What is the suitability and appropriateness assessment?

In accordance with Article 126.² of the Financial Instrument Market Law, in order to determine the suitability of investment service for the interests of an investor, an investment brokerage company shall request information from the investor or potential investor regarding his or her experience and knowledge in respect of transactions to be entered into during the course of the provision of investment services, if the investment brokerage company provides investment service other than consultations regarding investments in financial instruments or individual management of financial instruments according to the authorisation of the investors. Therefore, TWINO requires all investors to undergo the MiFID II Suitability Test, which is the process of collecting information about the investor and the subsequent assessment by TWINO that a given financial instrument is suitable for the investor, based also on the TWINO’s solid understanding of the products that it can recommend or invest into on behalf of the investor. The MiFID II Suitability Test includes questions about the investor's knowledge and experience, the investor's financial position, and the investor's investment objectives.

If TWINO, on the basis of the information obtained, considers that the relevant product or service is not suitable for an investor, in accordance with Article 126.2 Part 10 of the Financial Instrument Market Law it shall warn the investor. If the investor rejects to provide the requested information or if the TWINO has information that such information is incomplete or does not contain the last changes, TWINO shall warn the client or potential client that the company cannot evaluate the suitability of the intended service or product for the investor. If TWINO has warned the investor, but the investor has not provided additional information, it shall not be responsible for the consequences caused by the refusal of the investor to provide information, provision of incomplete information, or failing to give a notice regarding changes in the previously provided information.

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