Initial customer information
Managing Director: Thorsten M. Kuhr
Registry Court: AG Hamburg HRB-Nr. 116252
Ust.-Id.Nr.: DE 245806330
Initial customer information of Baron Investmentvertriebsgesellschaft mbH.
Business areas, range of services and pre-contractual information:
- the provision of advice on and brokerage of investments, in particular financial instruments, securities, AIFs (alternative investment funds, including closed-end funds) and other investment assets, as well as brokerage in asset management,
- advising on and brokering insurance policies,
- advising on and brokering loans and real estate,
- further business areas
1. Advice & brokerage of capital investments
Baron Investmentvertriebsgesellschaft mbH offers you investment advice and brokerage of financial instruments as well as asset management contracts pursuant to section 2 para. 2 nos. 3 and 4 WpIG (business division no. 1) exclusively as a contractually bound intermediary pursuant to section 3 para. 2 Securities Institutions Act (WpIG) in the name, for the account and under the liability of NFS Netfonds Financial Service GmbH (hereinafter: “NFS”). Financial instruments within the meaning of Section 2 (5) WpIG are, in particular, investment fund units, shares, certificates, derivatives, bonds, bearer bonds, participation certificates, AIF and asset investments. When using these services, only NFS Netfonds Financial Service GmbH becomes your contractual partner. For this purpose, Baron Investmentvertriebsgesellschaft mbH is entered in the public register of contractually bound intermediaries maintained by the Federal Financial Supervisory Authority (BaFin) on the following website: portal.mvp.bafin.de/database/VGVInfo/
Register of contractually bound intermediaries:
Screenshot https://portal.mvp.bafin.de/database/VGVInfo/ from 29.06.2021
NFS is a securities institution and is subject to the supervision of the Federal Financial Supervisory Authority (BaFin), Marie-Curie-Straße 24-28, 60439 Frankfurt am Main, Germany, which has granted it a licence pursuant to Section 15 (1) WpIG (or pursuant to Section 32 KWG in the version applicable until 25 June 2021) for investment advice and brokerage. All contractually bound intermediaries of NFS are registered in Germany. Communication takes place in German in person or via telephone, fax or e-mail and other electronic communication channels. Please contact Baron Investmentvertriebsgesellschaft mbH (details above) or directly:
|Liability:||Competent supervisory authority:|
NFS Netfonds Financial Service GmbH Heidenkampsweg 73, 20097 Hamburg Geschäftsführer: Peer Reichelt, Christian Hammer
Tel.: +49 (0) 40 – 8222838-0
|Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) Marie-Curie-Straße 24-28
Graurheindorfer Str. 108
Tel. +49 (0) 228-4108-0
Fax +49 (0) 228- 4108-1550
Information about the protection scheme
NFS is a member of the Compensatory Fund of Securities Trading Companies (EdW), 10865 Berlin, Behrenstraße 31, Berlin-Mitte, Tel. +49 (0) 30 203699-5626, Fax +49 (0) 30 203699-5630, E-Mail: firstname.lastname@example.org, Internet: www.e-d-w.de, due to legal obligation. A case of compensation within the meaning of the German Investor Compensation Act (AnlEntG) occurs if BaFin determines that an institution is unable to meet liabilities arising from securities transactions for reasons directly related to its financial situation and there is no prospect of subsequent fulfilment. The customer’s claims for compensation under the AnlEntG shall be based on the amount and scope of the liabilities to the customer arising from securities transactions, taking into account any rights of set-off and retention of NFS. Liabilities from securities transactions within the meaning of the AnlEntG are the obligations of an institution (the NFS) to repay funds that are owed to or belong to investors from securities transactions and are held for their account in connection with securities transactions. This also includes claims of investors for the surrender of instruments of which they are the owners and which are held or kept for their account in connection with securities transactions. The claim for compensation exists only if deposits or funds are denominated in the currency of an EU member state or in euros. The claim for compensation per creditor (customer) is limited to 90 percent of the liabilities from securities transactions and the equivalent value of 20,000 euros; claims to interest are also taken into account. These exist from the occurrence of the compensation case until the repayment of the liabilities, at the longest until the opening of the insolvency proceedings. When calculating the amount of the compensation claim, the amount of the funds and the market value of the financial instruments at the time of the occurrence of the compensation event shall be taken as a basis. The claim for compensation shall be reduced to the extent that the creditor’s loss of assets resulting from the event of compensation is compensated for by payments from third parties. Section 3 (2) AnlEntG lists which clients are not entitled to compensation. Upon request, information on the terms and conditions of the protection, including the formalities required for the assertion of compensation claims, can be obtained from NFS or Baron Investmentvertriebsgesellschaft mbH. NFS and Baron Investmentvertriebsgesellschaft mbH are not entitled to obtain possession or ownership of money, securities or other assets of the client and do not hold any financial instruments or funds of the clients in custody. The booking and safekeeping of funds and financial instruments of the clients take place exclusively in accounts of the client with the partner banks (custodians). The partner banks are in turn affiliated to their own legally prescribed compensation schemes. The compensation according to the AnlEntG does not cover claims for damages due to culpable advice, lack of information, execution of orders contrary to instructions, incorrect or false information and other breaches of contract.
