Costs & Charges Disclosure
Purpose
In accordance with Article 24 of Directive 2014/65/EU (MiFID II) and Article 50 of Commission Delegated Regulation (EU) 2017/565, Investium Limited (“FlexInvest”) is required to provide Clients with relevant information in a durable medium, in good time prior to the provision of investment services. This includes disclosures related to all costs and charges associated with investment and ancillary services.
Under MiFID II, there are two types of cost and charges disclosures:
- Ex-ante disclosure: Provided before a transaction is executed.
- Ex-post disclosure: Provided after the transaction, on an annual, personalised basis.
For both ex-ante and ex-post disclosures, FlexInvest will aggregate and disclose the following:
- All costs and associated charges imposed by FlexInvest or by any third parties to whom the Client has been referred, in relation to the investment and/or ancillary services provided.
- All costs and associated charges related to the manufacturing and management of financial instruments.
- Any third-party payments received by FlexInvest in connection with the investment service provided to the Client.
The aggregated amount of costs and charges will be presented both:
- As a monetary value (cash amount), and
- As a percentage of the investment.
This document is intended to provide Clients with an indicative overview of the costs and charges applicable to financial instruments, transactions, and related services, in line with MiFID II requirements. Where applicable, and when required under MiFID II, FlexInvest will also provide a personalised cost and charges breakdown prior to the execution of a specific transaction.
An itemised breakdown of these costs and charges is available upon request, where relevant and required under applicable regulations.
All costs and charges will be classified into two main categories:
- Product Costs: Costs related to the manufacturing and ongoing management of financial instruments.
- Service Costs: Costs related to the investment and/or ancillary services provided by FlexInvest or any third party, including the establishment and maintenance of a position.
FlexInvest provides execution-only access to buy and sell financial instruments through its App, without offering investment advice.
Please note the following:
- Pricing is provided in accordance with our Order Execution Policy, where applicable.
- This disclosure may be revised or supplemented periodically.
- Fee Schedule: All fees charged by FlexInvest are available on our official website at: flexinvest.com/fees
- FlexInvest does not retain or receive any third-party payments, commissions, or non-monetary benefits in connection with the investment services provided, unless such payments are designed to enhance the quality of service and do not impair the Company’s duty to act in the best interest of clients.
Information on Costs and Charges
FlexInvest does not apply any entry or exit fees, ongoing charges, trading commissions, custody fees, incidental costs, or charges for ancillary services.
Service Costs
| Type of Charges | Description | Subtype of charges | Costs |
|---|---|---|---|
| One-off charges | All costs and charges paid to the investment firm at the beginning or at the end of the provided investment service(s). | N/A | None |
| Ongoing charges | All ongoing costs and charges paid to investment firms for their services provided to the client. | N/A | None |
| Transaction costs | All costs and charges that are related to transactions performed by the investment firm or other parties. | Mark-up | A value-based mark-up is applied to each executed transaction, according to the instrument’s price* |
| Charges related to ancillary services | Any costs and charges that are related to ancillary services that are not included in the costs mentioned above. | FX fee | 0.12% whenever you convert funds from one currency to another |
| Incidental costs | None |
Product Costs
| Type of Charges | Description | Subtype of charges | Costs |
|---|---|---|---|
| One-off charges | All costs and charges (included in the price or in addition to the price of the financial instrument) paid to product suppliers at the beginning or at the end of the investment in the financial instrument. | N/A | None |
| Ongoing charges | All ongoing costs and charges related to the management of the financial product that are deducted from the value of the financial instrument during the investment in the financial instrument. | N/A | None |
| Transaction costs | All costs and charges that incurred as a result of the acquisition and disposal of investments. |
Government taxes and levies
|
|
| Incidental costs | None |
Costs and Charges – Illustrative Scenarios
This section presents illustrative scenarios to demonstrate the potential impact of costs and charges on your investment returns. The following examples illustrate the cumulative effect that total costs and charges may have on investment returns over time.
While the examples are based on reasonable assumptions and expected costs, the actual costs and charges applied to future transactions may vary.
