Information for consumers about our accessible services

Here: Investment brokerage (brokerage)

(Section 14 (1) No. 2 in conjunction with Annex 3 BFSG)

Pursuant to Section 14 (1) No. 2 in conjunction with Annex 3 of the BFSG, we are obliged to make information on the functioning of the investment services offered accessible to the general public in an accessible form. This information must also explain how we meet the legal requirements for accessibility with regard to the investment services we offer. All consumers should have easy access to the services offered and should not be dependent on outside help. The level of difficulty of the information provided should not exceed level B2 of the Council of Europe's Common European Framework of Reference for Languages. This means that it can be assumed that the most important content of complex texts on concrete and abstract topics can also be understood.

Table of contents

1. What investment services do we offer?
2. About financial portfolio management (asset management)
   2.1 General description
   2.2 What is "independent" asset management?
   2.3 What are financial instruments?
   2.4 Further explanations to understand asset management
   2.5 Our regular information about asset management
   2.6 About the term of the asset management agreement
   2.7 About the costs of the asset management agreement
   2.8 When is there a right of withdrawal?
3. How do we meet accessibility requirements?
   3.1 Accessibility of this information
   3.2 Accessibility of our website
   3.3 Accessibility in asset management
4. The competent market supervisory authority

1. which investment services do we offer?

We offer the following investment services:

• Financial portfolio management (asset management)
• Investment brokerage

2. for financial portfolio management (asset management)

Colloquial asset management is defined in the legal regulations as "financial portfolio management". We provide the following information for this service and only use the colloquial term "asset management".

2.1 General description

As part of asset management, we decide independently and without prior consultation with you which financial instruments we buy or sell for your securities account and when. We are not obliged to obtain your prior consent. A securities custody account is a special bank account in which the securities are booked.

In addition to the securities account, you also need a clearing account to carry out asset management. The funds used to purchase the securities are booked to this account. The proceeds from the sales are also credited to the clearing account. Income from asset management and costs are also credited to the clearing account. In addition to a clearing account in euros, there may also be one or more in a foreign currency. Securities accounts and settlement accounts are not managed by us, but by a bank. These form the so-called "portfolio".

2.2 What is "independent" asset management?

We speak of "independent" asset management when the asset manager is not dependent on the products and services of a bank or insurance company. The selection of investments should be as free as possible from the sales interests of banks or insurance companies.

2.3 What are financial instruments?

Asset management refers to investment opportunities in the form of "financial instruments". Financial instruments include

• Securities, for example shares, bonds, certificates and warrants,
• Shares in investment funds and
• Derivatives.

Real estate, precious metals (e.g. gold), vintage cars, works of art and crypto assets (e.g. Bitcoin) are not financial instruments. They are therefore not subject to asset management.

2.4 Further explanations on the understanding of asset management

In asset management, your assets should be invested in your interests and according to your individual needs. To do this, we need to obtain some personal data from you at the beginning and also your wishes (= the investor profile) using a questionnaire as follows:

• Your financial circumstances (= how high are your assets, your current income and your current expenses and other charges and thus the amount available to you for investment).
• Your investment objectives (= what do you want to achieve by investing your assets? Examples: long-term wealth accumulation or retirement provision)
• Your investment horizon (= For how long would you like to invest your money? Long-term for several years or only short-term for a few months? When will you need the money again?)
• Your risk appetite (= what fluctuations in value or losses in the managed portfolio are you prepared to accept?)
• Your sustainability preferences (= Should ecological or social criteria be taken into account when investing? Examples: Should investments in certain economic sectors be excluded or should certain environmental or social objectives be promoted?)
• Your knowledge and experience in investing (= What is your level of knowledge about the risks associated with the investment?)

Based on this information, we will then recommend suitable investment guidelines for you. These investment guidelines must be designed to ensure that your portfolio meets your interests and needs. They form part of the asset management agreement to be concluded and bind us in the ongoing selection of investments.