The NFS provides Baron Investmentvertriebsgesellschaft mbH with access to
- more than 15,000 investment funds and ETFs,
- all listed shares, bonds, certificates and derivatives,
- closed-end funds from more than 25 issuing houses,
- over 10 partner banks that trade and store these products,
- as well as asset management companies.
For details, please refer to www.nfs-netfonds.de/finanzinstrumente.
Investment advice is provided as commission-based advice. This means that inducements from third parties may be accepted by NFS in connection with investment advice and brokerage, forwarded to Baron Investmentvertriebsgesellschaft mbH and retained – subject to your consent, which is obtained when the framework agreement is concluded. Details are set out in the “Conflicts of Interest Policy of NFS” (www.nfs-netfonds.de/coip) and the General Terms and Conditions of Contract (GTCP)1 and, if applicable, will be announced separately on a product-specific basis in the course of the advisory process.
Out-of-court complaint and redress procedures / Competent consumer arbitration bodies.
NFS participates in dispute resolution procedures before the consumer arbitration boards mentioned below. Consumers may, without prejudice to their right to bring an action before the courts, bring an action before the consumer arbitration boards mentioned below within their respective jurisdiction. NFS does not participate in dispute resolution procedures before consumer arbitration bodies other than those mentioned below.
In disputes with consumers arising from the application of the provisions of the German Investment Code:
Schlichtungsstelle bei der Bundesanstalt für Finanzdienstleistungsaufsicht Graurheindorfer Str. 108, 53117 Bonn
Telefon: +49 228 41080,
Telefax: +49 228 410862299
EU platform for extrajudicial online dispute resolution: http://ec.europa.eu/odr
NFS Netfonds Financial Service GmbH can be reached by e-mail as follows: email@example.com
NFS and its contractually bound intermediaries limit the evaluation of the business press to evaluating the Handelsblatt and taking relevant reports into account no later than three days after they appear.
2. Advice on insurance brokerage
Baron Investmentvertriebsgesellschaft mbH will be your contractual partner in the brokerage of insurance contracts (business area no. 2.), including insurance contracts that serve investment purposes, e.g. unit-linked life insurance. This includes, for example, life insurance, property insurance, health insurance and others.
Baron Investmentvertriebsgesellschaft mBH also offers advice on insurance products, unless this is contractually excluded in advance. Advice may also be limited to individual insurance policies or product lines by corresponding agreement.
In connection with advice or brokerage, remuneration for this may be paid either by the client, by a commission included in the insurance premium or other remuneration paid by the insurance company, or a combination of both. This depends on your wishes and needs and the respective insurance products that are brokered. Insofar as remuneration components are paid by the client, this is done on the basis of a remuneration agreement to be made in advance. Further variable remuneration is possible in principle, but is always measured on the basis of qualitative characteristics.
Baron Investmentvertriebsgesellschaft mbH has been granted permission as an insurance broker in accordance with Section 34d (1) Sentence 2 No. 2 GewO by the Hamburg Chamber of Commerce and Industry, Adolphsplatz 1, 20457 Hamburg.
Baron Investmentvertriebsgesellschaft is entered in the register of insurance brokers under the number D-A1BS-X0KOC-56.
The register can be inspected at:
Deutscher Industrie- und Handelskammertag (DIHK) e. V.
Breite Straße 29
Tel.: 0180-600 585-0 (Cost per call: 20 cents from a German landline; max. 60 cents. from mobile networks).
Complaints bodies for out-of-court dispute resolution:
Versicherungsombudsmann e. V.
Postfach 08 06 32, 10006 Berlin
Ombudsmann für die private Kranken- und Pflegeversicherung
Postfach 06 02 22, 10052 Berlin
Schlichtungsstelle für gewerbliche Versicherungs-, Anlage- und Kreditvermittlung
Glockengießerwall 2, 20095 Hamburg
3. Advice on & mediation of loans and real estate
When brokering loan agreements or real estate transactions (business division no. 3), Baron Investmentvertriebsgesellschaft mbH becomes your contractual partner.
Baron Investmentvertriebsgesellschaft mbH also offers the brokerage of real estate consumer loan agreements in principle, unless this is contractually excluded in advance.
- Real estate agent and loan broker pursuant to § 34 c para. 1 GewO
- Real estate loan broker pursuant to § 34 i para. 1 GewO
Competent supervisory authority for granting permission to broker loans (with the exception of consumer real estate loans) pursuant to Section 34 c (1) GewO:
Competent supervisory authority for the granting of permission for the brokerage of real estate consumer loan agreements according to § 34 i GewO:
The broker is registered in the broker register under the following registration number pursuant to § 34i GewO: D-W-131-HAPR-55
The intermediary also provides advisory services.
