Author: Nadia Darie

When you start investing on Fagura.ro, one of the first steps after identity verification is completing the Investor Questionnaire. For many users, this may look like just a formality needed to activate the account. In reality, the questionnaire plays an important role both in investor protection and in creating an investment experience better suited to each person’s profile.

This process is mandatory for all crowdfunding platforms licensed in the European Union and is regulated under EU Regulation 2020/1503 regarding crowdfunding services.

What is the investor questionnaire?

The Investor Questionnaire is an evaluation form through which the platform analyzes:

• your level of investment experience;
• your understanding of financial risks;
• your general financial situation;
• your recommended investment capacity.

Its purpose is not to limit your access to investments, but to help you invest in a more informed and responsible way.

Why is this questionnaire important?

Crowdlending and online investments can generate attractive returns, but every investment also comes with risks. That is why licensed platforms must make sure investors understand:

• how investments work;
• what diversification means;
• what risks exist;
• how much it is recommended to invest.

In simple terms, the questionnaire helps both the investor and the platform create a safer and healthier investment environment.

What does sophisticated investor mean?

A sophisticated investor is a person who:

• has more investment experience;
• understands financial risks better;
• owns larger assets or has higher income;
• is familiar with investment products.

Based on this profile, the platform may allow larger investments in a single funding opportunity.

Important to remember: being classified as a sophisticated investor does not guarantee profit and does not remove investment risks.

What does non-sophisticated investor mean?

A non-sophisticated investor is someone who is at the beginning of their journey or has less experience in investing.

This is completely normal and very common for people who are just discovering crowdlending and alternative investments.

In this case, the platform may:

• display additional risk warnings;
• recommend investment limits;
• apply certain restrictions regarding the maximum amount invested in a single request.

These measures are designed to protect investors and reduce the risk of financial overexposure.

The questionnaire is not an exam

One of the most common concerns for new investors is that they might „answer incorrectly” or not be allowed to invest if they do not get a certain result.

In reality:

• there are no “right” or “wrong” answers;
• you cannot “fail” this questionnaire;
• your access to the platform is not blocked.

The most important thing is to answer honestly and realistically, because the investment experience will be adapted to your profile.

How does this process help you?

It helps you better understand risks

Smart investing starts with understanding risks. The questionnaire helps you become more aware of what investing in crowdlending involves.

It helps you invest more responsibly

Many investors make the mistake of investing too much money into a single opportunity. The platform tries to reduce this risk through recommendations and healthy investment limits.

It gives you a personalized experience

Depending on your profile, Fagura can adapt the information and experience on the platform to make it more relevant and useful for you.

It supports financial education

For many users, this is their first real contact with concepts such as:

• investment risk;
• diversification;
• capital protection;
• risk tolerance.

What happens after completing the questionnaire?

After completing the Investor Questionnaire:

• you can top up your account;
• you can analyze available opportunities;
• you can start investing on Fagura.ro;
• you can build your own investment portfolio.

Need help?

The Fagura team is here for you.

For Fagura.ro Romania accounts:
📞 +40 215557476
📧 info@fagura.ro
🕘 Monday – Friday | 09:00 – 18:00

Responsible investing starts with informed decisions. And the Investor Questionnaire is one of the steps that helps you invest in a more conscious, organized, and financially healthy way.

Version applicable starting 20.02.2026

This Regulation governs the participation conditions, operational mechanism, eligibility criteria, and bonus allocation method within the Fagura Referral Program, organized by FAGURA FINANCE S.R.L., a limited liability company incorporated and operating under the laws of Romania, with its registered office at 24 Sevastopol Street, Ground Floor, Room 1 Bis and Room 5, Sector 1, Bucharest, Romania, registered with the Trade Registry under no. J40/8030/2021, European unique identifier (EUID) ROONRC.J40/8030/2021, having fiscal registration code 44221810, hereinafter referred to as “Fagura”, acting as an authorized crowdfunding service provider, registration number and date in the A.S.F. Register: PJR28FSFPR/400003/04.09.2023.

This Regulation supplements the Terms and Conditions of Use of the Platform www.fagura.ro. In the event of any inconsistency between this Regulation and the Platform Terms and Conditions, the provisions of this Regulation shall prevail exclusively with respect to matters specific to the Referral Program.

At Fagura, the community is the engine that drives the growth of alternative investments. Therefore, we have rebuilt the Referral Program to expand the community and directly reward both the inviting user and the invited person. For each friend who creates an account through your link and fulfills the eligibility conditions, the bonus is granted to both parties. If the activation process takes longer than the initial term, you may relaunch the invitation from your account so that it remains valid according to the program rules.

1. Referral Program 3.0

Compared to previous versions, Referral Program 3.0 simplifies the bonus process and introduces new monitoring tools:

• Individual rewards: You receive a bonus for each approved referral who completes the required steps.
• Validity period: Each invitation has a 30-day opportunity window. It may be renewed twice (2), but must NOT exceed a total of 90 days.
• Reminder notifications: You may remind your friends to complete the process directly from the platform and ensure they do not miss the opportunity.

2. Key Terms

To simplify invitation tracking, each user may use the dedicated dashboard in their personal account, designed to provide transparency regarding the status of each invitation and allow real-time progress monitoring.

