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Flow Traders

Flow Traders N.V. is a publicly traded multinational firm that operates as a leading global electronic liquidity provider and , specializing in exchange-traded products (ETPs) and other financial instruments. Founded in 2004 in , , where it is headquartered, the company provides continuous liquidity to ensure market resilience and efficiency across including equities, , commodities, (FX), and digital assets. The firm was established by a team of experienced traders and initially focused on equity ETPs before expanding into broader markets. It went public through an (IPO) on in 2015, which marked a significant milestone in its growth. Key expansions include entry into spot precious metals trading in 2020, in 2021, and obtaining a Qualified Foreign Institutional Investor (QFII) license for operations in 2022, building on its earlier foray into and digital assets in 2017. Flow Traders conducts its activities both on-exchange—where it is registered as a quoting bid and ask prices—and off-exchange through bilateral trades with institutional counterparties, often via request-for-quote platforms. The company leverages scalable, modular trading platforms, sophisticated frameworks, and expertise in , , and to support transparent and orderly markets. With a global footprint including offices in , , , , , , , , and , it is led by CEO Thomas Spitz (appointed 2025), CFO Hermien Smeets-Flier (2023), and CTO Owain Lloyd (2024).

History

Founding and early years

Flow Traders was founded in 2004 in , , by Jan van Kuijk and Roger Hodenius, both experienced traders from the firm , along with other key individuals including Han Sikkens. The company started as a firm dedicated to providing in exchange-traded products (ETPs), capitalizing on the burgeoning popularity of these instruments in European markets. From its outset, Flow Traders employed high-frequency and quantitative trading strategies to act as a , offering continuous bid-ask spreads on major European exchanges while maintaining a market-neutral approach to minimize risk exposure. In its early years, the firm prioritized technological development to support its liquidity provision, investing in proprietary algorithms for pricing, hedging, and execution that enabled low-latency operations across fragmented trading venues. A pivotal milestone came in 2007 with the opening of its office, which provided initial access to Asian markets and marked the beginning of international expansion. This was followed in 2008 by the introduction of off-exchange trading capabilities, allowing Flow Traders to serve over 350 institutional counterparties directly and broaden its liquidity offerings beyond exchange floors. By 2009, the establishment of a office facilitated entry into U.S. markets, enhancing the firm's global footprint and enabling 24-hour trading coverage. These developments were supported by an acquisition in 2010 of TradeSense Solutions B.V., a software firm in Cluj, , which bolstered in-house technology for quantitative strategies. Between 2008 and 2014, Flow Traders achieved organic growth without relying on external funding, expanding its employee base from approximately 178 in 2012 to 215 by 2014, with a significant portion based in Amsterdam. Trading volumes surged during this period, with European ETP value traded rising from €219 billion in 2012 to €270 billion in 2014, reflecting deepening expertise in over 4,000 ETP listings worldwide. The firm scaled its infrastructure to handle around 65 million order messages per day by 2014, operating across 94 trading venues and more than 1,100 machines in 37 data centers, all underpinned by annual technology investments exceeding €20 million. This pre-IPO phase solidified Flow Traders' reputation as a leading ETP market maker in Europe, earning designations such as "ETF Market Maker Europe" from 2007 to 2014.

Initial public offering

Flow Traders announced its intention to pursue an (IPO) on on June 18, 2015, following a period of strong pre-IPO growth that included 38% annual increases in net trading income from 2012 to 2014. The company conducted a roadshow in mid-2015 to engage investors, culminating in the publication of its prospectus on June 30, 2015, which set an indicative price range of €29.00 to €37.00 per share. The IPO was priced at €32.00 per share on July 9, 2015, at the midpoint of a revised range, with the offering comprising 16,287,075 existing shares, representing approximately 35% of the company's total shares outstanding prior to any over-allotment option. This pricing raised €521 million before any exercise of the over-allotment option, resulting in an initial of approximately €1.5 billion. The offering was underwritten by joint global coordinators and bookrunners and , along with joint bookrunners and , with N M Rothschild & Sons Limited serving as the sole financial adviser. Shares began trading on on July 10, 2015, under the FLOW and ISIN BMG3602E1084. The strategic rationale for the IPO centered on enhancing the company's visibility and profile among institutional counterparties, investors, and talent, while providing access to capital markets to support accelerated in (ETP) markets and investments in technology infrastructure. On debut, shares experienced strong demand, rising as much as 20% to around €38.40, which underscored investor confidence in Flow Traders' market-making model for ETPs amid growing market volumes. This positive short-term reception valued the firm at over €1.8 billion by the close of the first trading day.

