Rules of Provision of Investment Services (MiFID)

In Estonia, the rules for provision of investment services are stipulated with the Securities Market Act and since November 2007, these rules have primarily been based on The Markets in Financial Instruments Directive (MiFID) of the European Union. One of the objectives of MiFID is to offer investors better protection and harmonise the requirements set for companies offering investment services in the European Union and the European Economic Area.

Swedbank AS (hereinafter Swedbank) provides investment services under the Conditions for Providing Investment Services that regulate the relationships between the bank and the client in the provision of services associated with financial instruments. The Conditions and the relating documents are available below and at all Swedbank branches. Swedbank advises you to carefully read the Conditions for Providing Investment Services and the other documents available below.

Additional information

1. General Information of Swedbank

The contact details of Swedbank are given under the menu option About Swedbank. Clients can contact Swedbank and request documents and information from Swedbank in Estonian, Russian and English. The ways in which information can be exchanged between Swedbank and its clients are specified in the General Terms and Conditions of the Bank, the Conditions for Providing Investment Services or in the terms and conditions of other agreements entered into between Swedbank and its clients.

Swedbank is supervised by the Financial Supervision Authority (address: Sakala 4, 15030 Tallinn, Republic of Estonia; telephone: 6 680 500; fax: 6 680 501; e-mail:; website: Swedbank belongs to the Swedbank Group (

2. Investment Services Provided by Swedbank

Swedbank operates in Estonia on the basis of the authorisation of a credit institution and may therefore provide financial services and the investment services and ancillary services specified in the Securities Market Act. Swedbank is engaged in the following investment activities and offers the following investment services and ancillary services:

  • reception and transmission of orders in relation to financial instruments;
  • execution of orders relating to financial instruments on behalf or on account of clients;
  • dealing with financial instruments on its own account;
  • securities portfolio management;
  • investment advice;
  • underwriting of financial instruments or placing of financial instruments on a firm commitment basis;
  • placing of financial instruments without a firm commitment basis;
  • safekeeping and administration of financial instruments for the account of clients and related services;
  • granting credits or loans to an investor for transactions in financial instruments;
  • advice to undertakings on capital structure, industrial strategy and related matters and advice and services relating to mergers and the purchase of undertakings and related services;
  • services associated with foreign exchange;
  • investment research and financial analysis relating to transactions in financial instruments;
  • services related to underwriting;
  • provision of other investment and ancillary services in association with derivative instruments.

Please note that use of investment services entails specific risks, which are described in the document Brief Summary of the Risks and Fees Relating to Securities available below and in Appendix 1 to the Conditions for Providing Investment Services. Swedbank advises you to carefully read the descriptions of different risks before you make your investment decisions. You can obtain an overview of the safekeeping of your securities in Swedbank and the measures taken to protect them, and the investment guarantee schemes effective in the Republic of Estonia from the Conditions for Providing Investment Services.

Information about the costs and fees related to the use of investment services is available in the Conditions for Providing Investment Services and the Swedbank price list, which you can view through our homepage or pick up at any Swedbank branch.

3. Classification of Clients for Provision of Investment Services

Pursuant to the Securities Market Act and the Conditions for Providing Investment Services, Swedbank categorises the clients to whom it provides investment or ancillary services as retail clients, professional clients or eligible counterparties. The purpose of categorisation is to apply investor protection to each client that corresponds to their knowledge, skills and experience.

Unless you are or have been notified otherwise by Swedbank, you have been categorised as a retail client, which gives you the most extensive investor protection provided by law. This means that Swedbank must give you more information about investing and, if necessary, assess whether you are financially capable of bearing the obligations arising from the investment and whether you understand all associated risks. Swedbank is obliged to give less information about investing to persons categorised as professional clients (mainly financial institutions, large companies or state institutions) and Swedbank may assume that the experience and skills of the client are on a certain level. There are also differences in the execution of the purchase and sales orders of financial instruments of retail clients and professional clients, which are described in the document Execution Policy of Swedbank AS available below. Swedbank has the right to provide certain services to clients categorised as eligible counterparties (e.g. another bank) without the implementation of investor protection.

Clients have the right to request to be categorised differently by Swedbank pursuant to the procedure established in the bank. A retail client may request re-categorisation as a professional client if the client has in his own opinion sufficient experience, knowledge and expertise for making investment decisions and adequately assessing related risks and if at least two of the following criteria are satisfied: the client has carried out transactions, in significant size, on the securities market at an average frequency of 10 per quarter over the previous four quarters, the size of the client’s financial instrument portfolio exceeds EUR 500,000, the client works or has worked in the financial sector for at least one year in a professional position, which requires knowledge of investing in financial instruments. A professional client may request re-categorisation as a retail client if the client can not in his own opinion assess or manage the risks related to services and transactions. According to the procedure laid down in Swedbank, re-categorisation of an eligible counterparty and treating a professional client as an eligible counterparty in case of certain services is also possible. Please note that changing your client category means that the extent of investor protection applicable to you will also change as described above.

4. Managing conflicts of interest

The diversity of investment services listed above and the other services offered by the Swedbank Group can sometimes cause conflicts of interest inside Swedbank or the Swedbank Group and also between Swedbank or its employees and clients or between different clients of Swedbank. Swedbank applies certain measures to avoid such conflicts of interest, which are described in the document Possible Situations and Measures for Prevention of Conflicts of Interest available below. For example, Swedbank has laid down respective internal rules (incl. code of ethics for employees), separates both organisationally and physically potentially conflicting functions and controls keeping of confidential information by employees. The fees that Swedbank is entitled to for sales of the units or shares of funds managed by certain management companies have been disclosed to clients in the document Fund Management Fees that is also available below.

5. Rules for execution of orders

In addition to the Conditions of for Providing Investment Services, a special agreement, if agreed between Swedbank and the client, and the Best Execution Rules of Swedbank available below apply to the receipt, transmission and/or execution of buy/sell orders of financial instruments. The Best Execution Rules stipulate the terms, conditions and principles based on which Swedbank shall execute and transmit the orders in financial instruments of Swedbank’s clients. The Best Execution Rules describe the methods of submitting such orders and the factors which are taken into account when executing the orders. In addition, the rules refer to trading venues (e.g. stock exchanges) and brokers, which are used for execution or transmission of orders. In executing or transmitting the clients’ orders, Swedbank follows the Best Execution Rules as much as possible, except, for example, in the case where the client gives specific instructions regarding his order. According to the Best Execution Rules, the client’s order may be executed outside a regulated market or multilateral trading facility. Swedbank presupposes that the client reads the Best execution Rules before submitting a buy/sell order of financial instruments.

6. Complex and non-complex financial instruments

According to the Securities Market Act, financial instruments are divided, inter alia, into complex and non-complex financial instruments. If a transaction with non-complex financial instruments is carried out at the initiative of the client, Swedbank is not required to assess the suitability or appropriateness of the financial instrument or services to the client. Non-complex financial instruments are:

  • shares admitted to trading on a regulated securities market or in an equivalent third country market;
  • money market instrument;
  • bonds or other forms of securitised debt (excluding those that embed a derivative);
  • UCITS;
  • other financial instruments that correspond to certain statutory conditions.