Scenario 1: EUR account investing in Belgian-Listed Equities (TOB 0.12%)
| Scenarios | Total initial Investment | €100.00 | €1,000.00 | €10,000.00 | ||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Performance of investment | 20.00% | 20.00% | -20.00% | 0.00% | 20.00% | -20.00% | 0.00% | 20.00% | 20.00% | |
| Gross returns | Gross return | -€20.00 | €0.00 | €20.00 | -€200.00 | €0.00 | €200.00 | -€2,000.00 | €0.00 | €2,000.00 |
| Gross return (%) | -20.00% | 0.00% | 20.00% | -20.00% | 0.00% | 20.00% | -20.00% | 0.00% | 20.00% | |
| One-off charges | Total one-off charges | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 |
| Total one-off charges (%) | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | |
| Transaction costs of the buy | Mark-up | €0.04 | €0.04 | €0.04 | €0.10 | €0.10 | €0.10 | €0.50 | €0.50 | €0.50 |
| Government taxes & levies | €0.12 | €0.12 | €0.12 | €1.20 | €1.20 | €1.20 | €12.00 | €12.00 | €12.00 | |
| Total transaction costs - buy | €0.16 | €0.16 | €0.16 | €1.30 | €1.30 | €1.30 | €12.50 | €12.50 | €12.50 | |
| Total costs and charges (buy) | Total costs and charges | €0.16 | €0.16 | €0.16 | €1.30 | €1.30 | €1.30 | €12.50 | €12.50 | €12.50 |
| Total costs (% of initial investment) | 0.16% | 0.16% | 0.16% | 0.13% | 0.13% | 0.13% | 0.125% | 0.125% | 0.125% | |
| Transaction costs of the sell | Mark-up | €0.04 | €0.04 | €0.04 | €0.10 | €0.10 | €0.10 | €0.50 | €0.50 | €0.50 |
| Government taxes & levies | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | |
| Total transaction costs - sell | €0.04 | €0.04 | €0.04 | €0.10 | €0.10 | €0.10 | €0.50 | €0.50 | €0.50 | |
| Charges related to ancillary services | FX fee | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 |
| Net returns | Final investment value | €79.80 | €99.80 | €119.80 | €798.60 | €998.60 | €1,198.60 | €7,987.00 | €9,987.00 | €11,987.00 |
| Net return (€) | -€20.20 | -€0.20 | €19.80 | -€201.40 | -€1.40 | €198.60 | -€2,013.00 | -€13.00 | €1,987.00 | |
| Net return (%) | -20.20% | -0.20% | 19.80% | -20.14% | -0.14% | 19.86% | -20.13% | -0.13% | 19.87% | |
| Total costs and charges after selling position | Total costs | €0.20 | €0.20 | €0.20 | €1.40 | €1.40 | €1.40 | €13.00 | €13.00 | €13.00 |
| Total costs (% of initial investment) | 0.20% | 0.20% | 0.20% | 0.14% | 0.14% | 0.14% | 0.13% | 0.13% | 0.13% | |
Scenario 2: USD account investing in Belgian Equities (FX fee applies & TOB 0.12%)
| Scenarios | Total initial Investment | $100.00 | $1,000.00 | $10,000.00 | ||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Performance of investment | -20.00% | 0.00% | 20.00% | -20.00% | 0.00% | 20.00% | -20.00% | 0.00% | 20.00% | |
| Charges related to ancillary services | FX fee | -$0.12 | -$0.12 | -$0.12 | -$1.20 | -$1.20 | -$1.20 | -$12.00 | -$12.00 | -$12.00 |
| Initial investment after FX fee | $99.88 | $99.88 | $99.88 | $998.80 | $998.80 | $998.80 | $9,988.00 | $9,988.00 | $9,988.00 | |
| Initial investment in € | €92.90 | €92.90 | €92.90 | €928.84 | €928.84 | €928.84 | €9,288.84 | €9,288.84 | €9,288.84 | |
| Gross returns | Gross return | -€18.58 | €0.00 | €18.58 | -€185.77 | €0.00 | €185.77 | -€1,857.77 | €0.00 | €1,857.77 |
| Gross return (%) | -20.00% | 0.00% | 20.00% | -20.00% | 0.00% | 20.00% | -20.00% | 0.00% | 20.00% | |
| One-off charges | Total one-off charges | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 |
| Total one-off charges (%) | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | 0.00% | |
| Transaction costs of the buy | Mark-up | €0.04 | €0.04 | €0.04 | €0.10 | €0.10 | €0.10 | €0.50 | €0.50 | €0.50 |
| Government taxes & levies | €0.11 | €0.11 | €0.11 | €1.11 | €1.11 | €1.11 | €11.15 | €11.15 | €11.15 | |
| Total transaction costs - buy | €0.15 | €0.15 | €0.15 | €1.21 | €1.21 | €1.21 | €11.65 | €11.65 | €11.65 | |
| Total costs and charges (buy) | Total costs and charges | €0.15 | €0.15 | €0.15 | €1.21 | €1.21 | €1.21 | €11.65 | €11.65 | €11.65 |
| Total costs (% of initial investment) | 0.15% | 0.15% | 0.15% | 0.12% | 0.12% | 0.12% | 0.12% | 0.12% | 0.12% | |
| Transaction costs of the sell | Mark-up | €0.04 | €0.04 | €0.04 | €0.10 | €0.10 | €0.10 | €0.50 | €0.50 | €0.50 |
| Government taxes & levies | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | €0.00 | |