Response to the COVID-19 pandemic

In early 2020, as the triggered global lockdowns, Flow Traders implemented innovative operational measures to ensure trading continuity while adhering to protocols. In , the company's headquarters, trading staff set up temporary "tent camps" in the office during late to create a bio-secure environment, allowing essential personnel to remain on-site and provide uninterrupted amid extreme market volatility. Similar adaptations, including split teams and limited office access with mask requirements, were applied in other locations such as and , where back-up trading facilities were activated as part of a robust business continuity plan launched in the first quarter. The heightened market turbulence, exemplified by the index peaking at 85 in March, drove a surge in trading volumes, with Flow Traders handling a total value traded of €5.2 trillion and ETP value traded reaching a record €1.5 trillion for the year. As a leading in exchange-traded products, the firm benefited from this volatility, reporting net trading income of €933.4 million and EBITDA of €586.6 million in 2020, culminating in a net profit of €464.5 million—a significant increase from €53.1 million in 2019. No infrastructure outages occurred, underscoring the effectiveness of these measures in maintaining global liquidity provision. To support broader societal impacts, Flow Traders established the Flow Traders Foundation in April 2020, committing €10 million in initial funding, including €8.5 million from the company and additional contributions from founders, the Management Board, and employees. The foundation focuses on poverty alleviation in line with UN , emphasizing health and well-being initiatives in regions where the company operates. The pandemic also accelerated policies, with the majority of employees transitioning to home-based setups supported by investments in office equipment, while online events helped preserve company culture. This period effectively stress-tested the firm's quantitative models and risk management framework, which are reviewed annually, demonstrating their resilience under unprecedented disruptions without explicit breakdowns in performance.

Corporate restructuring and recent developments

In January 2023, Flow Traders completed a major corporate by redomiciling its top holding company from the to , effective January 13, establishing Flow Traders Ltd. as the new entity. This shift was designed to improve tax efficiency and provide greater operational flexibility for global expansion, without affecting the company's profit, loss, or positions. The restructuring proceeded smoothly, incurring no material financial disruptions and allowing Flow Traders to maintain its entrepreneurial culture, which emphasizes innovation and employee-driven initiatives. By the end of 2022, the company had grown its workforce to approximately 600 employees, with steady increases continuing into subsequent years to support expanding operations. Key strategic initiatives in included the launch of Flow Traders Capital, a dedicated unit with an initial €50 million commitment focused on investments in financial and assets to foster . Later that year, on November 9, Flow Traders secured a Qualified Foreign Institutional Investor (QFII) license from Chinese regulators, enabling direct on-shore trading and liquidity provision in China's growing exchange-traded products . Leadership underwent notable transitions starting in 2023. Mike Kuehnel, previously the , was appointed effective February 1, succeeding Dennis Dijkstra to guide the firm's strategic direction amid post-pandemic recovery. Hermien Smeets-Flier joined as and on September 14, following her start as Global Finance Director in July, bringing expertise in financial oversight to bolster operational resilience. In 2024, Owain Lloyd was appointed and effective June, after joining in May, to accelerate technological advancements in trading systems. In 2025, Thomas Spitz was appointed and effective September 1, succeeding Mike Kuehnel. From 2024 to 2025, Flow Traders intensified its focus on digital assets, experiencing accelerated growth and institutional adoption that enhanced its role in this sector, contributing to overall revenue diversification.

Business activities

Core trading operations

Flow Traders operates as a firm that provides bidirectional liquidity in securities markets, primarily focusing on exchange-traded products (ETPs), options, and equities across more than 180 exchanges and trading venues worldwide. As a designated , the firm continuously quotes bid and ask prices to facilitate efficient trading, acting as a stabilizing force that enhances market transparency and reduces overall costs for participants during both normal and volatile conditions. The firm employs (HFT) algorithms to enable rapid execution and effective , leveraging proprietary quantitative models for accurate pricing and dynamic hedging of positions. These models, supported by a scalable trading platform with modular architecture, allow for quick adaptations to market changes and ensure quotes remain within predefined risk parameters through pre-trade controls. Over 40% of Flow Traders' workforce is dedicated to , underscoring the central role of advanced algorithms in their operations. Daily operations involve 24/7 monitoring of global markets from trading hubs in , the U.S., and , with a primary emphasis on minimizing bid-ask spreads and accommodating large order flows without directional market bias. The firm handles over 6,500 ETP instruments, providing on-screen via exchanges and off-exchange through bilateral trades with institutional counterparties. Revenue is primarily generated through net trading income derived from bid-ask spreads and exchange rebates, independent of client order flows as all trades are executed using the firm's own capital. For scale, Flow Traders traded €492 billion in ETP value during the second quarter of 2025, reflecting a 42% year-over-year increase and alignment with broader market growth. Risk management is governed by the Enterprise Risk Management Framework (ERMF), which includes real-time position limits monitored via net liquidation balances and pre-trade volume/price checks, alongside post-trade reconciliations with counterparties. Stress testing within the liquidity risk framework evaluates scenarios to maintain adequate buffers, ensuring operations remain robust and compliant without reliance on client-driven exposures.