The Referral Program uses the following statuses:

• Invited: The invitation has been sent (email delivered), but the invited person has not yet created an account on the platform.
• Account Created: The invited person has created a user account and completed all necessary steps to invest or contract loans, including identity verification (KYC). From this moment, the 30-day eligibility period begins.
• Accepted: The invited person has fulfilled the applicable conditions (investment/loan), and the bonus is granted and transferred to the eligible parties’ accounts according to this Regulation.
• Pending: The invited person has not yet fulfilled the applicable conditions and the 30-day period has not expired.
• Expired Invitation: The 30-day period and the renewal possibility have expired without fulfilling the program conditions; the invitation becomes invalid.
• Closed: The referral created and activated the account or invested the required amount, but used an expired link or exceeded the maximum 90-day period from the initial invitation. In this case, no bonus is granted to either party.

3. Eligibility and Reward Conditions

Eligibility Conditions

Participation in the Fagura Referral Program is open to any natural or legal person, freely and voluntarily, provided they meet the general eligibility requirements applicable to users of www.fagura.ro, as provided in the Platform Terms and Conditions.

The bonus is granted to the Referrer and the Referral if the following conditions are cumulatively met:

• Both referrer and referral must have an active account on the platform and complete all required steps to invest or contract loans, including KYC verification.
• The invitee who has created an investor account must fund the account and make effective investments in loans that are signed and disbursed to the borrowers; the bonus will be calculated and granted only when these transaction completion conditions are met (subject to compliance with the deadline set forth in this Regulation).
• An invited borrower must contract a loan; the loan agreement must be signed and the amount disbursed according to platform rules and contractual documentation.
• The invited person may create both types of accounts (Borrower and Investor). The bonus will be granted to the account where the bonus conditions are fulfilled first.

Rewards are determined according to the type of account created by the invited person.

Referral Type	Bonus Condition	Referrer Bonus	Referral Bonus
Individual Investor	Minimum €250 cumulatively invested within 30 days	€30	€30
Corporate Investor	Minimum €1,000 cumulatively invested within 30 days	€90	€90
Corporate Borrower	Contracting a loan of minimum €1,000	€30	€30 (credited to loan account)

Bonus Allocation Procedure

The referral bonus is granted only after cumulative fulfillment of all eligibility conditions provided in this Regulation and the Platform Terms and Conditions.

After confirmation of eligibility (investment made according to applicable threshold or loan approved, signed and disbursed), the bonus will be validated by Fagura and allocated to both eligible parties.

The bonus will be credited directly to the user’s platform account within a maximum of 30 (thirty) calendar days from the confirmation date.

The platforms www.fagura.com and www.fagura.ro belong to the Fagura group. The Referral Program applies uniformly across both platforms under regulations containing identical rules and conditions. If the Referrer sends the invitation from fagura.com and the Referral chooses to invest or borrow on fagura.ro (or vice versa), once the program conditions are fulfilled, the Referrer receives the bonus on the platform from which the invitation was initiated, and the Referral receives the bonus on the platform where the bonus conditions were first fulfilled.

Fagura reserves the right to perform additional checks before granting bonuses to prevent fraud or abuse.

4. Notifications

To facilitate invitation management and eligibility tracking, the Referral Program includes notification and reminder functionalities within the dashboard.

If the invitation validity expires without fulfilling the conditions, the invitation may be relaunched through the “Renew Invitation” option. Relaunching is a manual action and starts a new 30-day cycle, subject to the Regulation limits.

For invitations with „Account Created” status, reminder messages may be sent to encourage completion of required actions (investment/loan). A maximum of two (2) reminders per invitation cycle is allowed. The first reminder may be manually initiated only after the first 10 days from invitation sending, with at least 10 days between reminders. If no manual reminder is sent, the system will automatically send one 7 days before the 30-day cycle expires. Messages are sent by Fagura but associated with the referrer to preserve a personal communication character.

5. Exclusions and Prohibited Conduct

The Referral Program aims to stimulate real, direct, and authentic recommendations. Any misuse may result in measures under this section.

Fagura reserves the right to suspend, cancel, or recover granted bonuses and restrict or close accounts involved in abusive, fraudulent, or improper practices, including but not limited to:

• Inviting fictitious persons, using false identities, or creating accounts without consent;
• Creating multiple accounts by the same person for unjustified bonus acquisition (self-referral);
• Bulk/referral farming schemes, mass non-personalized distribution, or automated invitation generation;
• Use of artificial/technical methods (scripts, bots, VPNs, intermediary accounts, simulation mechanisms, etc.) to artificially fulfill bonus conditions;
• Any other behavior that reasonably aims at unjustified benefit acquisition.

6. Taxation

The tax treatment of referral bonuses is determined according to applicable tax legislation. If bonuses are subject to taxation and withholding obligations exist, the tax will be calculated and withheld by Fagura at the time of bonus granting.

The amount credited may represent the net value after tax withholding.

If additional tax obligations apply (including contributions, declarations, or reporting), they will be fulfilled according to applicable legal provisions, and participants remain responsible for any personal tax obligations that cannot be withheld at source.

Fagura reserves the right to request additional information or supporting documents necessary for tax compliance.