BW Gestao de Investimentos Ltda.

$3.0B reported 13(f) long value · latest quarter 2026-03-31 · CIK 1568280 · EDGAR ↗
sum of disclosed values for 2026-03-31; 0 positions carry a NULL value and are excluded from the sum, surfaced here rather than folded away
$3.0B
ALL retained default holdings for this (filer, period), including NULL-value ones
270
positions with no comparable holding in the prior quarter (kind new), 2026-03-31
135
positions absent from this quarter's filing after being held last quarter (kind exit), 2026-03-31 — inferred from absence, not a sale record
70
A quarter-end snapshot. Filed up to 45 days later, so this page is not current holdings and never a complete portfolio. what a 13F is — and is not ↓ methodology §13F ↗
FILING WINDOW OPEN
Quarter 2026-09-30: the 13F window is open until 2026-11-16. Rankings and QoQ moves that touch this quarter are provisional by construction — filers who have not yet reported are not zeros.

Position changes — into 2026-03-31

by shares · Δ value · filing link · how changes are classified §
Period
Position changes into quarter 2026-03-31
position matched across quarters by exact reported CUSIP over a registry gap — producer-reconciled identity, never a name match identity_reconciled_by_cusipthe reported share count is unchanged across the pair; this build's data classified the change from its reported value; builds from 2026-09-10 on read it as NO CHANGE classified_by_value · EXIT = absent this quarter: disposed, delisted, under confidential treatment, or reported instead by an affiliated manager — the filing does not say which · change not classifiable: value undisclosed on one side of the quarter pair, or neither shares nor value can classify it · NO CHANGE = the share count is identical in both quarters; the value moved only with price, so the row is mark-to-market and never an ADD or a TRIM (NEW / ADD / TRIM / EXIT / NO CHANGE) · NO PRIOR = this filer has no comparable holdings list for the previous quarter on record — a first filing under this registration, or a quarter reported inside an affiliated manager's filing — so the position is not called a new stakederived by Public Filings from the published aggregate; NULL means the source did not disclose a usable value — never zeroreported unit changed across the pair (SH↔PRN); the share delta is withheld rather than fabricated shares_unit_mismatchPrev valueCurr valuePrev sharesCurr shares
position key pos:11570 · issuer key iss:1599 TR UNIT PUTTRIM−$251M−350,000$511M$260M750,000400,000
position key pos:15702 · issuer key iss:1012 RUSSELL 2000 ETF PUTTRIM−$96.8M−400,000$320M$223M1,300,000900,000
position key pos:10307 · issuer key iss:1012 CORE S&P500 ETFTRIM−$310M−438,806$506M$196M738,842300,036
position key pos:10357 · issuer key iss:1786 COM PUTNEW+$74.4M+200,000$0$74.4M—200,000
position key pos:17824 · issuer key iss:1514 COMTRIM−$11.3M−60,711$80.9M$69.5M785,947725,236
position key pos:17130 · issuer key iss:1776 COM NEWTRIM−$10.6M−36,955$71.0M$60.5M357,435320,480
position key pos:11173 · issuer key iss:995 UNIT SER 1 PUTTRIM−$127M−200,000$184M$57.7M300,000100,000