| Total transaction costs - sell | €0.04 | €0.04 | €0.04 | €0.10 | €0.10 | €0.10 | €0.50 | €0.50 | €0.50 | |
| Net returns | Final investment value | €74.13 | €92.71 | €111.29 | €741.76 | €927.53 | €1,113.30 | €7,418.92 | €9,276.69 | €11,134.46 |
| Net return (€) | -€18.77 | -€0.19 | €18.39 | -€187.08 | -€1.31 | €184.46 | -€1,869.92 | -€12.15 | €1,845.62 | |
| Net return (%) | -20.20% | -0.20% | 19.80% | -20.15% | -0.14% | 19.86% | -20.14% | -0.13% | 19.87% | |
| Total costs and charges after selling position | Total costs | €0.19 | €0.19 | €0.19 | €1.31 | €1.31 | €1.31 | €12.15 | €12.15 | €12.15 |
| Total costs (% of initial investment) | 0.19% | 0.19% | 0.19% | 0.13% | 0.13% | 0.13% | 0.12% | 0.12% | 0.12% | |
General Assumptions (Applicable to Both Scenarios):
- The scenarios assume a simple buy-and-hold strategy, with the position held for 12 months. No other trading activity or corporate actions (dividends, splits, etc.) are assumed.
- Charges are calculated based on whole share purchases (rounded for simplicity).
- Gross performance scenarios modelled: -20%, 0%, and +20%.
- Investment amounts: €100, €1,000, and €10,000.
- All transaction fees, government taxes, and FX fees are rounded to the nearest cent.
- Total Costs are expressed in EUR and also as a percentage of the initial investment.
Scenario 1: EUR Account / Belgian Equities
- Account Currency: EUR
- Underlying Investment: Belgian equities
- Exchange Rate: Not applicable (no FX conversion required)
- TOB Tax (Belgium): 0.12% applied on the buy leg
- Mark-Up is applied per trade according to the value-based mark-up structure (e.g., €100 → €0.04, €1,000 → €0.10, €10,000 → €0.50)
- FX Fees: Not applicable
- Government Taxes on Sell: Zero
Scenario 2: USD Account / Belgian Equities (FX Conversion Required)
- Funding Currency: USD
- Converted Investment Currency: EUR
- FX Rate (Illustrative): 0.93 USD/EUR
- FX Conversion Fee: 0.12% applied once on the full USD amount before conversion
- TOB Tax (Belgium): 0.12% applied to the converted EUR amount on the buy leg
- Mark-Up is applied per trade according to the value-based mark-up structure (e.g., €100 → €0.04, €1,000 → €0.10, €10,000 → €0.50) (applied in EUR after conversion)
- Government Taxes on Sell: Zero
- All subsequent charges and calculations are applied in EUR, on the converted amount, as funds are credited to the EUR account after conversion.
Explanatory Notes for Table Rows:
- Gross Return = Initial Investment * Performance of investment
- Gross Return (%): Performance of investment
- Total Transaction Costs – Buy = Mark-Up + TOB (Belgian Tax of 0.12% on buy)
- Total Costs and Charges – Buy (%) = Buy Charges ÷ Initial Investment
- Total Transaction Costs – Sell = Mark-Up only (no taxes on sell)
- FX Conversion Fee (USD Scenario Only): 0.12% applied on USD amount before conversion
- Final Investment Value = Initial Investment + Gross Return - Buy Costs - Sell Costs
- Net Return (€) = Final Value - Initial Investment
- Net Return (%) = (Net Return ÷ Initial Investment) * 100
- Total Costs After Sell (€) = Total Buy Costs + Total Sell Costs
- Total Costs (% of Initial Investment) = (Total Costs After Sell ÷ Initial Investment) * 100
Ex-post Costs and Charges Disclosure
The Ex-post Costs and Charges Disclosure will be provided to each client on an annual basis, within four months following the end of each calendar year, via a durable medium (downloadable PDF within the mobile application). It provides information on the actual costs and charges incurred by the client over the reporting period.
Important Information
This document is provided for informational and illustrative purposes only. The costs and charges presented are estimates based on assumptions and may not reflect each client’s individual circumstances. As such, actual costs incurred may differ.
This document does not constitute marketing material, investment advice, or a recommendation, and it is not suitable for tax reporting purposes.
*For the detailed mark-up structure, please refer to our Fee Schedule at flexinvest.com/fees.
Version: 1.1 | Effective Date: 28 November 2025 | Reviewed: Q4 2025 | Next Review: Q4 2026 | Approved by: Compliance Department