In our opinion the transaction executed under the framework of a non-standard contract (paragraph 3.2.6 of the TRUM in the separated box), is the inception of the contract itself (i.e. signature of the contract) or contractual amendments issued. On the contrary the specific lifecycle events that occur after the signature (e.g. price switch, additional quantities) are the mere exercise of a contractual right. Could you confirm it?
In the Agency’s view the explanation in paragraph 3.2.6 of the Transaction Reporting User Manual (TRUM) in the separated box is clear: each exercise of the contractual right is a reportable transaction.