Expansion into new asset classes and markets

Flow Traders began diversifying its trading operations beyond traditional exchange-traded products (ETPs) in 2017 by entering the foreign exchange () and digital assets markets. This expansion involved providing market-making services for cryptocurrency ETPs, particularly those tracking and , with the firm becoming the leading provider in European crypto ETPs and connecting to over 20 trading venues for and ETP trading. The move leveraged the company's (HFT) infrastructure to offer 24/7 in the nascent digital assets space, where institutional adoption was accelerating. By establishing bilateral relationships with exchanges and custodians, Flow Traders positioned itself as a key participant in OTC trading and ETP listings, supporting and market efficiency. In , the firm further broadened its offerings by entering precious metals trading, achieving a top-3 market-making position on major electronic communication networks (ECNs). This initiative built on the existing capabilities, which by then handled over $5 billion in daily trading volume across EMEA and APAC platforms, enhancing overall multi-asset provision. The expansion aligned with strategic investments in technology and to handle the and interconnectedness of metals with markets. By 2021, Flow Traders extended into products, including bonds and , marking a significant step in electronifying markets. The company launched single-bond market making for over 9,000 ISINs in USD and corporate , as well as bonds, and integrated as a disclosed provider on platforms like , Tradeweb, , and Neptune. This built upon its ETP expertise, where it maintained a leading role in EMEA and the , including Authorized Participant activities to bolster and transparency. Portfolio trading in European grew to €16 billion monthly, representing 6% of total activity, often involving trades exceeding €500 million. The digital assets segment experienced substantial growth post-2017, with Flow Traders handling a significant portion of global ETP liquidity by 2023 through adaptations for 24/7 markets, including specialized custody and pricing mechanisms via transparency tools like Proof of Reserves. Trading volumes in ETPs surged, reaching a global total of $87.5 billion by November 2024—an 817% increase year-over-year—with monthly averages of $72 billion in 2024 compared to $6.8 billion annually from 2021 to 2023. This growth was fueled by the launch of spot ETFs, which shifted 95.2% of global ETP volume to the by 2024, where Flow Traders provided bridging between traditional and ecosystems. Volumes doubled in the fourth quarter of 2024 versus the prior quarter and tripled year-over-year, reflecting the firm's role in over 200 ETPs worldwide. In July 2025, Flow Traders, through its joint venture AllUnity with DWS and Galaxy Digital, launched EURAU, Germany's first fully reserved and MiCAR-compliant euro-denominated stablecoin, aimed at facilitating faster and cheaper euro transactions on Ethereum via Optimism. Strategic drivers for these expansions centered on repurposing HFT systems for scalability across asset classes, enabling rapid execution and risk-neutral strategies like long/short delta-neutral positions in digital assets. Partnerships with entities such as Wormhole, Pyth Network, and AllUnity—collaborating with DWS and Galaxy Digital—facilitated new exchange listings and technological integrations for enhanced liquidity. Investments through Flow Traders Strategic Capital further supported ecosystem development in fixed income and commodities. These new asset classes contributed meaningfully to financial performance, with fixed income, commodities, FX, and digital assets collectively accounting for 51% of total net trading income (NTI) in 2024, totaling €467.8 million overall. Digital assets alone saw holdings for trading rise from €213.9 million in 2023 to €625.0 million in 2024, underscoring their role as a high-growth segment amid broader diversification efforts. In fixed income, trading volume reached €943 billion in 2024, reinforcing the segment's scale.

