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Information for consumers about our accessible services

According to Section 14 Paragraph 1 No. 2 in conjunction with Annex 3 of the BFSG, we are obliged to make information on how the investment services offered work accessible to the general public in a barrier-free form. This information must also explain how we meet legal accessibility requirements in relation to the investment services we offer. All consumers should have easy access to the services offered and not have to rely on outside help. It is intended that the level of difficulty of the information does not exceed language level B2 of the Common European Framework of Reference for Languages ​​of the Council of Europe. This means that it can be assumed that the most important content can be understood even in complex texts on concrete and abstract topics.

 

1. What investment services do we offer?

We offer the following investment services:

  • Financial portfolio management (asset management)
  • Investment advice
  • Investment brokerage
  • Final placement

 

2. On financial portfolio management (asset management)

Colloquially, asset management is defined in the legal regulations as “financial portfolio management”. For this service we provide the following information 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 will buy or sell for your securities portfolio and at what point in time. We are not required to obtain your prior consent. A securities account is a special bank account in which the securities are recorded.

In order to carry out asset management, you need a securities account as well as a clearing account. The amounts of money with which the securities are purchased are recorded on this. The revenue generated from sales is also credited to the clearing account. Furthermore, income from asset management is credited to the clearing account and costs are debited. In addition to a clearing account in euros, there may also be one or more in a foreign currency. Securities deposits and clearing 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 stocks, 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 the subject of asset management.

2.4 Further explanations for understanding asset management

With asset management, your assets should be invested in your interests and according to your individual needs. To do this, we first need to obtain some personal data from you 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 burdens and thus the amount that is available to you for investment?)
  • Your investment goals (= What do you want to achieve by investing your assets? Examples: long-term asset accumulation or retirement security)
  • Your investment horizon (= For how long do you want to invest your money? Long-term for several years or just short-term for a few months? When do you need the money again?)
  • Your risk tolerance (= what fluctuations in value or losses in the managed portfolio are you willing 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 goals be promoted?)
  • Your knowledge and experience in investing (= what level of knowledge do you have about the risks associated with the investment?)

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

In order to carry out our asset management activities, we require a bank power of attorney from you. This only entitles us to initiate purchases and sales on your securities account maintained by the bank. The power of attorney precludes us from transferring your assets to our account or to other accounts.

Before we conclude an asset management contract with you, we will also inform you about the expected costs.

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

After concluding the asset management contract, after opening the securities account including the clearing account and after granting the power of attorney, we begin asset management. From this point on, we act independently and buy and sell financial instruments for you. When making our decisions, we take into account the investment guidelines agreed with you.

2.5 Our regular information about asset management

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

The reports can 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 in the reporting period?)
  • Fees and costs (= How high were the costs for asset management in the reporting period?)
  • Balance of your clearing account at the beginning and end of the reporting period
  • Payments received, e.g. B. Dividends and interest
  • Individual transactions, i.e. purchases and sales of financial instruments, if you do not receive regular information about them from the custodian bank.
  • Explanation of suitability, i.e. an explanation of how the purchases and sales initiated 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 losses in your portfolio exceed certain thresholds. A threshold is reached when the initial value of your portfolio has fallen by a certain percentage during the reporting period. The law specifies a threshold of 10 percent. You will then receive another loss notification if the initial value of your portfolio has fallen by another 10% during the reporting period. However, lower thresholds can also be agreed in the asset management contract.

2.6 During the term of asset management

The asset management contract does not have a fixed term. You can terminate the contract at any time and without notice. Termination cannot be declared verbally, but must be made in text form (e.g. by email).

In contrast, we can only terminate the contract by adhering to the notice period agreed in the asset management contract.

2.7 The costs of asset management

You will receive separate information about the costs of asset management at the beginning. We receive regular compensation for carrying out asset management. This amounts to a certain percentage of the volume that we manage for you (so-called fixed remuneration).

The bank will invoice the costs for maintaining the securities account and clearing accounts in addition. This also applies to the costs of acquiring or selling the financial instruments. Instead of charging the costs for the various issues separately, the bank can also agree on a flat rate of costs with you (so-called “all-in fee”).

2.8 When does the right of withdrawal exist?

A right of withdrawal only exists if the asset management contract was not concluded on our premises, but rather, for example, over the Internet or over the 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 cancellation instructions. You will be informed about all further details of the revocation. The cancellation period of two weeks only begins when the contract has been concluded and we have correctly given you the cancellation instructions.

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

 

3. How do we meet accessibility requirements?

The legal regulations oblige us to meet certain accessibility requirements when providing the investment service. We ensure this as follows:

3.1 Accessibility of this information

We make this information available to you via various sensory access options. These are:

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

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 corresponds to the general principles of barrier-free web content. These are:

  • Perceptibility: As many users as possible should be able to access the information and other functions. To do this, we ensure that alternative texts explaining images, graphics and videos are available.
  • Usability: As many users as possible should be able to use the functions. To do this, we ensure that the web content can be operated with a keyboard.
  • Understandability: We make the web content readable for as many users as possible and, if possible, in simple language.
  • robustness: The web content is compatible with assistive technologies. This means they are suitable for programs for reading aloud, enlarging texts or converting speech into text.

3.3 Accessibility of asset management

The asset management contract is concluded in text form with your personal signature. The other documents are also usually provided in text form. Graphical representations in the documents are accompanied by descriptions. All documents in text form can be read out and explained in detail.

Once the asset management contract has been concluded, asset management generally takes place without any further personal communication. We make individual investment decisions without consulting you.

 

4. The responsible market surveillance authority

The responsible authority for monitoring compliance with accessibility requirements is:

Market monitoring 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
PO Box 39 11 55
39135 Magdeburg

Telephone: 0391 567 6970
E-mail: ed.tlahna-neshcas.sm@FBLM.

As of: June 28, 2025