Information for consumers about our accessible services

Contact details:
CapTrader GmbH
Elberfelder Straße 2
40213 Düsseldorf
Email: invest@captrader.com
Phone: 0800-08723370

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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. Description of financial portfolio management (asset management)

   1. General description

   2. What is asset management in a managed account?

   3. What is asset management in social trading?

   4. What are financial instruments, what are derivatives, what are short sales and what is margin?

   5. Our regular information on asset management

   6. On the term of the asset management agreement

   7. On the costs of the asset management agreement

   8. When is there a right of withdrawal?

3. How do we meet the accessibility requirements?

   1. Accessibility of this information

   2. Accessibility of our forms (customer information form, customer information text, contract)

   3. Accessibility in asset management

4. The competent market supervisory authority

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1. which investment services do we offer?

We offer financial portfolio management (asset management) in the following variants:

• Managed account (with various investment guidelines)

• Implementation of SocialTrader proposals

2. description of 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 with which the securities are purchased 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". We are also entitled to utilize any credit (margin) granted by the bank for asset management purposes.

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.

2.2 What is asset management in a managed account?

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 situation (= 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 with the investment of your assets? Examples: long-term wealth accumulation or retirement provision)

• Your investment horizon (= For what period 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 willingness to take risks (= 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 in the investment? Examples: Should investments in certain economic sectors be excluded or should certain environmental or social objectives be promoted?)

• Your knowledge and experience in asset management (= 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 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 set out in the asset management agreement. You will also receive an information brochure on our services and the risks.

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.

2.3 What is asset management in social trading?

If you have subscribed to a stock market letter or a model portfolio with a third party (so-called social trading) and have given the third party a corresponding order to transmit the investment examples or trading signals to us, we will implement these as part of the asset management for your account and custody account with your bank. This is subject to the stock market letter or model portfolio provider having concluded a corresponding contract with us.

In all other respects, the above applies to asset management in the managed account. In contrast to the Managed Account, however, we are entitled to receive financial contributions from your bank and to pass them on in full or in part to the issuer of the stock market letter or model portfolio.

2.4 What are financial instruments, what are derivatives, what are short sales and what is margin?

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.

Forms of investment in which the return, but also the risk, does not relate exclusively to the assets deposited with the bank are subject to the particular risk of an obligation to make additional contributions to the bank. These include derivatives, which are forward transactions, and short sales, which are sales of financial instruments that the customer does not own. Margin is a general investment on credit against a pledge of the financial instruments held in the customer's account and custody account. With these forms of investment, your assets deposited with the bank may be used to cover a loss and, in extreme cases, your other free assets may even be liable to the bank for losses. Please read our and the bank's risk information carefully. If you have received margin trading, short selling and derivatives authorization from the bank, we are entitled to make these types of investments in our asset management.

2.5 Our regular information on asset management

You will receive regular reports from us with specific information on the implementation of asset management. These will be sent to you by e-mail or posted in the notification and overview center of your electronic account and custody account management system provided by your bank. 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?)

• 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 receiveddividends and interest, for example

• Suitability statementThe statement of compliance, 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 loss in value of your portfolio exceeds certain thresholds. A threshold value is reached if the initial value of your portfolio or an individual financial instrument that may be subject to margin calls 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 has fallen by another 10% in the reporting period. However, lower thresholds can also be agreed in the asset management contract.

2.6 Term of the asset management agreement

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 Costs of the asset management agreement

You will receive separate information on the costs of asset management in the information brochure 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 achieved in 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 first be offset.

The percentage of the fixed and, if applicable, variable remuneration and other settlement details are agreed in the asset management agreement.

In the case of asset management in the form of social trading (see above), we are entitled to receive financial inducements from your bank and to pass them on in full or in part to the issuer of the stock market letter or model portfolio.

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 statutory 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 written in easy-to-understand language. Language level B of the Common European Framework of Reference for Languages is not exceeded.
Please note: This language level does not apply to the contract and the associated pre-contractual information.

For better readability, the layout of this information is in Arial font with a font size of 14 points.

3.2 Accessibility of our forms (customer information form, customer information text, contract)

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.

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 difference is that the individual steps leading up to the conclusion of the contract are not carried out in paper form, but electronically as follows:

• Submission of the questionnaire to determine your investor profile: You answer a questionnaire about 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 your details, you will receive a customized proposal for the investment guidelines that are right for you.

• Identity check and digital contract signing: Once you have agreed to the proposed investment guidelines, you can sign the asset management agreement 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 ID card) or by the advisor directly.

• Opening of custody account and start of asset management: Finally, you must open a digital securities account with the custodian bank.

• 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 is usually accompanied by an employee who goes through the entire route 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 understandable. If necessary, the documents can be read aloud and explained.

4. the competent market supervisory 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)
Ministry of Labor, Social Affairs, Health and Equality of the State of Saxony-Anhalt, Department 3 "Social Affairs and Occupational Safety"
Turmschanzenstrasse 25
39114 Magdeburg

Phone: 0391 567 4530
Email: MLBF(at)ms.sachsen-anhalt.de

Contact details:
CapTrader GmbH
Elberfelder Straße 2
40213 Düsseldorf
Email: info@captrader.com
Phone: 0800-08723370

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According 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 services offered accessible to the general public in an accessible form. This information must also explain how we meet the legal requirements for accessibility in relation to the 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 support services do we offer?

