Global Asset Management

Corporate Environmental, Social and Governance Policy Statement

True Partner’s environmental, social and corporate governance (ESG) policy is based on evaluations which are principally consistent with and supportive of the United Nations Principles of Responsible Investment.

True Partner seeks to provide its clients with superior risk-adjusted investment returns and client service. As an asset manager, we act as a fiduciary on behalf of our clients and seek to develop long-term partnerships to help our clients achieve their investment goals. As a company, we seek to be a responsible corporate citizen in the communities in which we operate and to be mindful of our overall environmental footprint.

We believe that incorporation of relevant environmental, social and corporate governance factors into our investment and non-investment processes and practices will support these objectives. ESG analysis can help to identify potential risk factors and opportunities, make us more efficient in our use of resources, and better align our corporate footprint with the values and goals of our stakeholders. Over time we believe this will help us to recruit and retain the best talent and to be an effective long-term partner to our clients.

We are a global company and value diverse perspectives and experience. We seek to attract talent from all backgrounds and have zero-tolerance for any forms of discrimination in the workplace, including on the grounds of race, gender, ethnicity, religion and other legally protected statuses.

We seek to govern the Firm in a way that supports our belief in the power of the team, provides attractive opportunities for individual growth, offers appropriate transparency, and recognises the value of independent external perspectives. We provide opportunities for wide equity participation to our team, encourage an open dialogue with our investors, and benefit from the skills and experience of our independent directors. We recognize the benefits of compliance and regulation and place a high priority on having and following appropriate policies and procedures.

We always take steps to manage the environmental impacts of our operations through practical initiatives and thoughtful working practices.

In line with the UN Principles for Responsible Investment, and in support of our objective of providing clients with superior risk-adjusted returns, as fiduciaries we believe that environmental, social, and corporate governance issues can affect the performance of investment portfolios to varying degrees across companies, sectors, regions, asset classes and through time. Given the fact that we primarily invest for our clients in index options it is harder to incorporate ESG consideration into the investment decision process. However, were possible we seek to incorporate ESG factors into our investment analysis as one aspect of a robust investment process.

The Firm has a primary focus on volatility strategies in equity index related products and has a trading orientated approach. We seek to trade in liquid, well governed markets that offer attractive alpha opportunities. As a result, ESG factors are typically most impactful at the product selection stage, where they can help us to identify whether potential markets may have uncompensated risks. An example of such uncompensated risks would be a jurisdiction where changes in contract value could occur without an investor having recourse (such as the non-payment of dividends or adjustments of contract specifications). ESG factors can also be relevant when assessing potential event risks in some traded markets, particularly in instruments linked to individual corporate securities. Similarly, on a company level ESG factors such as the risk of government appropriation of assets would add potential risks which are outside of the scope of the quantitative models. It is important to note that while the investments underlying the True Partner Volatility Fund, True Partner Offshore Fund and TP Customized Volatility Fund do not take into account the EU criteria for environmentally sustainable investments under Regulation (EU) 2020/852, we have incorporated sustainable risks in our investment decision-making processes by incorporating such events in our risk framework - any shock (whether caused by ESG or non-ESG events) is taken into account in our scenario-based stress testing.

When selecting products and markets to trade, external perspectives are applied:

  • With regards to equity indices, our strategy trades derivatives on the world’s main equity indices. Given this product set, the index options and futures we trade are generally listed on a UN Sustainable Stock Exchange. In the unlikely situation where an instrument would not be traded on such exchange, this relevant instrument would be omitted from our product universe
  • With regards to the trading of single stocks and the overlying options, these names cannot be on the Exclusion List as prepared and published by one of the world’s largest pension funds which has a long-standing and thoughtful approach in this area.

Given our trading orientated approach, we typically have limited net market exposure and are not long-term holders of individual securities. Where relevant we will seek to vote proxies in accordance with our investors’ best interests, and where possible we take into account any ESG considerations.

At the investment level, our ESG policy is reviewed annually as part of the Risk Committee’s annual policy review. At the Firm level, our ESG policy is reviewed annually by the Board of Directors.


The Sustainable Finance Disclosure Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 ("SFDR"), requires True Partner to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAI”) of its investment decisions on sustainability factors and in its investment advice, in accordance with the specific regime outlined in SFDR. PAIs are described as impacts of investment decisions and advice that result, or might result, in negative effects on sustainability factors, such as environmental, social and employee matters, respect for human rights, anticorruption or anti-bribery matters.

True Partner evaluated the requirements of the PAI regime under Article 4 of the SFDR and in the Regulatory Technical Standards as published in April 2022 by the European Supervisory Authorities. True Partner is supportive of the policy aims of the PAI regime, including, to improve transparency but does not currently consider PAI at an entity level. This is because an entity that considers PAI is required to do so across all asset classes being managed by that entity and as True Partner primarily invests in stock index derivatives where PAI consideration is less relevant, it is unclear how compliance can be achieved at entity level at this stage. It would likely be very challenging to conduct a detailed PAI due diligence assessment on the stock indices’ component securities. It is further noted that there is currently a lack of readily available data on the mandatory PAI indicators which does not have sufficient coverage of the investment universes of the Funds to provide transparent and reliable information to shareholders.

True Partner will continue to closely monitor the development of data quality [and shareholder demand with respect to PAI consideration] and will revisit it decision with respect to PAI on at least a yearly basis. True Partner reserves the right to change its position in the future. Where PAI is considered at a Fund level, this will be disclosed in the relevant Supplement for that Fund.


References to the “True Partner Group”; “True Partner”, “True Partner Capital”; “the Firm”, “our”, “or we”, in this policy should be regarded as references to the True Partner Group, or the relevant wholly owned company/companies within the True Partner Group including True Partner Capital Holding Limited, True Partner Holding Limited, True Partner Advisor Limited, True Partner Capital Netherlands B.V., True Partner Advisor Hong Kong Limited, and True Partner Capital USA Holding, Inc. For specific information regarding the role of different entities in the implementation of our policies please contact us using the website Contact us page.