Declaration of accessibility

Financial portfolio management (asset management)

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

 

DJE Kapital AG

Pullacher Street 24

82049 Pullach

Pullach, Germany

 

Phone: +49 89 790453-0

Fax: +49 89 790453-185

E-mail: info@dje.de

 

 

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 available to the general public in an accessible form. This information must also explain how we comply with the legal accessibility requirements in relation 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 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.

 

What investment services do we offer?

We offer the following investment services:

• Financial portfolio management (asset management)

• investment advice

• Investment brokerage

• contract brokerage

 

Financial portfolio management (asset management)

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

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 custody 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".

 

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.

 

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,

• units 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.

 

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 (= what are your assets, current income and current expenses and other charges and therefore 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 do you want 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 tolerance (= 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 corresponds to 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 set out 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 will commence 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.

 

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 on this from the custodian bank.

• Suitability statement, 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 is reached when the initial value of your portfolio has fallen by a certain percentage during 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.

 

The term of the asset management contract

The asset management contract does not have a 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.

 

About 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 fee, a variable fee 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 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 are 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 cost ratio with you (so-called "all-in fee").

 

When is there a right of withdrawal?

There is only a right of withdrawal if the asset management agreement 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 contract, 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.

 

About investment advice

 

General description

 

In the context of investment advice, we provide you with a specific recommendation in relation to a specific financial instrument. The recommendation may be

• Purchase of a financial instrument

• Sale of a financial instrument

• Holding a financial instrument

• Advising against the purchase of a financial instrument

You decide whether or not to follow the recommendation. Once the recommendation has been made, the investment advice is complete. The execution of the recommendation, e.g. the purchase or sale of the financial instrument, is not part of the investment advice.

 

What is "portfolio-related" investment advice?

The normal case of investment advice relates to a single financial instrument. The term "portfolio-related" investment advice is used when the subject of the recommendation is an entire portfolio consisting of a securities account and a clearing account. These are managed by a bank.

In this form of advice, recommendations are regularly made to tailor the portfolio to your needs.

 

What are financial instruments?

Investment advice relates to the following financial instruments:

• Securities (e.g. shares, bonds, certificates, warrants)

• Shares in investment funds

• Derivatives

No financial instruments and therefore not the subject of advice: real estate, precious metals, vintage cars, works of art, crypto assets (e.g. Bitcoin).

 

Further explanations

Recommendations should be made in your interests and according to your needs.

 

Collection of personal data

To determine your investor profile, we will ask you about

• Financial circumstances

• investment objectives

• Investment horizon

• Risk appetite

• Sustainability preferences

• Knowledge and experience with investments

You will receive information on costs and legal details before concluding the contract.

 

Suitable recommendation

The recommendation must match your goals, preferences, financial circumstances and knowledge. Agreed investment guidelines apply to portfolio-related advice.

Declaration of suitability

You will receive a statement of reasons (suitability declaration) for each recommendation, unless you are classified as a professional client.

 

Execution of the recommendation

Execution is not investment advice, but investment or contract brokerage. Separate information is required for this. A combined contract is usually concluded.

 

Regular information

You will only receive regular reports with details of the composition, performance, costs, transactions and declaration of suitability if you receive portfolio-related advice with execution. Loss reports are also issued for losses of 10% or more.

 

Term

The contract is open-ended. Termination possible at any time (text form). Our notice period is set out in the contract.

 

Costs

You will receive information on fixed and, if applicable, variable remuneration. The latter depends on performance. Further costs are incurred for custody account management and trading, possibly as an "all-in fee".

 

Right of withdrawal

Cancellation possible when concluding a contract outside our premises (e.g. online). Deadline: 2 weeks from correct revocation instruction. Recommendations already made or transactions already executed remain valid.

 

How do we meet the accessibility requirements?

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

 

Accessibility of information

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

 

• Personal delivery in paper form in our offices.

• Reading aloud by our employees.

• By retrieving it from our company website.

 

The contents of this information are formulated in an 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)

 

Accessibility of our website

You can find information 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 design the web content to be readable for as many users as possible and preferably in simple language.

