We offer liquidity and transparency on financial markets
We contribute to transparency and effective operation of global financial markets by providing liquidity to markets worldwide. We facilitate the trading of thousands ETPs and similar products across the world’s markets, by continuously quoting bid and ask prices. As an innovative segment of global financial markets, ETPs have introduced efficiencies and cut investment costs substantially for a wide range of investors, from pension funds to retail investors. Increased liquidity, higher execution quality, and lower overall trading costs are just some of the benefits that liquidity providers, such as Flow Traders, offer through these financial products compared to more traditional investment products.
We enable trading in investment products that are widely diversified and accessible to anyone at any time. This allows end investors, such as pension funds, to do so with less costs and potentially higher returns. As a result, trading costs have decreased over time, while access to transparent and inexpensive products has improved for anyone looking to invest. This benefits institutional investors, individual investors and, ultimately, society at large.
We enter the public dialogue with full transparency. Our contributions to the regulatory dialogue are typically made public and we are always willing to discuss what we do and how it impacts the world around us. We have extensive dialogue with interest groups, including those focusing on transparency, institutional and retail shareholder interests, academia and students, local governments, regulators and anyone else who has an interest in what we do, and how we do it. We commit to being approachable and fully transparent with the goal to promote fairness, transparency and orderly functioning of the financial markets.
We offer sustainable employment
By creating and retaining high quality jobs we help develop a stable and trusting working environment that benefits our people, our business, and society. Since we started in 2004, our goal has been to foster a culture that encourages innovation, entrepreneurialism and risk-awareness, while focusing on drive, teamwork and ownership. By developing talent in-house and maintaining a committed and substantial employee shareholder base, we strengthen the internal bonds and help create a loyal, forward-looking team. We invest in employees for the long run. We encourage our people to move between offices internationally, to share ideas and best practices across the company, while experiencing life in different cultures. Although our business does not directly affect human rights issues, we are strong proponents of ensuring fair and equal treatment for all and expect the same from our relationships and stakeholders.
We also believe that a diverse workforce can supply a greater variety of ideas and provide better solutions to the challenges we face. We have a long-standing policy of recruiting and retaining the best talent available, regardless of their gender, ethnicity, faith or sexual preference. We are committed to providing equal employment opportunities to all qualified job applicants. As a result, we employ people from 36 nationalities across our offices. The composition of our workforce tracks the outflow of the education system in the various roles on offer at Flow Traders. We strongly encourage women to apply for any function within the firm, particularly when they have a background in fields that traditionally have a higher proportion of male employees.
We believe in sharing our profits with all relevant stakeholders, including our employees. Given good performance, all employees, in any role, in any office, are entitled to receiving a bonus relative to their contribution to the firm as a whole. We are transparent about both how we pay our people and how much we pay them, including management. We have a straight-forward remuneration policy that permits variable pay only when actual profit is made. And because variable remuneration is deferred to a large extent, it remains at risk of forfeiture in the case that we sustain a loss. We believe this is the strongest incentive for sustainable, risk-aware behaviour for all our staff. In addition, we promote employee shareholding, particularly at the more senior levels. This aligns the interests of the company with those of our employees by creating ''skin in the game'’.
We invest in our employees' development through opportunities for training, in order to improve our business as a whole on a day-by-day basis. For example, in the Trading and Technology departments, new joiners follow rigorous initial training. All employees, regardless of role or department, receive in-house training through our Flow Academy program. Employees cover a wide variety of topics to better understand our business, including culture, technology, trading, and regulatory developments.
We take good care of our people and stakeholders. We ensure a high quality working environment, fair treatment and equal remuneration principles for all our staff, including contractors, regardless of gender, tenure or personal factors. All employees and contractors have unrestricted, direct access to senior management and are regularly informed and consulted about key developments. People are encouraged to speak their minds to help make Flow Traders better. Information travels freely and is not restricted unless we need to protect overriding interests, such as those concerning regulations, commercial sensitivities or to protect our intellectual property. In addition, we hold regular employee surveys, including for the survey by ‘Great Place to Work’, in order to hear our employees’ views on how the company is doing and their experiences in their day-to-day workplace.
We are committed to full compliance and integrity
We are a strong proponent of effective, efficient and equal regulation and contributes to the regulatory dialogue in our key jurisdictions as we want markets to be fair, transparent and functioning in an orderly fashion. We commit to complying with all relevant laws and regulations that apply to us, wherever we operate, including anti-corruption and anti-bribery laws. Integrity and transparency are central to how we run our business, which includes communication between our Management Board, Supervisory Board, and all staff, regardless of role. Flow Traders encourages an open culture within its organization and expects its employees to comply with applicable laws, regulations and internal policies. Each employee is responsible for conducting business ethically and honestly. We have issued a Code of Conduct which forms part of our employment documentation.
