Accessibility

Information for Consumers on Our Accessible Services

Financial Portfolio Management (Asset Management)

 

Address

investify S.A.
46, Grand Rue
6630 Wasserbillig
Luxembourg

Contact

+352 278 628 68
service-b2c@investify.com

We are legally obligated to make information on the functioning of the investment services offered accessible to the general public in an accessible format. This information must also explain how we meet the legal accessibility requirements for the investment services we offer. All consumers should have easy access to the services offered without needing external assistance. The information is intended to not exceed language level B2 of the Common European Framework of Reference for Languages of the Council of Europe. This means it can be assumed that the main content of complex texts on concrete and abstract topics will be understood.

Table of Contents

1. What investment services do we offer?

2. On Financial Portfolio Management (Asset Management)

3. How do we meet accessibility requirements?

4. The Competent Market Supervisory Authority

1. What investment services do we offer?

We offer the following investment services:

  • Financial Portfolio Management (Asset Management)

2. On Financial Portfolio Management (Asset Management)

The colloquial term ‘Vermögensverwaltung’ (asset management) is defined in legal provisions as ‘Finanzportfolioverwaltung’ (financial portfolio management). For this service, we provide the following information and will only use the colloquial term ‘Vermögensverwaltung’ (asset management).


2.1 General Description

Within the scope of asset management, we decide independently and without prior consultation with you which financial instruments we buy or sell for your securities account and at what time. We are not obliged to obtain your prior consent. A securities account is a special bank account where securities are recorded.

For the execution of asset management, you need a settlement account in addition to the securities account. This account records the monetary amounts used to purchase the securities. Proceeds from sales are also credited to the settlement account. Furthermore, income from asset management is credited to the settlement account, and costs are debited. In addition to a settlement 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?

‘Independent’ asset management refers to a situation where the asset manager is not in a dependent relationship with 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, and
  • Shares in investment funds

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


2.4 Further Explanations for Understanding Asset Management

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

  • Your Financial Situation (Example questions: How much money do you have left at the end of the month, how long can you live on your reserves?)
  • Your Investment Goals (= What is important to you when investing? e.g., acting conservatively, beating returns)
  • Your Investment Horizon (= How long do you want to invest your money? e.g., long-term for more than 5 years or only short-term (up to 3 years).
  • Your Risk Appetite (= What value losses in the managed portfolio are you willing to accept?)
  • Your Sustainability Preferences (= Should ecological or social criteria be considered in the investment? Examples: Should investments in certain economic sectors be excluded or certain environmental or social goals be promoted?)
  • Your Knowledge and Experience in Asset Investment (= What level of knowledge do you have 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 are an integral part of the asset management agreement to be concluded and bind us in the ongoing selection of investments.

For our activities within the scope of asset management, we require a bank power of attorney from you. This only authorizes us to initiate purchases and sales in your securities account managed by the bank. The power of attorney explicitly excludes the transfer of your assets to our account or any other accounts.

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

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

After the conclusion of the asset management agreement, the opening of the securities account including the settlement account, and the granting of the power of attorney, we begin with asset management. From this point on, we act independently and buy and sell financial instruments for you. In doing so, we consider the investment guidelines agreed upon with you in our decisions.


2.5 Our Regular Information on Asset Management

You will receive regular reports from us with specific information on the execution of asset management. As a rule, the information refers to a specific past period. This is the reporting period. This usually comprises 3 or 12 months. Some information in the report refers to a cut-off date. This cut-off 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 cut-off date? How much were the individual financial instruments worth on the cut-off 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 during the reporting period?)
Account balance of your settlement account at the beginning and end of the reporting period
Received payments, for example, dividends and interest
Individual transactions, i.e., purchases and sales of financial instruments, provided you do not receive regular information about these from the custodian bank.
Suitability explanation, i.e., an explanation of how the initiated purchases and sales complied with the agreed investment guidelines.
We usually inform you about the current composition and performance of your portfolio four times a year (quarterly).

We will also inform you if the value losses of your portfolio exceed certain thresholds. A threshold is reached if the initial value of your portfolio has fallen by a certain percentage during the reporting period. The law specifies a threshold of 10 percent. Subsequently, you will receive a new loss notification each time the initial value of your portfolio falls by another 10% during the reporting period. However, lower thresholds can also be agreed upon in the asset management agreement.


2.6 On the Term of Asset Management

The asset management agreement has no fixed term. You can terminate the contract at any time with the notice period agreed upon in the asset management agreement. Termination cannot be declared verbally but must be in text form (e.g., by email).

Conversely, we can terminate the contract with a notice period agreed upon in the asset management agreement.


2.7 On the Costs of Asset Management

You will receive separate information about the costs of asset management at the beginning. We receive regular remuneration for carrying out asset management. This amounts to a certain percentage of the volume we manage for you (so-called fixed remuneration). In addition to the fixed remuneration, a so-called variable remuneration may also apply. This is levied 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 with a certain percentage of the value change above this minimum performance. However, losses from previous calculation periods must first be offset.
The percentage of the fixed and, if applicable, variable remuneration as well as further billing details are agreed upon in the asset management agreement and the price list.

