Flow Traders Ltd

Lobbying Governance & Transparency

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Lobbying Governance
Overall Assessment Analysis Score
None Flow Traders Ltd outlines a broad Public Affairs Policy that explains how “we engage in policy influencing to support our business objectives, collaborating with trade associations and a diverse range of stakeholders” and highlights that “our contributions to the regulatory and legislative dialogue are typically made public,” demonstrating a degree of transparency in its activities. The company also details its involvement in industry bodies—such as “Serving on the Board of the Dutch Association of Proprietary Traders (APT)” and “Holding the vice-chair position of the Executive Committee of the European Proprietary Traders Association (FIA-EPTA)”—but does not disclose any internal mechanisms or processes for reviewing, monitoring, or aligning these lobbying efforts. We found no evidence of a named individual or formal body responsible for oversight, no description of how lobbying positions are approved or reconciled with corporate objectives, and no criteria for assessing participation in trade associations. As a result, while Flow Traders provides a policy framework for public affairs, it does not disclose any substantive governance structures or accountability measures for its lobbying activities.

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E
Lobbying Transparency
Overall Assessment Analysis Score
Limited Flow Traders offers only limited insight into its climate-related lobbying. It does name two identifiable pieces of EU financial-markets legislation that it engages on – the Markets in Crypto-Assets (MiCA) framework and the ongoing review of the Markets in Financial Instruments Regulation (MiFIR) – indicating that these are the main regulatory initiatives on which it interacts with policymakers. The company states that it “collaborates with governments, regulators, interest groups and trade associations” and lists its participation in bodies such as the EU Consolidated Tape Expert Group and the European Central Bank’s Foreign Exchange Contact Group, but it does not explain whether its engagement takes the form of written submissions, bilateral meetings or public consultations, nor does it consistently identify the specific government departments or officials it approaches. On objectives, Flow Traders signals a general preference for “robust market transparency” and the creation of a near real-time consolidated tape in bond markets, and notes that it seeks to shape the emerging digital-assets rule-set under MiCA, yet it stops short of setting out concrete amendments, timetables or quantitative targets it is pressing for. As a result, while the disclosure confirms that lobbying occurs and points to the broad regulatory areas involved, the company remains opaque about the detailed methods and precise policy outcomes it is pursuing.

D