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MiCA licensed CASP by the FSC of Bulgaria · Licence No. 001-DUKA/07.05.2026

MiCA CASP licencse · No. 001-FSC Bulgaria

Belayer
FEE SCHEDULE

Crypto-Asset Management Fee Schedule

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This fee schedule is an informational document and does not constitute advertising material. It applies to the individual client portfolios managed by Belayer OOD.

Management fee

The management fee is charged at the end of each calendar month based on the value of the portfolio. It is calculated proportionately and cumulatively across the applicable tiers, as shown below.

PORTFOLIO VALUE (EUR)

Below 25,000

25,001–50,000

1.75% 

50,001–125,000

1.50% 

125,001–250,000

1.25% 

Above 250,001

1.00% 

MANAGEMENT FEE (ANNUAL)

2.00% 

FORMULA

Management fee = Σ [(portion of the portfolio in each tier) × (applicable rate) × (number of days / 365)]

Example: management fee on a EUR 140,000 client portfolio

PORTFOLIO VALUE (EUR)

Below 25,000

25,001–50,000

50,001–125,000

125,001–250,000

Above 250,001

MANAGEMENT FEE (ANNUAL)

2.00%

1.75%

1.50%

1.25%

1.00%

1.61% effective rate

SHARE IN EACH TIER

25,000

25,000

75,000

15,000

-

140,000

MANAGEMENT FEE (ANNUAL)

500.00

437.50

1,125.00

187.50

-

2,250.00

For a portfolio valued at EUR 140,000, the effective annual management fee is 1.61%, or EUR 2,250. As additional funds are placed under management, the effective percentage rate decreases or remains the same; the total fee in euros may increase.

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If a client enters or exits during a month, the management fee is charged proportionately for the number of days the service was used.

Performance fee

BAX is a crypto-asset investment strategy developed by Belayer for investors with a higher tolerance for risk and volatility. The strategy focuses on established crypto-assets with strong fundamentals, liquidity and growth potential in their respective sectors.

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Belayer charges a performance fee of 18% (eighteen per cent) of the portfolio’s realised positive performance after deduction of the management fee, subject to a High Water Mark (“HWM”).

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The fee is calculated on the increase in the net value of the individual client portfolio above its previous highest value. If there is no increase above that value, no performance fee is charged. The HWM is not reset annually.

Example: performance fee calculation

PERIOD

​

period 1

period 2

period 3

OPENING VALUE

10,000

11,640

9,500

FINAL VALUE (NET)

11 640

9 500

12 345

RETURN FOR THE PERIOD

20%

-18%

32%

HWM (BENCHMARK)

10,000

11,640

11,640

PROFIT (LOSS)

2,000

(2,140)

3,000

GAIN ABOVE HWM

2,000

няма

860

FEE

(18%)

360

-

150

PROFIT (LOSS)

2,000

(2,140)

3.000

CLOSING VALUE BEFORE FEES

12,000

9,500

12,500

NEW HWM FOR NEXT PERIOD

11 640

11 640

12 345

How the calculation works:

  • Period 1 (20% growth): The portfolio gains 2,000. An 18% performance fee of 360 is charged. The client portfolio’s net value is 11,640, which becomes the new HWM.

 

  • Period 2 (18% decline): The portfolio falls to 9,500. As its value is below the HWM of 11,640, no performance fee is charged. The HWM remains 11,640.

 

  • Period 3 (recovery and a new high): The portfolio rises from 9,500 to 12,500. The first 2,140 of the gain restores the value lost in the preceding period. A performance fee applies only to the remaining 860 above the HWM. After the fee, the portfolio’s net closing value is 12,345, which becomes the new HWM.

The High-Water Mark principle

The HWM means that a performance fee is charged only when the client portfolio exceeds its previous highest net value. A recovery that merely brings the portfolio back to an earlier high does not trigger another performance fee.

1.3

One-off entry and exit charges

No entry or exit charges are applied.

2

Expenses and third-party charges

Expenses incurred in managing a client portfolio include fees and commissions charged by banks, exchanges and other intermediaries. They are paid when incurred, either from the client’s available funds or, if sufficient funds are unavailable, through the sale of assets from the client’s portfolio.

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These expenses vary and are determined by the relevant banks, exchanges and intermediaries. Expenses relating to the purchase, sale or exchange of crypto-assets are treated as part of the asset’s purchase or sale price. Belayer OOD follows policies intended to minimise these expenses and achieve the best possible result in the client’s interest (“best execution”).

3

Custody services

Custody fees are calculated using the average daily value of assets under custody and are invoiced monthly at the end of each month. Each day, the total value of the client’s assets held in custody is converted into euros using mid-market exchange rates. The daily values are averaged over the month, and the applicable annual rates are applied proportionately across the relevant tiers.

Value of assets under custody (EUR million)

Annual custody fee

Up to 5

0.75% 

5 - 25

0.55% 

25 - 100

0.40% 

Above 100

по договаряне

FORMULA

Monthly custody fee = Σ [(portion of assets in each tier) × (applicable annual rate) / 12]

Example: custody fee on EUR 30 million of assets

Asset value tier (EUR million)

Up to 5

5 - 25

25 - 100

Above 100

Annual rate

0.75%

0.55%

0.40%

By agreement

0.56% effective rate

Amount in tier (EUR million)

5

20

5

-

30

Annual fee (EUR)

37,500

110,000

20,000

-

167,500

For assets under custody valued at EUR 30 million, the effective annual custody fee is approximately 0.56%, or EUR 167,500. As additional assets are placed in custody, the effective percentage rate decreases or remains the same; the total fee in euros may increase.

4

Taxes

Under Bulgarian tax law, a client that is a Bulgarian tax-resident legal entity may be liable for corporate income tax under the Corporate Income Tax Act. A client who is a Bulgarian tax-resident individual may be liable for tax under the Personal Income Tax Act. Tax is due on realised gains during the calendar year; for individuals, the taxable gain is calculated taking into account the applicable 10% deduction for statutory expenses.

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The prices stated in this fee schedule exclude VAT.

 

Belayer OOD reserves the right to update this fee schedule in response to changes in market conditions or in the fees charged by institutions serving the company. Any change will be announced in a timely manner.

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This fee schedule was adopted by the General Meeting of the Shareholders of Belayer OOD on 4 December 2025 and amended by a decision of the Managers dated 31 July 2026.

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