Information for consumers about our accessible services

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.

1. Which investment services do we offer?

We offer the following investment services:

• Financial portfolio management (asset management)
• Investment brokerage

We are also licensed to provide investment advice (BaFin license, not currently exercised) and to act as an intermediary (BaFin license, not currently exercised).

2. For investment brokerage (brokerage)

Investment brokerage is also referred to as "non-advisory business". This is because no recommendation is given. We merely broker a transaction for you to buy or sell a financial instrument. We do not consider whether this transaction corresponds to your investment objectives, your risk appetite or your sustainability preferences. All that matters is whether you have sufficient knowledge or experience to understand the risks associated with the transaction.

2.1 General description

In the case of investment brokerage, we forward the buy or sell order you have already signed in relation to a transaction involving a financial instrument to the recipient of the declaration. We do not act in our own name or with a power of attorney on your behalf. In practice, this service is often simply referred to as "brokerage".

2.2 What are financial instruments?

Brokerage relates 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 brokerage as an investment service.

2.3 Further explanations for understanding the mediation

You must be able to understand the economic risks resulting from the transaction. To do this, we need to determine your knowledge and experience of investing at the outset. It is important to know what we — unlike in the case of investment advice — do not check:

• Your financial circumstances are not relevant.
• Your investment objectives (e.g. retirement provision) are not relevant.
• Your investment horizon is not relevant.
• Your risk appetite is not relevant.
• Your sustainability preferences are not relevant.

Before we conclude an agency contract with you, we will also inform you of the expected costs. All important legal details are regulated in the agency contract.

2.4 Assessment of appropriateness

When brokering, we only check the appropriateness of the investment. The investment is appropriate if your knowledge and experience are sufficient for you to understand the economic risks associated with the financial instrument brokered. This is an internal check. You will not receive any separate confirmation of this.

2.5 What is "pure execution" and "execution only"?

In practice, brokerage also occurs in what is known as "execution only". This means that no appropriateness test is carried out during the placement. However, mediation without checking your knowledge and experience is only permitted under special legal conditions. Among other things, you must take the initiative for the placement. Furthermore, brokerage without an appropriateness test is not permitted for complex financial instruments.

2.6 What information do you receive about the brokered transaction?

In the case of an order to purchase a financial instrument, you will receive additional information and instructions from us prior to the execution of the brokerage, insofar as these are available (e.g. product information, sales prospectus, key investor information). If you receive information on the execution of the order from a third party (e.g. custodian bank), we are not obliged to send it to you again.

2.7 Term and costs of the brokerage agreement

The brokerage contract does not have a fixed term and is generally completed upon execution of the specific transaction. If brokerage transactions are to be commissioned over a longer period of time, we can conclude a corresponding contract. You can terminate this contract at any time and without notice in text form (e.g. by e-mail).

We receive a fee for the brokerage, which amounts to a certain percentage of the investment volume. In addition, the custodian bank may incur costs for custody account management or transaction costs.

2.8 Right of withdrawal

There is a right of revocation if the brokerage contract was concluded outside our business premises — for example via the Internet or by telephone. In this case, you can cancel the contract within two weeks. The period only begins once you have received the statutory revocation instructions.

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:

• personal in paper form,
• read out by employees,
• or digitally via our company website.

The content is formulated in understandable language (language level B2). Language level B2 does not apply to contracts and pre-contractual information.

3.2 Accessibility of our website

Our website complies with the general principles for accessible web content. It is designed to be perceivable, operable, understandable and robust. Images and graphics contain alternative texts and the content is compatible with assistive technologies.

3.3 Accessibility of mediation

The brokerage contracts can be concluded in text form or digitally. When concluding digitally, the process is user-friendly and barrier-free. All documents can be read aloud and explained.

4. The competent market surveillance authority

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

The MLBF is still being set up, but is already accepting requests and forwarding them to the relevant state authorities.