• Robustness: 
  The web content is compatible with assistive technologies. This means that it is suitable for programs for reading aloud, enlarging texts or converting speech into text.

 

Status of compatibility with the requirements

The website is currently not fully compatible with the technical requirements of the Web Content Accessibility Guidelines (WCAG) 2.2 and the Barrierefreie-Informationstechnik-Verordnung (BITV 2.0).

 

• Unlabeled or hidden headings

  Some pages contain headings that are hidden with aria-hidden.
  WCAG: 1.3.1 - Info and relationships

• Missing subordinate elements in HTML tags

  Structural HTML tags are sometimes incomplete, making screen reader navigation difficult.
  WCAG: 1.3.1 - Info and relationships

• Incorrectly structured tables

  Tables are sometimes not semantically labeled, which hinders the assignment of header and data cells.
  WCAG: 1.3.1 - Info and relationships

• Incorrectly structured lists

  Lists contain elements that are not correctly marked up as

• .
  WCAG: 1.3.1 - Info and relationships

   

• Insufficient color contrast

  Text on some pages has too little contrast to the background.
  WCAG: 1.4.3 - Contrast (minimum)

• Zoom function disabled by meta-viewport

  The meta-viewport prevents the page from being enlarged, which limits readability.
  WCAG: 1.4.4 - Change text size

• Scrollable elements that cannot be operated using the keyboard

  Scrollable areas are not fully accessible with the keyboard.
  WCAG: 2.1.1 - Keyboard

• Non-speaking names of interactive elements

  Some buttons and links are not correctly labeled, which makes voice control difficult.
  WCAG: 2.5.3 - Labeling in the name

• Links without link text

  Some links do not contain any meaningful text.
  WCAG: 4.1.2 - Name, role, value

• Form fields without labeling

  Some input fields are not labeled.
  WCAG: 4.1.2 - Name, role, value

• iFrames without labeling

  Embedded content is not sufficiently described.
  WCAG: 4.1.2 - Name, role, value

• Invalid or duplicate ARIA attributes

  Incorrect or multiple ARIA IDs are used.
  WCAG: 4.1.2 - Name, role, value

• Focusable decorative elements

  Non-interactive elements are incorrectly focusable.
  WCAG: 4.1.2 - Name, role, value

• iFrames with multiple assigned labels

  Some iFrames use identical labels, which can lead to confusion for screen readers.
  WCAG: 4.1.2 - Name, role, value

• Elements with roles without matching ARIA attributes

  Some elements are provided with roles, but do not contain the required ARIA attributes.
  WCAG: 4.1.2 - Name, role, value

• Buttons without labeling

  Some buttons are not sufficiently labeled, which makes them difficult to use with screen readers.
  WCAG: 4.1.2 - Name, role, value

• PDF documents before 28.06.2025

  Some PDFs published before 28.06.2025 are not accessible.
  WCAG: 1.1.1 - Non-text content

• Fund charts with performance curves

  These are currently not accessible.
  WCAG: 1.1.1 - Non-text content

• Videos without subtitles

  Older videos do not contain subtitles for hearing-impaired users.
  WCAG: 1.2.2 - Subtitles (recorded)

• Forms from HubSpot with contrast problems

  Embedded forms have contrast issues and missing labels.
  WCAG: 1.4.3 - Contrast (minimum), 3.3.2 - Labels or instructions

• App "My DJE" not accessible

  The app is currently not fully accessible. Web access is available as an alternative.
  WCAG: General non-compliance with several criteria

• Onboarding route & Solidvest custody account access

  Not yet fully accessible, but will be gradually adapted.
  WCAG: Partially non-compliant, gradual implementation planned

   

 

Accessibility of asset management

 

Conclusion of the asset management agreement in text form

The asset management agreement is generally 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.