Global presence

Office locations and expansions

Flow Traders is headquartered in Amsterdam, Netherlands, where the company was founded in 2004 and maintains its primary operations. The Amsterdam office serves as the central hub for global strategy, , and technology development, supporting the firm's provision across international markets. The company has expanded its physical presence to 10 locations worldwide, employing 622 professionals as of October 2025. Key trading offices include , opened in 2007 as the firm's first foray into the region to facilitate regional market access and global expansion. This was followed by the New York office in 2009, established to enter the Americas and provide coverage for U.S. equities through proximity to the (NYSE). In 2017, the office was launched as the principal trading hub for operations, enhancing access to regional exchanges and counterparties. The London office, opened in 2018, supports UK and broader European activities with direct connectivity to the London Stock Exchange (LSE). Further expansions in included the office in 2020, aimed at improving efficiency with the counterparty network in , and the branch in 2021, which deepens the EMEA footprint and strengthens access to French markets and . In , the representative office opened in 2022 following the acquisition of a Qualified Foreign Institutional Investor (QFII) license, enabling onshore trading in China's rapidly growing market. The most recent addition is the office in early 2023, focused on broadening U.S. asset class coverage, including and derivatives, while leveraging local talent pools and counterparty proximity. Additionally, the office in , established in 2010, houses part of the team supporting technology infrastructure. These expansions are strategically driven by the need for close proximity to major financial exchanges, counterparties, and regulatory centers to optimize and market access. Each office specializes in regional asset classes—such as U.S. equities in or APAC ETFs in —while remaining integrated through a unified global technology platform that ensures real-time connectivity and coordinated across locations. This structure supports 24-hour liquidity provision without delving into specific acquisition-driven growth.

Key acquisitions and partnerships

In 2010, Flow Traders acquired a technology development company in Cluj, , to strengthen its proprietary software capabilities for (HFT) algorithms. This acquisition integrated a skilled Romanian software development team, known for its expertise in and engineering, complementing the firm's in-house development efforts and reducing dependence on external vendors. The move enhanced Flow Traders' technological infrastructure, enabling more efficient quantitative modeling and systems. Flow Traders has formed key partnerships with major exchanges to support exchange-traded product (ETP) listings and provision. As a designated provider on , the firm contributes to efficient trading in European ETPs, including its own IPO listing in 2015. Similarly, Flow Traders serves as a provider for in areas such as blocks and FX futures, facilitating deeper market access and execution quality for institutional clients. These collaborations have expanded the firm's role in global ETP ecosystems, driving in product and market efficiency. In 2022, Flow Traders launched Flow Traders Capital, a dedicated unit with an initial €50 million commitment, to partner with asset managers and innovative firms in . This unit focuses on investments in platforms, data solutions, and talent aligned with the firm's mission to enhance market transparency and efficiency. Concurrently, the firm obtained a Qualified Foreign Institutional Investor (QFII) license in , enabling onshore trading and strategic ties in the Asian market, including partnerships for ETP market making on exchanges like the ASX and CBOE . These initiatives have bolstered quantitative model innovations and reduced third-party reliance by fostering in-house advancements. Since 2017, Flow Traders has deepened ties with platforms to support ETPs, providing 24/7 for spot, derivatives, and regulated products across over 200 ETPs. Notable recent deals include a strategic and solver network partnership with the Foundation to improve multichain swap efficiency, and a collaboration with for integrated custody and trading infrastructure using ClearLoop. These partnerships have significantly enhanced the firm's technological edge, promoting convergence between traditional and digital markets while advancing proprietary quantitative innovations.

