Sustainable Finance Disclosure Regulation

Version 1.0
Last updated: March 2021


Transtrend currently offers one trading program, the Diversified Trend Program (DTP), which is available in different formats. The program is applied to a broad range of markets, including commodities, currencies, equities and fixed income. DTP only takes positions in futures, swaps and forwards on these markets, with the aim to collect market risk premia by actively participating in the different underlying trends. DTP can take long as well as short positions and focuses on the medium term — positions are generally held between two weeks and two months.

When making investment decisions, Transtrend does not take into account ‘sustainability risks’ as defined in Regulation (EU) 2019/2088 (the Sustainable Finance Disclosure Regulation), i.e. environmental, social or governance (ESG) events that may have a negative impact on the value of an investment. Consequently, these sustainability risks are also not taken into account in Transtrend’s remuneration policy. DTP’s investment horizon plays a fundamental role here. Transtrend recognizes that sustainability risks are one of the elements of market price risk of the markets traded. However, within the time horizon in which Transtrend is active, this risk is almost entirely subordinated to shorter term price dynamics, which are dominated by asynchronicity in the willingness to trade — i.e. buyers and sellers not coming to the market at the same time — and psychological factors. Transtrend’s trading strategy is entirely geared to these price dynamics.

When making investment decisions, Transtrend does not consider any adverse impact that its investment decisions may have on sustainability factors as defined in the Sustainable Finance Disclosure Regulation. Given our broad investment universe across asset classes, the specific instruments we trade and our short to medium term oriented trading strategy, Transtrend focuses on three responsible roles in the market: 1) bear market price risk that other parties may wish to (partly) offload, 2) provide liquidity to the markets we trade, enabling other parties to buy and sell more efficiently, and 3) actively contribute to the formation of fair prices, supporting the price discovery process. Aligned with these roles, we strive to be actively involved in all the areas where large fundamental changes — including the transition towards a more sustainable society — may take place, as these changes form a major source of market price risk. Risk that has to be borne by active investors. Therefore, we in principle include every actively and freely traded futures contract in DTP’s investment universe, provided they are effective in their function to facilitate the exchange of price risk. In certain markets where futures are not available or not actively traded, we include swaps or forwards.

Transtrend’s investments do not bear any voting rights, as DTP’s investment universe consists of futures, swaps and forward contracts. Voting, such as on ESG related matters, is therefore not within our scope. Besides, we believe the long-term well-being of companies is best served when shareholders and stakeholders with a longer-term commitment to these companies set the tone. Not investors with a shorter-term investment horizon such as ourselves.

In terms of engagement, we do engage, but primarily with exchanges, brokers, industry associations and regulators around the well-functioning of markets, for example on (proposed) rules and regulations and observed trading activity that in our view undermines the well-functioning of markets.

In summary, Transtrend aims to be a responsible investor, committed to fulfill the responsibilities that come with the investment process we manage and the instruments we trade. Our focus is on contributing to well-functioning, well-organized and reliable markets — an important social responsibility and an integral part of our investment philosophy and process.

In our Responsible Investment policy Transtrend’s position in society, we discuss our position in society and our contribution to more sustainable global markets in more detail.

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LEI code of Transtrend B.V.: 549300QMRPHU0AS15A62

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If you have a question or would like to know more about our services, please get in touch with our Investor Relations team.
Yvonne Bouhuizen
Yvonne
Bouhuizen
André Honig
André
Honig
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