2. Description of the support service

   1. General description

   2. Support service for opening an account/custody account with Interactive Brokers

   3. Support service for the operation of the Interactive Brokers system

   4. The term of the contract

   5. On the costs of the support service

   6. When is there a right of withdrawal?

3. How do we meet the accessibility requirements?

   1. Accessibility of this information

   2. Accessibility of our website (including general terms and conditions and customer information text)

   3. Accessibility in the service sector

4. The competent market supervisory authority

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1 What support services do we offer?

We offer support in operating the order transmission and account and securities account management system provided to you by your account and securities account-holding bank Interactive Brokers after you have opened your account and securities account there. We do not offer investment advice or order transmission services or any other banking or securities services. We also do not offer IT support.

2. description of the support service

The support service does not include any investment services. Rather, the client makes his investment and trading decisions entirely on his own responsibility. We only provide assistance in the event of problems in understanding how to use the electronic system provided to the client by the bank. We are not representatives of the bank. Our support service is therefore an independent and autonomous "first level support" for your operation of the bank system.

2.1 General description

During our opening hours (08:30 - 19:30) during our business days (trading days of the Frankfurt Stock Exchange or opening days of the client bank), questions about the operation of the banking system can be asked by telephone or email. The same applies to the electronic account and custody account opening application at your bank. We cannot answer other questions, for example tax or legal questions. We do not manage your account or custody account and do not accept or execute orders for transactions in financial instruments. We therefore have no access to the assets deposited in your account and custody account at your bank, which means that we cannot, for example, initiate custody account transfers or account closures. In this respect, we can also only support you in your use of the banking system by answering relevant questions. We do not independently monitor the messages from your bank that it enters into the banking system for you in your message area. Please note our General Terms and Conditions (GTC) and our customer information on support services.

2.2 Support service when opening an account/custody account with Interactive Brokers

If you require assistance with opening an account and custody account online, we are available to you by telephone ... and by email ..... You must provide your bank with complete and truthful information about your personal circumstances. This is for your protection. Please read the information provided by the bank carefully, especially the risk information. We are not aware of your bank's criteria for entering into the business relationship or certain trading authorizations. Our support service relates exclusively to the general handling of the online form, technical questions or explanations of terms. However, only your bank is responsible for accepting or rejecting the opening of an account or securities account or the approval of certain trading authorizations.

2.3 Support service for the operation of the Interactive Brokers system

Interactive Brokers provides you with an electronic order transmission system and an electronic account/custody account management system. Our support service relates exclusively to the operation of this system. During our opening hours (08:30 - 19:30) during our business days (trading days of the Frankfurt Stock Exchange or opening days of the customer's bank) you can ask us questions about the operation of the banking system by telephone or e-mail. We are unable to answer other questions, for example tax or legal questions. We do not manage your account or custody account and do not accept or execute orders for transactions in financial instruments. We therefore have no access to the assets deposited in your account and custody account at your bank, which means that we cannot, for example, initiate custody account transfers or account closures.
We do not independently monitor the messages from your bank that it enters into your message area in the tape system for you. Please note our General Terms and Conditions (GTC) and our customer information on the support service.

2.4 Duration of the support service

The contract for the support service 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 GTC. We reserve the right to terminate the contract for good cause with immediate effect.

2.5 Costs of the support service

We will inform you about the costs of the support service in the customer information sent to you. We receive payments (so-called inducements) from your bank, which are financed by the bank fees charged to you. These can amount to up to 100% of the fees charged by the bank. We will be happy to inform you of the specific amount on request.

2.6 When is there a right of withdrawal?

A right of withdrawal only exists if the contract was not concluded in our business premises, but for example via the Internet or by telephone. You can then cancel the contract within two weeks. In this case, you will receive separate legal information from us in the form of the cancellation policy. 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.

3. how do we meet the accessibility requirements?

In accordance with legal requirements, we are obliged to disclose certain Accessibility requirements in the provision of our Support services to fulfill. We implement these requirements as follows:

3.1 Accessibility of this information

We make this information available to you via various sensory-accessible channels. This allows you to choose how you want to access the content:

• Personally in paper form: In our offices you can obtain the information in printed form on request - clearly structured and easy to read.

• Read aloud by our staffOur employees will be happy to read the contents to you personally - for example during a consultation.

• Online via our websiteThe information is available to you digitally on our website. There you can read it, enlarge it or have it read aloud to you using assistive technologies.

The contents of this information are in easy to understand language written. The Language level B of the Common European Framework of Reference for Languages (CEFR) are not exceeded.

Important noteThis simplified language level applies exclusively to the information provided - not to contracts or pre-contractual documents, as these must meet certain legal requirements.

For better Readability is the layout in the Arial font and with a Minimum font size of 14 point designed.

You also have the option of downloading this text from your browser. to be read aloud. Also the Adjusting the font size is possible depending on the browser.

3.2 Accessibility of our forms (customer information text, General Terms and Conditions)

Our customer information and our General Terms and Conditions (GTC) will be sent to you by email before the support service begins.

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

• Personal delivery in paper form at our business premises.

• Reading aloud by our employees.

• By accessing our company website.

3.3 Accessibility in the service sector

We offer our specific support services by email or by telephone. If you contact us by telephone at 0800-08723370 or by post at CapTrader GmbH, Elberfelder Straße 2, 40213 Düsseldorf, preferably with the keyword "accessibility" and, if you wish, with details of your support needs, we can try to make you an offer that goes beyond this or tailor our email/telephone support specifically to you.

4. the competent market supervisory 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)
Ministry of Labor, Social Affairs, Health and Equality of the State of Saxony-Anhalt, Department 3 "Social Affairs and Occupational Safety"
Turmschanzenstrasse 25
39114 Magdeburg

Phone: 0391 567 4530
Email: MLBF(at)ms.sachsen-anhalt.de.