Leadership and governance

Executive team

The executive team at Flow Traders, as of November 2025, is led by a group of seasoned professionals focused on driving innovation in , , and technological advancement across global markets. Following the departure of Mike Kuehnel as CEO at the end of August 2025 after serving since February 2023, Thomas Spitz was elected as and effective November 1, 2025, bringing extensive experience in building high-performing trading operations. The team emphasizes a strong, team-driven culture that fosters and diversity, with members drawn from varied international backgrounds to support the firm's multi-asset class strategy. Thomas Spitz, the current CEO, has over 25 years of experience in financial markets, beginning his career as a trader at Societe Generale in 1998 before spending 21 years at Credit Agricole in progressively senior roles, including leadership in global markets. He later served as CEO of QuantCube , a firm specializing in alternative data and analytics, from February 2025, and as Global Head of Markets at from May 2022. In his role at Flow Traders, Spitz oversees the overall strategy, with a particular emphasis on expanding provision in ETFs, , and digital assets. Hermien Smeets-Flier serves as Chief Financial and Risk Officer (CFRO) and Executive Director. She was elected as Chief Financial Officer in September 2023 after joining the firm in July of that year and formally assumed the expanded CFRO role in 2025. With more than 20 years in finance, risk, and operations, primarily in insurance and asset management, she previously held the role of Chief Financial and Risk Officer at Achmea Investment Management. Smeets-Flier, a Chartered Accountant from the University of Amsterdam, manages financial reporting, compliance, investor relations, and integrated risk functions, contributing to the firm's post-merger stability and growth initiatives. Owain Lloyd, appointed and in June 2024, leads efforts in technological innovation, including AI-driven trading systems and infrastructure scalability. A British national with prior experience at , Lloyd joined Flow Traders from Numeus Research, a digital assets firm, where he was CTO and since 2022. His background supports the firm's emphasis on low-latency trading platforms and expansion into new markets. Key trading leadership includes Co-Chief Trading Officers Marc Jansen and Alex Kieft, both appointed in April 2025 to oversee global trading operations in equities, commodities, , and crypto. Jansen, who joined in 2013 as a trader focusing on commodities and later , became Head of Trading EMEA in 2018 and was elected in June 2025 effective September 1, 2025; he holds an MSc in Quantitative Finance from . Kieft, with a master's in Theoretical Physics from the , started as a trader in 2014 specializing in index products, advancing to Global Head of Trading for equities before his co-leadership role. Their appointments reflect a strategic shift to dual leadership for enhanced regional coordination. Other senior roles include Tamara Maris-Mravunac as Global Head of Risk and Compliance, who joined in 2023 from where she headed Financial Markets and Business Services; she manages enterprise-wide risk controls, compliance, and legal affairs. Cam Colella, Global Head of since advancing from his 2015 entry as a trader, oversees teams and reports to the CTO, with experience in U.S. operations since 2016. This structure underscores Flow Traders' entrepreneurial , promoting cross-functional collaboration in a diverse, global environment. The current leadership emerged from significant turnover in 2022, including the resignations of Britta Achmann in November and other executives such as Head of Trading Thomas Wolff in April, which prompted a comprehensive refresh to align with post-pandemic expansion and technological demands. This transition, culminating in the 2023-2025 appointments, has positioned the team to navigate volatile markets and pursue growth in digital assets and emerging regions.

Corporate structure and board

Flow Traders operates under a one-tier board structure, consisting of executive and non-executive directors, which is supported by a broader Global Leadership Team responsible for day-to-day management and strategic execution. This structure ensures integrated oversight of the company's operations while maintaining clear separation of roles, with executive directors handling operational leadership and non-executive directors providing independent supervision. Following the 2023 redomiciliation to , Flow Traders Ltd. is governed by Bermuda law and its bye-laws, while adhering to principles of the Dutch Corporate Governance Code for aspects such as director independence and transparency. This shift, effective from January 2023, provides enhanced flexibility for international operations and access without altering operational control or day-to-day management. The board's composition reflects a balance of expertise in , trading, , , and , with a majority of independent non-executive directors to promote objective decision-making. As of the 2025 Annual General Meeting, the board comprised nine members, including three executive directors and six independent non-executive directors. Elections at the October 30, 2025 Special General Meeting added Thomas Spitz as executive director effective November 1, 2025, and Caroline Terry as non-executive director effective November 1, 2025, following Marc Jansen's addition as executive director effective September 1, 2025, bringing the total to eleven. The board maintains dedicated committees to support governance: the Audit Committee oversees financial reporting and internal controls; the Remuneration and Appointment Committee handles compensation and succession planning; the Risk and Sustainability Committee focuses on enterprise risks and ESG integration; and the Trading and Technology Committee addresses operational and innovation matters. Governance emphasizes robust risk oversight, including market and operational risks inherent to trading activities, alongside aligned with global standards and shareholder interests through the company's listing. The board's policy targets at least one-third female or male representation among non-executive directors by 2025, a threshold met with two female non-executive directors out of six as of mid-2025, alongside diversity in nationalities, backgrounds, and competencies to foster inclusive decision-making. Annual self-assessments confirm the board's composition supports effective collective oversight.