We require a bank power of attorney from you for our asset management activities. This only authorizes us to initiate purchases and sales on your securities account managed by the bank. The power of attorney excludes the possibility of us transferring your assets to our account or to other accounts.

Before we conclude an asset management agreement with you, we will also inform you of the anticipated costs.

All important legal details are regulated in the asset management agreement.

Once the asset management agreement has been concluded, the securities custody account including the clearing account has been opened and the power of attorney has been granted, we begin asset management. From this point on, we act independently and buy and sell financial instruments for you. In making our decisions, we take into account the investment guidelines agreed with you.

2.5 Our regular information on asset management

You will receive regular reports from us with specific information on the implementation of asset management. As a rule, the information relates to a specific past period. This is the reporting period. This usually covers 3 or 12 months. Some of the information in the report relates to a reporting date. This reference date is usually the last business day of the reporting period.

The reports may contain the following information:

• Composition and valuation of your portfolio (= Which financial instruments were included in your portfolio on the reporting date? How much were the individual financial instruments worth on the reporting date?
• Performance of your portfolio and the benchmark (e.g. an index), if agreed with you, during the reporting period (= how did the value of your financial instruments and the benchmark develop during the reporting period?)
• Fees and costs (= How high were the costs for asset management in the reporting period?)
• Account balance of your clearing account at the beginning and end of the reporting period
• Payments received, for example dividends and interest
• Individual transactions, i.e. purchases and sales of financial instruments, unless you receive regular information about them from the custodian bank.
• Suitability statement, i.e. an explanation of how the purchases and sales initiated have complied with the agreed investment guidelines.

We usually inform you about the current composition and performance of your portfolio four times a year (every quarter).

We will also inform you if the loss in value of your portfolio exceeds certain thresholds. A threshold is reached when the initial value of your portfolio has fallen by a certain percentage in the reporting period. The law stipulates a threshold value of 10 percent. Subsequently, you will always receive another loss notification if the initial value of your portfolio has fallen by a further 10% during the reporting period. However, lower thresholds can also be agreed in the asset management contract.

2.6 On the term of asset management

The asset management contract has no fixed term. You can terminate the contract at any time without notice. Notice of termination cannot be given verbally, but must be given in text form (e.g. by e-mail).

In contrast, we ourselves can only terminate the contract subject to a notice period agreed in the asset management contract.

2.7 On the costs of asset management

You will receive separate information about the costs of asset management at the beginning. We receive a regular fee for carrying out the asset management. This amounts to a certain percentage of the volume that we manage for you (so-called fixed remuneration). In addition to the fixed remuneration, a so-called variable remuneration may also be payable. This is charged depending on the performance of the portfolio during the calculation period. However, this only occurs if the contractually agreed minimum performance has been exceeded. The variable remuneration is then calculated as a percentage of the change in value above this minimum performance. However, losses from previous calculation periods must be offset beforehand.
The percentage of the fixed and, if applicable, variable remuneration and other settlement details are agreed in the asset management agreement.

The costs for the management of the securities custody account and the clearing accounts by the Bank shall be charged additionally by the Bank. This also applies to the costs for the purchase or sale of financial instruments. Instead of charging the costs for the various matters separately, the bank can also agree a flat-rate fee with you (so-called "all-in fee").

2.8 When is there a right of withdrawal?

A right of revocation only exists if the asset management contract was not concluded in our offices, but for example via the Internet or by telephone. You can then revoke the asset management contract within two weeks. In this case, you will receive separate legal information from us in the form of the revocation instructions. This will inform you about all further details of the revocation. The revocation period of two weeks only begins once the contract has been concluded and we have correctly provided you with the revocation instructions.

Note: Even if you revoke the asset management agreement, the financial instruments purchased or sold for you remain unaffected. This means that the purchases or sales initiated by us up to the time of revocation will not be reversed despite the revocation.