 

Digital conclusion of the asset management agreement (Solidvest)

The asset management contract can also be concluded digitally (electronically) via a special website (computer, tablet, etc.). The so-called "digital onboarding" makes it possible to conclude the asset management contract 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:

 

• Determination of your investor profile: you answer a questionnaire on your investment objectives, financial circumstances, experience and knowledge in the securities sector and your risk tolerance. This information is necessary in order to offer you a customized investment strategy.

• Proposal of a suitable investment strategy: Based on your information, you will receive a customized proposal on the investment guidelines that are suitable for you.

• Registration: You then register on the online platform and the data you previously provided is saved.

• Identity check and digital contract signing: 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 Videoident 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 implementing your investment strategy. This generally takes place without any further personal communication. We make the individual investment decisions without consulting you.

 

If you need help, you can also contact our customer service team by telephone. We will be happy to support you during our business hours.

 

Our aim is to ensure that all people - regardless of their abilities - can make good use of our online service.

 

Accessibility of investment advice

 

Conclusion of the investment advisory agreement in text form

The investment advisory 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 graphical representations in the documents. All documents in text form can be read aloud and explained in detail.

 

Digital conclusion of the investment advisory agreement

The investment advisory 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 investment advisory agreement online and paperless. The process is designed to be user-friendly, meets all security and data protection standards and corresponds in terms of content to the process under section 3.2. The difference lies in the exclusively digital processing:

• Registration: To begin, you register on the online platform.

• Submission of the questionnaire: You answer questions online about your financial situation, investment goals, risk tolerance and your knowledge and experience. Individual investment guidelines are determined on this basis.

• Suitable recommendations: With portfolio-based advice, you receive suitable investment guidelines based on the information you provide.

• Identity check & digital signature: After agreeing to the recommendations, you sign the contract electronically. Identity verification is carried out via Videoident, eID or by the advisor.

• Opening a securities account: A securities account is opened digitally with the custodian bank, if not already available.

• Start of investment advice: Implementation begins on the basis of the agreed investment guidelines. You will then receive specific investment recommendations.

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

As a rule, you will be accompanied by an employee who will go through the entire process with you and explain all the steps clearly. You can ask questions at any time. The digital documents meet accessibility requirements and are easy to read and understand. If necessary, they can be read aloud or explained.

 

The options for complaining
 

Complaint to DJE Kapital AG

Do you have a comment or a note about barriers on this website? Please get in touch with us. We will explain which barriers exist. You can find out what exceptions we have made. We will answer your questions as quickly as possible, but at the latest within the statutory period of six weeks. Thank you for your feedback. You can contact us at the following address:

 

By post:

DJE Kapital AG
Compliance

Pullacher Street 24

82049 Pullach

Pullach, Germany

 

By e-mail:

compliance@dje.de

 

 

Out-of-court dispute resolution

DJE Kapital AG is affiliated with the ombudsman's office of the Verband unabhängiger Vermögensverwalter e.V. (Association of Independent Asset Managers). In the event of complaints, you can also call the ombudsman's office of the Verband unabhängiger Vermögenverwalter e.V. (Association of Independent Asset Managers). An independent and neutral mediator can help to resolve the conflict out of court.

 

The contact details are as follows:

 

VuV Ombudsman's Office

Stresemannallee 30

60596 Frankfurt am Main

https://vuv-ombudsstelle.de/

In the event of disputes involving consumers, the parties involved can also contact the official consumer arbitration board of the Federal Financial Supervisory Authority:

 

Federal Financial Supervisory Authority

Marie Curie-Strasse 24-28

60439 Frankfurt am Main

www.bafin.de/schlichtungsstelle

 

 

The responsible market surveillance authority

If you have problems with the accessibility of our service, you can also submit an application to this authority:

 

Market surveillance authority of the federal states for the accessibility of products and services.

 

This authority checks whether the accessibility requirements are met. The authority may take legal action against us.

 

In the application, you can list the requirements of the BFSG or the BFSGV that we are in breach of.

 

Contact details of the authority:

 

Market surveillance body of the federal states for the accessibility of products and services

Turmschanzenstraße 25

39114 Magdeburg

Phone: +49 391 567-4530

E-mail: MLBF@ms.sachsen-anhalt.de