Client Policy

Introduction and purpose

The Novus Capital platform is operated by the Company ("the Company", "we", "us", "our"), a crowdfunding service provider established in the Republic of Bulgaria and supervised by the Bulgarian Financial Supervision Commission (the "FSC"). This policy describes how we apply the investor-protection rules of the ECSPR when we provide our services to you.

Its purpose is to make clear, before you invest, what category of investor you are, what checks we carry out, and what safeguards apply to you. Nothing in this policy is personal investment advice; you make your own investment decisions.

How we classify investors

Under the ECSPR every investor is treated either as a sophisticated or a non-sophisticated investor. Your classification determines the level of protection you receive, and non-sophisticated investors receive the highest level.

By default we treat you as a non-sophisticated investor, which gives you the fullest protection. The two categories differ as follows:

• Sophisticated investors meet defined financial or professional thresholds set out in the ECSPR and receive a lighter level of protection.
• Non-sophisticated investors do not meet those thresholds and receive additional protections, including the appropriateness assessment, the simulation of the ability to bear loss, the reflection period, and specific risk warnings.

You may ask to be treated as a sophisticated investor if you meet the criteria — for example thresholds relating to your own funds, income, or professional experience — and we will ask you to confirm that you understand the protections you would give up. You can ask to change your classification at any time, and a change takes effect only after we have confirmed that you meet the applicable criteria.

Treatment as a sophisticated investor is valid for two years. When that period ends it lapses: we treat you as a non-sophisticated investor again unless you apply afresh and still meet the criteria.

Appropriateness of our services

Before a non-sophisticated investor can invest, and at least every two years afterwards, we carry out an entry knowledge test to assess whether our services are appropriate for you. The test covers your experience, investment objectives, financial situation, and understanding of the risks involved in investing through the platform.

We also ask you to simulate your ability to bear loss, calculated as 10% of your net worth, based on information you provide about your income, assets, and financial commitments. We repeat that simulation every year. It is a prompt for reflection rather than a limit, and the result is not disclosed to anyone else.

If you do not provide the information, or if the test suggests that our services may not be appropriate for you, we will warn you. You may still choose to invest, but only after you have acknowledged the warning.

Reflection period and key investment information

As a non-sophisticated investor you benefit from a pre-contractual reflection period of four calendar days, during which you may withdraw your offer to invest at any time, without giving a reason and without penalty. Until the period ends your commitment is not final.

For each Loan offered on the platform we make available a key investment information sheet (KIIS) — a concise document, drawn up under the ECSPR, that sets out the essential features and risks of the investment. Please read the relevant KIIS before you invest.

Investor protection and limits

Investing through the platform puts your capital at risk. It is not covered by a deposit guarantee scheme established in accordance with Directive 2014/49/EU of the European Parliament and of the Council on deposit guarantee schemes, nor by an investor compensation scheme established in accordance with Directive 97/9/EC of the European Parliament and of the Council on investor-compensation schemes. To help you invest responsibly, we draw specific matters to your attention where the rules require it.

If, as a non-sophisticated investor, you intend to invest an amount that exceeds the higher of EUR 1 000 or 5% of your net worth in a single Loan, we will show you a specific risk warning and ask for your explicit consent before the investment proceeds.

We encourage you to invest only what you can afford to lose and to spread your investments across several Loans.

Our full risk disclosure — the risks, costs, selection criteria and scoring methodology — is published on the website and is open to anyone, whether or not they hold an account.

Conflicts of interest

We maintain arrangements to identify, prevent, and manage conflicts of interest that could harm your interests. We do not take part in any crowdfunding offer on our own platform. We do not accept as Borrowers any of our shareholders holding 20% or more of our capital or voting rights, our managers or employees, or persons connected to them, and we do not grant them preferential access to investments.

Where a conflict cannot be avoided, we disclose its general nature and source, and the steps taken to mitigate it, so that you can make an informed decision. That disclosure is published on the website in a prominent place rather than made available on request: it sits in our risk disclosure, open to anyone.

Acting fairly and in your interest

We act honestly, fairly, and professionally in the best interests of our clients. Our communications are fair, clear, and not misleading, and the fees, procedures, and risks associated with our services are disclosed to you before you invest.

We do not pay or accept any remuneration, discount, or non-monetary benefit that would conflict with acting in your best interest.

Safeguarding of client funds

Funds you hold on the platform but have not invested are kept separate from the Company's own funds. Payment services connected with the platform are provided by authorised payment-service providers, and your money is held in a way that keeps it distinct from our assets.

Keeping funds segregated is designed to protect them if the Company were to fail; it does not remove the investment risk of the Loans in which you choose to invest.

Handling complaints

If you are dissatisfied with our services, you may submit a complaint free of charge. This section is our published complaints procedure.

Send your complaint to the contact address published on the platform. There is no compulsory form, but a complaint is easiest to deal with when it contains:

• your name, the contact details we should reply to, and your account identifier if you have one;
• the service, transaction or Loan the complaint concerns, with dates and amounts where relevant;
• what happened, and why you consider it wrong;
• what you would like us to do about it;
• copies of any documents that support the complaint.

We handle complaints promptly and fairly, following a documented procedure, and send you a reasoned response in writing. If we cannot answer within the time limit that applies, we will tell you why and when to expect our response.

If you are not satisfied with our response, you may be entitled to refer the matter to the FSC or to an out-of-court dispute-resolution body. Using this procedure does not affect that right, or your right to go to court.

Communications and language

We communicate with you and make our pre-contractual information, including each KIIS, available in the languages we support on the platform. Where a document is provided in more than one language, each version is intended to have the same meaning; if you are in any doubt, please contact us before you invest.

Contact

If you have any questions about this policy or about your classification as an investor, you can contact us using the contact details published on the platform. This policy should be read together with our General Terms and Conditions and our Privacy Policy.