Anti-bribery, anti-corruption and anti-money laundering
Our anti-bribery, anti-corruption and anti-money laundering (AML) policies apply to all staff. We expect our counterparties, business partners, intermediaries, contractors and subcontractors to adhere to the same standards. We believe that the risk of bribery or corruption is very limited as we do not hold or manage client money or funds. We trade financial instruments for our own account and own risk only. We do not do business with suppliers, maintain production facilities or source raw materials. Nevertheless, staff receive training in respect of anti-bribery, anti-corruption and AML practices.
Key to our anti-bribery and anti-corruption policy is that officials or counterparties may never be placed in an uncomfortable position. No gifts or favours may lead (or have the appearance to lead) to obligations or embarrass any recipient, and no gifts or favours of any substantial value may be given to authorities. Facilitation payments are not permitted. We provide clear and recurring guidance in that respect. As part of our constant monitoring, the firm's senior managers monitor all employee expenses and gifts relating to external parties. Employees are expected to state the purpose and recipient of all expenses.
In line with our open, transparent, and participatory culture comes our extensive Whistle-blower Policy for all staff and relevant contractors. This policy is approved by the Management Board and Supervisory Board. Employees are free to raise issues and have the responsibility to report misconduct and incidents, or any reasonable suspicions.
Circumstances may arise that cause an employee to feel unsecure or unsafe to the extent that they may not want to use the usual reporting lines. The company provides employees with a safe way of reporting misconduct within its organization and offer adequate protection. The Whistle-blower Policy has wide applications, including in respect of topics such as fraud, market abuse, corruption, anti-money laundering, theft, bribery and any other structural misconduct that threatens the integrity and proper business conduct of Flow Traders. The Whistle-blower Policy provides whistle-blowers with anonymity, confidentiality, and the company will not impose sanctions on disclosure (or affect an employee’s position) unless the employee is involved in the issue that is being reported.
We are committed to being good corporate citizens of the communities we operate in. We pay taxes where they are due and subscribe to fair taxation, both in terms of corporate taxes and wage taxation. In 2016 we paid total taxes of €62.1 million which is 25% of our Net Trading Income.
We operate a fair, transparent and straightforward tax policy. We believe this is an important part of being a sustainable business and in delivering long-term value to all of the company’s stakeholders, including the tax authorities in countries whose infrastructure and facilities we benefit from. We do not use aggressive tax structuring or tax havens. We entered into a covenant with the Dutch Tax Authority for horizontal supervision (horizontal toezicht). This allows the Dutch Tax Authority and ourselves to pro-actively manage our relationship and discuss any tax items timely, transparently and professionally.
We are involved in society and our immediate vicinity
While our activities do not involve production, use, processing or transport of physical goods, sustainable business is important to us. Many of our employees live reasonably close to our offices, limiting travel. We seek to limit our energy use and CO2 emission to take care of our environment. For example, when refurbishing our offices we sought to use more environmental friendly solutions for lighting and water consumption. We regularly review opportunities to compensate or limit our footprint, for instance by applying greener alternatives and perform annual energy audits in order to assess and reduce our impact on our environment.
Societal commitment and charity
It is important to us to contribute to initiatives that benefit society. We support a number of charities, not only financially but also by offering access to knowledge and experience we have available. Our employees feel empowered to support charitable initiatives, which has always been part of our working culture. We give back to our communities across all offices throughout the year. We support employee fund raising initiatives not only through financial offerings, but also with guidance and access to our network to increase their positive impact. For example, at the end of every year we ask our employees to donate a certain amount of money to a charity of their choice. As a result, more than 150 charitable organizations received donations.
Our employees actively participate in the charitable initiatives throughout the year. For example, every winter our employees come together to donate holiday gifts to children in need. We also support education initiatives in our communities, like the ''NewTechKids'' to provide computer science classes to children with an interest in technology. Employees also participate in charitable events, raising money and awareness for organizations through initiatives like the ''War Child Kili Challenge'' and ''Wall Street Rides FAR''.
From time to time, our business encounters dilemmas that compel us to weigh our societal impact against business benefits. As a publicly traded company, these dilemmas often appear at the intersection of entrepreneurship and regulation. While we are guided by our internal Code of Conduct and Whistle-blower Policy, we must also resolve dilemmas by reflecting on our role within society and using common sense to guide our decisions.
For example, while we profit from trading in a highly competitive environment, we also aim to leverage our knowledge and positions to safeguard market order and transparency. More specifically, we see purpose in protecting retail investor interests in these markets. Therefore, we spend considerable resources and efforts to address such outside interests in our regulatory dialogue as it improves market quality for everyone, including more vulnerable participants.