Performance fee/costs, product range
Baron Investmentvertriebsgesellschaft mbH receives a performance fee from the lender for the successful brokerage of the loan. The amount of this remuneration may result in particular from:
- of the gross loan amount,
- interest payments and/or
The final amount of the remuneration is not yet known at this point in time. Detailed information can be obtained at a later date from the so-called ESIS (European Standardised Information Sheet), which you will receive in good time before the conclusion of the contract. Further variable remuneration is possible in principle, but is always based on qualitative characteristics.
Baron Investmentvertriebsgesellschaft mbH operates independently, i.e. it is not tied to any lender.
Complaints and dispute resolution
Baron Investmentvertriebsgesellschaft mbH participates in dispute resolution procedures before the consumer arbitration boards listed below. Consumers may, without prejudice to their right to appeal to the courts, appeal to the arbitration bodies named below within the scope of their respective jurisdiction.
In the event of disputes with consumers arising from the application of the provisions of the German Civil Code (Bürgerliches Gesetzbuch) concerning distance contracts for financial services as well as in the event of disputes with consumers arising from the application of Sections 655a – 655d of the German Civil Code (Vermittlung von Verbraucherdarlehensverträgen und entgeltlichen Finanzierungshilfen) or real estate consumer loan agreements and corresponding financing aids:
Schlichtungsstelle der Deutschen Bundesbank
Postfach 11 12 32, 60047 Frankfurt am Main
Telefon: +49 (0) 69 2388-1907,
Telefax: +49 (0) 69 709090-9901
Schlichtungsstelle für gewerbliche Versicherungs-, Anlage- und Kreditvermittlung Glockengießerwall 2, 20095 Hamburg
4. Details of: Other business areas
If Baron Investmentvertriebsgesellschaft mBH advises you on the general structuring of your assets without making specific investment recommendations regarding one or more financial instruments (financial planning) or advises you on the topics of succession planning, management consulting, seminars or software solutions, etc., these are transactions that do not require a licence and that Baron Investmentvertriebsgesellschaft mbH carries out for its own account and under its own liability.
5. Complaint management
If you are dissatisfied with our services, please contact us. Your contact person for complaints is first the responsible employee and otherwise then our managing director Thorsten M. Kuhr (e-mail: firstname.lastname@example.org). Dealing with complaints is our top priority and we will get back to you promptly. If you have any complaints about our activities, please contact our complaints office:
Telefon: +49 (0)40 / 18 04 074-0
6. Professional regulations:
– § 34d Trade, Commerce and Industry Regulation Act (GewO)
– §§ 59-68 Insurance Contract Act (VVG)
– Ordinance on Insurance Mediation and Advice (VersVermV) – § 34f Trade, Commerce and Industry Regulation Act (GewO)
– Ordinance on the Brokerage of Financial Investments (FinVermV)
The professional regulations can be viewed and accessed on the website www.gesetze-im-internet.de operated by the Federal Ministry of Justice and juris GmbH.
see our notes: https://www.baron-investment.com/compliance
Information from the BDVM eV: https://bdvm.de/versicherungsmakler/code-of-conduct/
Information on the TVO (point 9): https://www.baron-investment.com/erstinfo
8. Information on sustainability
Art. 3 TVO
When selecting insurance companies and insurance products, we take into account the information provided by the insurers/product providers. If applicable, we do not offer insurers that recognizably do not include a strategy for incorporating sustainability risks in their investment decisions.
Within the scope of the individual advice provided in the client’s interest, we will, upon request, separately explain if the consideration of sustainability risks in the investment decision means a recognisable advantage or disadvantage for the individual client. The respective insurer informs about the respective consideration of sustainability risks in investment decisions with its pre-contractual information. If the client has any questions, he/she is welcome to contact me / us in advance of a possible conclusion.
Art. 4 TVO
Within the scope of the consultation, the most important adverse effects of investment decisions on sustainability factors of the financial market participants (insurers) are currently taken into account to a limited extent. Where applicable, the consideration is based on the information provided by the insurance companies. The insurance company, not the intermediary, is responsible for its accuracy. Due to the currently limited information provided by the insurers, these aspects are currently not taken into account in the advice as standard. They can be taken into account at the special request of the client on the basis of the data currently available. With a broader market offer in the future, they will be taken into account as standard.
Art. 5 TVO
The remuneration for the brokerage of insurance policies is currently not oriented towards the sustainability risks associated with the investments of these. This means in particular that the remuneration level of the product is currently not influenced positively or negatively by the sustainability risks of the investment.
Art. 6 TVO
When advising on insurance investment products, Riester and basic pensions or occupational pension schemes, sustainability risks are included by using the pre-contractual information provided by the insurers.
In the case of a possible dutiful assessment of a comparable or better return of the product that takes sustainability risks into account, we are happy to recommend this.