Lemox Marketing Guide for Affiliates

The requirements and DOs and DONT’s laid out in this file are without prejudice to requirements set out in the Terms and Conditions. It is designed to help create compliant, effective content for the German and EU markets.

Please note, this is not a substitute for legal advice. This may not not contain most up to date information if there have been recent changes in laws or regulations or best practice, it takes time to incorporate changes in these Guidelines. Always use common sense, and contact Lemox with any questions about compliance.

About Lemox

Lemox operates an online platform at www.lemox.net, enabling project developers (“Issuer(s)”) to present their projects (“Investment Projects”) directly to investors. Through this platform, registered users (“Platform Users”) have the opportunity to participate in financing these investment projects. Lemox’s investment projects are funded via a crowdfunding model, in compliance with Section 2a Vermögensanlagengesetz (VermAnlG) under German law.

Lemox provides investors with accessible entry into the German real estate market, with investments starting at just €50. The platform is fully regulated and fee-free, allowing investors to diversify their portfolios with ease and transparency while potentially earning up to 11% annually.

General Requirements for Marketing Content

Clarity and Accuracy: Ensure your content is fair, clear, and not misleading. Avoid exaggeration, jargon, or technical language that may confuse investors. Simplicity: Use simple, direct language. Any technical terms should be explained concisely. Factual Information: All facts, quotes, and statements must be accurate and supported by reliable sources. Always reference any external data used.

DOs and DON’Ts for Marketing Lemox

DO: Clearly Identify Promotional Content

All content created to promote Lemox must be clearly identified as advertisement or promotional material. Ensure your audience understands that the content serves a commercial purpose.

DO: Use Disclaimers and Warnings

When presenting the benefits of Lemox’s products or services, include clear disclaimers and warnings about potential risks to ensure balanced and accurate information. For instance, if you highlight positive aspects of Lemox’s investment options, include disclaimers that emphasize possible risks. Be sure to comply with any specific regulatory requirements that may apply to your content.

DO: Explain Lemox’s Investment Products and Services

You may discuss the distinctions between different types of investments offered by Lemox, such as real estate investment projects, and how they operate. Content can also address topics like how to add or withdraw funds, the functionalities of Lemox’s platform, and any other features that enhance user understanding.

DON’T: Provide Investment Advice

According to MiFID II, investment advice involves making personal recommendations to a client, either upon their request or at the initiative of the investment firm, concerning one or more financial instruments. When interacting with individuals through any communication channels, including private messages, do not advise or solicit investments in specific properties, regions, or financial instruments. Similarly, refrain from offering portfolio management advice or recommending particular assets.

“Private messages” are defined as communications sent or received in a private context—such as through direct messaging on social media or messaging platforms—that are viewable only by the parties involved. Content shared broadly with your audience should not qualify as investment advice and should be general in nature.

DO: Promote Diversification as a Risk Management Strategy

Encourage diversification as a means of reducing risk. Explain how Lemox’s platform allows investors to spread their investments across different real estate projects or regions, which can help protect against market volatility. Focus on promoting general investment strategies that are beneficial for all investors, without offering specific advice.

DON’T: Recommend Specific Investments

Refrain from recommending particular real estate projects, properties, or geographic regions for inclusion in an investor’s portfolio. Content should avoid singling out specific investment opportunities and should present options neutrally, enabling users to make their own informed decisions.

DO: Share Accurate, Objective Information

Affiliates may share objective and factually correct information about Lemox’s investment opportunities, including details about various properties and general real estate trends. Information should be non-misleading and should not favor one investment opportunity over another. Any data or claims made must be verifiable and supported by credible sources.

DON’T: Favor One Asset over Another

Content should remain balanced, without suggesting that one property or region is superior to others. Avoid emphasizing specific assets, developers, or geographic areas, and instead provide a comprehensive view of Lemox’s diverse investment offerings.

Required Disclaimers and Disclosures

Content must include the disclosure that the content is an advertisement and the following disclaimer:

“The value of your investment can go up as well as down. You could lose some or all of the invested money.”

When discussing past performance, use:

“Past performance does not guarantee future returns.”

The disclaimers can be indicated anywhere in the post or article/video, but in a way that it’s visible to the reader/watcher.

Germany-Specific Requirements

In Germany, all commercial communication must be clearly identifiable as such, in accordance with Section 6 (1) No. 1 of the German Telemedia Act. This requirement aligns with the Electronic Commerce Directive (Directive 2000/31/EC), while specific guidelines on what qualifies as “clearly identifiable” are further defined by German case law.

For influencer marketing, German case law specifies that posts on social media promoting Lemox must begin with a clear label such as “Werbung” (advertising) or “Anzeige” (advertisement). This ensures that the promotional nature of the content is immediately evident to the audience.

Important points to remember:

Avoid Hashtag Clouds: Hashtags like “#ad” or “#sponsoredby” are not sufficient if placed in a hashtag cloud or at the end of the post. These tags should be clearly visible and placed at the beginning of the post.

Linking Alone is Not Enough: Simply tagging Lemox with “@” or “#” is insufficient. The content must explicitly indicate its advertising nature with clear terms like “Werbung” or “Anzeige” at the beginning.

We strongly advise German affiliates and influencers to adhere to these requirements when promoting Lemox’s services. This not only ensures compliance but also maintains transparency and trust with your audience.

Additional Tips for Lemox Affiliates

Emphasize Lemox’s Strengths: Highlight unique features such as the low entry point of €50, potential annual returns of up to 11%, and the platform’s ease of use and security.

Share Experiences, Not Recommendations: Use personal experiences with Lemox’s platform to create authentic content. For example, mention how easy it is to monitor investments rather than suggesting specific investment choices.

Remain Neutral: Promote Lemox’s offerings in a balanced way, avoiding bias towards specific projects, regions, or asset classes.

By following these guidelines, you can create effective, compliant content for Lemox that resonates with German and EU audiences. If you have any questions, please contact the Lemox team for further support.