No consideration of adverse impacts of investment decisions on sustainability factors.

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Transtrend currently offers one trading program — the Diversified Trend Program (DTP) — which is available in different formats, among others through Transtrend’s alternative investment funds. The program is applied to futures, swaps and forwards on a broad range of commodity, currency, equity-related and fixed income markets. DTP aims to collect market risk premia by actively participating in the different trends in these markets. 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, defined as why and when to buy or sell, 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. Even though Transtrend recognizes that sustainability risks are one of the elements of market price risk of the markets traded, within DTP’s investment horizon this risk is considered subordinated to shorter-term price dynamics. Transtrend’s market risk management 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. The investments underlying the program do not take into account the EU criteria for environmentally sustainable economic activities. Given our broad investment universe across asset classes, the specific instruments we trade and our medium-term oriented trading strategy, Transtrend focuses on three roles that we believe active investors have in the market: 1) taking on market price risk that other parties may wish to (partly) offload, 2) trading in a way that provides liquidity and 3) contributing to the formation of fair prices, supporting the price discovery process. In line 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 markets where futures are not available or not actively traded, we may include swaps or forward contracts.

DTP’s investment universe consists of futures, swaps and forward contracts, which do not bear voting rights. 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.

Our engagement is mainly focused on the well-functioning of markets. We collaborate with exchanges, brokers, industry associations and regulators to provide feedback on (proposed) rules and regulations and to report and discuss trading activity that we think harms the markets. We publish articles reflecting our view on responsible investing and participate in roundtables and other industry discussions to increase awareness around the requirements for the well-functioning of markets. We also engage with exchanges on the topic of ‘responsible sourcing’, with a focus on the question whether or not contract specifications of listed futures contracts should reflect environmental and/or social requirements. Furthermore, we participate in industry discussions on the role of derivatives in the net-zero investment framework.

In summary, Transtrend is 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 and our environment, we discuss our position in society and our contribution to more sustainable global markets in more detail.

LEI code of Transtrend B.V.: 549300QMRPHU0AS15A62

Initial version, prepared in accordance with SFDR.

Added i) disclosure that the investments underlying the program do not take into account the EU criteria for environmentally sustainable economic activities, and ii) Transtrend’s LEI code.

Clarified Transtrend’s view on sustainability risks in relation to DTP.

Further details of the content and methods of our engagement activities.

Clarification of the text regarding the three roles that we believe active investors have in the market.

Added i) standard text as referred to in article 12 Delegated Regulation SFDR and article 7 Taxonomy Regulation, and ii) reference to our engagement in the form of publishing articles and participating in roundtables and other industry discussions.