor Investor platform terms:
Business Terms for Securities Trading effective until 20.04.2023.
General Business Terms for Investment Services effective until 20.04.2023.
General Provisions for the Agreement on Administration of Financial Instruments effective until 20.04.2023.
Inducement Policy for the Provision of Investment and Ancillary Services:
Effective till 14.12.2023
Effective till 20.12.2021
Effective till 01.01.2019
Information on the investment service provider and services provided:
Effective till 30.09.2021
Effective till 01.01.2019
Application For Non-independent Investment Advice, valid from 01.11.2019 to 30.07.2020
Ex-ante Costs & Charges disclosure:
Effective till 02.11.2021
The statement on principle adverse sustainability impacts of Luminor
The statement on principle adverse sustainability impacts and indicators of Luminor valid from 07.2022 to 04.2023
The statement on principle adverse sustainability impacts of Luminor valid from 03.2022 to 07.2022