Supervision

The Commodity Discovery Fund meets all legal and regulatory requirements and collaborates with a large number of professional service providers. From a legal point of view, the fund is a fund for joint account (Fonds voor Gemene Rekening), which was incorporated in the Netherlands (2008) and is also established there under the UCITS regime.

Supervision is structured as follows:
- CDFund is registered/supervised by The Dutch Authority for the Financial Markets
- CDFund is supervised by De Nederlandsche Bank
- CDFund is affiliated with the Dutch Institute for Financial Disputes Kifid

UCITS
UCITS was introduced to provide greater transparency and protection for investors. The UCITS guideline is in line with the previously determined AIFMD, a similar guideline, but applicable to real estate and hedge funds. The introduction has ensured that all funds that can be traded in the EU are protected throughout the EU in the same way. The protection stems from the introduction of a so-called depositary. The depositary checks all the cash flows of a fund in order to prevent fraudulent behaviour. UCITS is translated as ICBE in the Netherlands. Investors must also be elaborately informed about the fund by means of what is known as a key investor information document. All other information can be found in a very extensive Offering Memorandum.

Manager
The fund's manager is Commodity Discovery Management B.V, of which Willem Middelkoop, as initiator and co-founder, owns 50% of the shares. After the buyout of co-founders Jan Dobber (2014) and Edwin Bergshoeff (2016), the other 50% of these shares are now owned by seven individual participants.

Directors
The board, which has been assessed by both The Dutch Authority for the Financial Markets (AFM) and De Nederlandsche Bank (DNB), is formed by Terence van der Hout and Willem Middelkoop. They have been working together since 2005 to identify the best commodity discoveries worldwide and to further develop the 'Discovery Investing' strategy.

AFM
The fund's manager, Commodity Discovery Management B.V., received its AFM license on March 29, 2012. The license was converted on 21 July 2014, and since then, Commodity Discovery Management B.V. is registered as UCITS manager in the AFM register, which means that it is subject to an even stricter supervisory regime. The AFM assesses whether all relevant laws and regulations have been complied with and whether the correct information is provided via, for example, the Offering Memorandum. Click here for a link to the AFM website.

DNB
De Nederlandsche Bank is an independent central bank and, as a supervisor, has examined the reliability of the directors and checks whether the Commodity Discovery Fund is financially sound.

Kifid
Kifid, the Dutch Institute for Financial Disputes, is the expert financial grievances institute and accessible for consumers, small business entrepreneurs and the self-employed. Kifid helps to solve issues between consumers and their bank, insurer, intermediary or other financial services provider. This is done through mediation or by a (usually) legally binding ruling from a Disputes Committee. In this way, Kifid helps consumers and entrepreneurs to find a solution, as an alternative to the courts.

Participant administration
The administrative interests of the participants in the fund are managed by Bolder Fund Services (Netherlands) B.V. (formerly Circle Partners), an international independent service provider. Bolder Fund Services (Netherlands) B.V. manages the portfolio administration and the participant administration, and calculates the net asset value of the portfolio on a monthly basis. A transparent statement, and if desired, a personalized internet access, will keep you informed of the value of your participations.

Financial Service Provider
CACEIS, Netherlands is an independent business partner active worldwide and manages the processing of orders for the fund.

External Compliance Officer
Commodity Discovery Management B.V. works with Compliance Advies Financiële ondernemingen in the field of legal compliance and regulation, AFM license and advice regarding the Commodity Discovery Fund.

Accountants
Crowe Foederer audits the annual financial statement of Commodity Discovery Management B.V.. Since 2023 RSM Netherlands Accountants N.V. audits the annual financial statement of Commodity Discovery Fund.

Fund partners

Back to topBack to top