The costs for managing the securities account and settlement accounts by the bank are additionally charged by the bank. This also applies to the costs for the acquisition or sale of financial instruments. Instead of charging the costs for the various matters separately, the bank can also agree on a flat-rate cost ratio with you.


2.8 When is there a Right of Withdrawal?

A right of withdrawal exists if the asset management agreement was concluded online. You can then withdraw from the asset management agreement within two weeks. In this case, you will receive separate legal information from us in the form of a withdrawal instruction. This will inform you about all further details of the withdrawal. The two-week withdrawal period only begins when the contract has been concluded and we have correctly provided you with the withdrawal instruction.

Note: Even if you withdraw from the asset management agreement, the financial instruments acquired or sold for you remain unaffected. This means that the purchases or sales initiated by us until the withdrawal will not be reversed despite the withdrawal.

3. How do we meet accessibility requirements?

Legal regulations oblige 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 this information to you via various perceptually accessible channels. These are:

  • By retrieving it from our company website.
  • Through the read-aloud function of documents, websites, and apps
  • Reading aloud by your advisor (if applicable)

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. (description of usability follows, e.g., typography, font, line lengths, line spacing)


3.2 Accessibility of Our Website

You can find information about our company and the services offered on our website. The content of our website complies with the general principles for accessible web content. These are:

  • Perceptibility: 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.
  • Operability: As many users as possible should be able to operate the functions. To this end, we ensure that web content can be operated with a keyboard.
  • Understandability: For as many users as possible, we design web content to be readable and, if possible, in simple language.
  • Robustness: The web content is compatible with assistive technologies. This means it is suitable for programs for reading aloud, enlarging texts, or converting speech to text.


3.3 Accessibility of Asset Management

3.3.1 Digital Conclusion of the Asset Management Agreement

The asset management agreement will 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. We strive to meet all security and data protection standards and design them as explained above in Section 3.2. The individual steps up to the conclusion of the contract are completed electronically as follows. The order may differ:

  • Registration: To begin, you register on the online platform.
  • Submission of the questionnaire to determine your investor profile: You answer a questionnaire about your financial situation, investment goals, risk appetite, and your knowledge and experience in the securities sector. This information is necessary to offer you individually suitable investment guidelines.
  • Proposal of suitable investment guidelines: Based on your information, you will receive a tailored proposal for suitable investment guidelines.
  • Digital contract conclusion: After your consent to the proposed investment guidelines, you can conclude the asset management agreement and all other relevant documents electronically with a click.
  • Identity verification: Before or after (depending on the identity/signature service used), a legally required identity verification takes place. This is done via video identification procedure and in some cases, it is also possible at a post office branch.
  • Account opening and start of asset management: Finally, a securities account is opened digitally for you at the custodian bank, if one does not already exist.
  • Then we begin implementing your investment guidelines. This generally occurs without further personal communication. We make individual investment decisions without consulting you.

The digital onboarding process can be interrupted at any time and continued on different devices without losing data.

All retrieved documents generally comply with accessibility requirements and are particularly perceptible and understandable. If necessary, the documents can be read aloud and explained.

3.3.2 Evaluation Methods

Various methods were used to assess accessibility, including manual tests to check keyboard navigation, color contrasts, structure, and alternative texts, as well as the use of assistive technologies such as screen readers.

3.3.3 Status of Compliance with Requirements

We implement the accessibility requirements based on the law of March 8, 2023, and the Accessibility Strengthening Act (BFSG). In doing so, we adhere to the specific requirements of the Accessibility Ordinance (BFSGV).
Our measures are based on the Web Content Accessibility Guidelines (WCAG) 2.2 standards at levels A and AA. Level AAA requirements are not mandatory according to EN 301 549, but we implement them additionally in certain cases to further improve accessibility.

3.3.4 Known Barriers

Despite our efforts, the following barriers currently exist:

  • Occasionally, interactive elements do not have meaningful ARIA attributes.
  • In some areas, semantic HTML is not yet consistently used.
  • Occasionally, color contrasts and keyboard navigation are not yet fully optimized.
  • PDF documents or embedded third-party content may not be accessible.

We are continuously working to improve accessibility.

4. The Competent Market Supervisory Authority

In Luxembourg, the following authority is responsible for monitoring compliance with accessibility requirements under the Accessibility Strengthening Act (BFSG):
Office de la Surveillance de l’Accessibilité des Produits et Services (OSAPS)
Ministère de la Famille, des Solidarités, du Vivre ensemble et de l’Accueil
L-2975 Luxembourg
www.osaps.lu
Email: accessibilite@fm.etat.lu

This authority is officially responsible for market surveillance, effective June 28, 2025, in accordance with Luxembourg’s implementation of EU Directive 2019/882 (EAA) through the law of March 8, 2023.

5. Accessibility Statement

This statement was created on June 28, 2025, and is reviewed annually to ensure it is up to date.

6. Feedback and Contact

If you encounter barriers or have suggestions for improving accessibility, please contact us:

Email: service-b2c@investify.com

Phone:
Luxembourg Office: +352 278 628 68
Germany Office: +49 221 650 888 00

Address:
Luxembourg Office: investify S.A., Josef-Lammerting-Allee 25, D – 50933 Köln
Germany Office: investify S.A., 46 Grand Rue, L – 6630 Wasserbillig