Corporate social responsibility

Flow Traders Foundation

The Flow Traders Foundation was established on , 2020, as an independent philanthropic arm of Flow Traders N.V., initiated by company employees in response to the socioeconomic challenges posed by the . The foundation received its initial funding totaling €10 million in 2020, consisting of an €8.5 million donation from Flow Traders (including 235,000 shares valued at €6 million and other assets) and €2.5 million in personal contributions from founders, the Management Board, employees, and former employees. Its mission centers on alleviating global by supporting initiatives that enhance well-being through , , direct aid, and microcredits, with a particular emphasis on long-term solutions for individuals below the poverty line. Key initiatives include grants to non-governmental organizations (NGOs) in developing and underserved regions, such as IIMpact in , which has provided education to approximately 50,000 rural girls since 2021, and Project Backboard in the United States, which renovated community basketball courts in in 2022 to promote youth engagement. Additional programs encompass employee volunteering efforts, like a Kilimanjaro climb by 40 Flow Traders staff that raised funds for alleviation, and internal events such as poker tournaments to support charitable causes. The foundation measures impact in alignment with (SDGs), particularly SDG 1 (No ) and SDG 4 (Quality Education), ensuring grants prioritize scalable, expertise-driven projects. By 2025, the foundation had supported projects in several countries, including the (via Stichting SINA, aiding over 2,000 vulnerable households and 5,586 children since 2020), the , , and (through Dreptul la Viata for community aid). Annual donations remain tied to Flow Traders' trading performance, with subsequent years building on the initial €10 million commitment; for instance, €930,000 was donated in 2021 and nearly €900,000 in 2023, resulting in cumulative grants and commitments exceeding €10 million by 2023 and total assets reaching €8 million by 2024. Governance is handled by an independent, unpaid board comprising Dennis Dijkstra (Chairman), Jan van Kuijk (Treasurer), and Roger Hodenius (Secretary), with terms serving indefinitely and including representatives from Flow Traders' employee base to maintain alignment with the company's origins. This structure fosters a strong tie to Flow Traders' culture, embedding among traders through active participation in and , thereby reinforcing the firm's commitment to societal impact alongside its market-making operations.

Sustainability initiatives

Flow Traders has established an ESG framework guided by a Double Assessment conducted in 2023 and updated in 2024, identifying key priorities in environmental footprint, sustainable employment, and , in alignment with the Non-Financial Directive (NFRD) and monitoring developments under the Directive (CSRD) and EU Regulation. The company integrates these themes into its operations to support a transition to a sustainable through efficient financial markets, with annual sustainability disclosures included in its integrated annual reports that detail Scope 1, 2, and 3 (GHG) emissions using the GHG Protocol and operational control approach. In the social domain, Flow Traders emphasizes (DE&I) through a dedicated policy that sets key performance indicators (KPIs) for talent attraction, retention, and leadership , supporting UN (SDGs) 5 () and 8 (). As of 2024, senior management achieved 31% compared to 20% across the overall , with employees representing over 50 nationalities, exceeding the of over 20% diverse nationalities; the Non-Executive Board maintains a gender balance of two s to four males. These efforts overlap briefly with the Flow Traders Foundation's focus on sustainable by fostering inclusive opportunities. Environmentally, Flow Traders targets a 42% reduction in Scope 1 and 2 emissions by 2030 from a 2023 baseline and a 50% cut in Scope 3 emissions related to by the same year, alongside achieving 100% renewable energy in its and offices by 2030 and by 2035. In 2024, 73% of total energy consumption (4,284 MWh) was renewable, with and offices powered entirely by renewable , and efforts to reduce usage in these locations contributed to lowering the operational . energy efficiency improved significantly, with non-renewable energy emissions dropping over 40% from 2022 levels to 274 tCO₂e in 2023. Emissions disclosures for 2024 show Scope 1 at 10 tCO₂e (primarily from heating and vehicles) and Scope 2 at 692 tCO₂e (market-based ), while 2023 totals reached 4,157 tCO₂e across all scopes, with Scope 3 (including , travel, and commuting) comprising about 95%. Governance of ESG efforts is embedded through the Risk & Sustainability Committee, which provides board-level oversight of ESG risks, including climate-related impacts assessed for financial reporting with no material effects identified as of December 2024, and ensures alignment with EU sustainable finance regulations such as the NFRD and emerging CSRD requirements. The board integrates ESG into long-term value creation and , adhering to the Dutch Corporate Governance Code and conducting annual reviews of material topics. Progress includes targeted reductions in GHG emissions and adoption, with 2024 compliance awareness at 100% and scores at 7.2 out of 10 (targeting 7.7), alongside partnerships with green (ETP) issuers to provide liquidity for sustainable investments, such as serving as for the Gold ETP (AUCO2) that tracks carbon-offset gold. These initiatives reflect Flow Traders' role in facilitating the trading of ESG-focused products with minimal operational emissions.

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