3. how do we meet the accessibility requirements?

Legal regulations require us to meet certain accessibility requirements for the provision of investment services. We ensure this as follows:

3.1 Accessibility of this information

We provide you with this information via various sensory access options. These are

• Personal delivery in paper form at our business premises.
• Reading aloud by our employees.
• By accessing our company website.

The content of this information is formulated in understandable language. Language level B of the Common European Framework of Reference for Languages is not exceeded.

However, language level B2 does not apply to the contract and the associated pre-contractual information.

The layout of this information is specially designed. (hereinafter description of user-friendliness, e.g. typography, font, line lengths, line spacing)

3.2 Accessibility of our website

You can find out more about our company and the services we offer on our website. The content of our website complies with the general principles of accessible web content. These are

• Perceivability: As many users as possible should be able to perceive the information and other functions. To this end, we ensure that explanatory alternative texts are available for images, graphics and videos.
• Usability: As many users as possible should be able to use the functions. To this end, we ensure that the web content can be operated using a keyboard.
• Comprehensibility: We make the web content readable for as many users as possible and use simple language wherever possible.
• Robustness: The web content is compatible with assistive technologies. This means that they are suitable for programs for reading aloud, enlarging texts or converting speech into text.

3.3 Accessibility of asset management

3.3.1 Conclusion of the asset management agreement in text form

The asset management agreement is usually concluded in text form with your personal signature. The other documents are also generally provided in text form. Descriptions are attached to graphic representations in the documents. All documents in text form can be read aloud and explained in detail.

Once the asset management agreement has been concluded, asset management is generally carried out without any further personal communication. We make the individual investment decisions without consulting you.

3.3.2 Digital conclusion of the asset management agreement

The asset management agreement can also be concluded digitally (electronically) via a special digital program on an electronic medium (computer, tablet, etc.). The so-called "digital onboarding" makes it possible to conclude the asset management agreement online and paperless. The process is designed to be user-friendly. It meets all security and data protection standards and is structured as explained in section 3.2 above. The difference is that the individual steps up to the conclusion of the contract are not carried out in paper form, but electronically as follows:

• Registration: To begin, register on the online platform.
• Submission of the questionnaire to determine your investor profile: You answer a questionnaire on your financial situation, investment objectives, risk tolerance and your knowledge and experience in the securities sector. This information is necessary in order to offer you individually tailored investment guidelines.
• Proposal of suitable investment guidelines: Based on the information you provide, you will receive a customized proposal for suitable investment guidelines.
• Identity check and digital contract signature: Once you have agreed to the proposed investment guidelines, you can sign the asset management contract and all other relevant documents electronically. The electronic signature is made using a certified procedure. Before or after (depending on the identification/signature service used), a legally required identity check is carried out. This is carried out using the video ID procedure or eID (electronic identity card) or by the advisor directly.
• Opening a securities account and starting asset management: Finally, a securities account is opened digitally for you at the custodian bank, if this does not already exist.
• We will then begin to implement your investment guidelines. In principle, this takes place without any further personal communication. We make the individual investment decisions without consulting you.

The digital onboarding process can be interrupted at any time and continued on different end devices as required without any loss of data.

The digital onboarding process is usually accompanied by an employee who goes through the entire process with you and explains all the details in a comprehensible manner. You have the opportunity to ask questions at any time. All retrieved documents generally comply with accessibility requirements and, in particular, are perceptible and comprehensible. If necessary, the documents can be read aloud and explained.

4. the competent market surveillance authority

The authority responsible for monitoring compliance with accessibility requirements is

Market Surveillance Body of the Federal States for the Accessibility of Products and Services - MLBF (under construction)
c/o Ministry of Labor, Social Affairs, Health and Equality Saxony-Anhalt
P.O. Box 39 11 55
39135 Magdeburg
Phone: 0391 567 6970
E-mail: MLBF@ms.sachsen-anhalt.de