position key pos:17300 · issuer key cusip6:81369Y STATE STREET UTITRIM−$7.8M−250,000$49.1M$41.3M1,150,000900,000
position key pos:13249 · issuer key iss:632 CL AADD+$11.6M+80,663$28.2M$39.9M259,871340,534
position key pos:15702 · issuer key iss:1012 RUSSELL 2000 ETF CALLTRIM−$36.6M−150,000$73.8M$37.2M300,000150,000
position key pos:15447 · issuer key cusip6:78574H COM SHSADD+$21.9M+661,883$13.2M$35.2M1,467,2222,129,105
position key pos:15179 · issuer key iss:1012 EXPANDED TECH CALLNEW+$32.0M+400,000$0$32.0M—400,000
position key sid:sec:prov:eccbebd4ae697b4cc5b742610cdbf1dd · issuer key cusip6:37954Y GLOBAL X COPPERNEW+$31.3M+410,050$0$31.3M—410,050
position key pos:12827 · issuer key iss:323 COMADD+$24.0M+79,900$6.9M$30.9M20,00099,900
position key sid:sec:prov:2b5902c05a996d81adf5ce01e71326f4 · issuer key cusip6:81369Y STATE STREET HEATRIM−$11.7M−65,000$41.2M$29.5M266,000201,000
position key pos:16278 · issuer key iss:390 COM CALLNEW+$27.4M+150,000$0$27.4M—150,000
position key pos:15494 · issuer key iss:98 COMADD+$17.2M+1,863,000$9.3M$26.5M605,0002,468,000
position key pos:13768 · issuer key iss:1651 COMADD+$7.1M+22,644$17.9M$25.0M55,21477,858
position key pos:11791 · issuer key iss:1333 CL ATRIM−$10.3M−33,510$34.3M$23.9M663,074629,564
position key pos:15622 · issuer key iss:282 COMADD−$443K+46,804$22.9M$22.5M148,776195,580
position key pos:16716 · issuer key iss:633 COMTRIM−$9.8M−38,433$31.7M$21.9M120,78782,354
position key pos:18087 · issuer key iss:578 COMADD+$889K+4,317$20.6M$21.5M104,048108,365
position key pos:15111 · issuer key iss:2070 SHSTRIM−$9.8M−70,237$30.9M$21.1M1,267,3731,197,136
position key pos:13738 · issuer key iss:1698 COMNEW+$20.2M+209,292$0$20.2M—209,292
position key pos:11461 · issuer key iss:102 COMTRIM+$501K−16,613$19.6M$20.1M169,861153,248
position key pos:14868 · issuer key iss:68 COMADD+$15.9M+224,903$4.1M$20.1M77,455302,358
position key pos:15409 · issuer key iss:1212 COM CL AADD+$13.3M+290,000$6.3M$19.6M150,000440,000
position key pos:13598 · issuer key iss:1994 COMADD+$1.5M+1,780$17.9M$19.4M242,457244,237
position key pos:17974 · issuer key iss:488 COMNEW+$19.3M+14,023$0$19.3M—14,023
position key pos:11825 · issuer key iss:1225 COMADD+$4.7M+21,833$14.5M$19.2M29,97651,809
position key pos:10663 · issuer key iss:1575 COMADD+$17.6M+79,896$1.4M$19.0M7,79587,691
position key pos:10128 · issuer key iss:1413 COMADD+$6.8M+7,359$12.0M$18.9M13,70921,068
position key pos:15958 · issuer key iss:1753 COMADD−$2.9M+907$21.8M$18.8M58,07758,984
position key pos:11354 · issuer key iss:506 COMTRIM+$470K−18,023$18.0M$18.5M181,065163,042
position key pos:12241 · issuer key iss:2267 COMADD−$5.3M+36,037$23.5M$18.2M359,487395,524
position key pos:11654 · issuer key iss:1847 CL ATRIM−$31.5M−1,393,200$49.7M$18.2M3,032,1501,638,950
position key pos:17283 · issuer key iss:425 COMADD+$10.9M+125,089$7.2M$18.1M183,669308,758
position key pos:16659 · issuer key iss:1408 COMADD+$9.2M+160,219$8.1M$17.3M155,980316,199
position key pos:10501 · issuer key iss:779 CL BADD+$6.5M+82,894$10.5M$17.0M206,938289,832
position key pos:12993 · issuer key iss:1898 COM CL ANEW+$16.9M+1,074,345$0$16.9M—1,074,345
position key pos:15221 · issuer key iss:1228 COM PUTNEW+$16.9M+50,000$0$16.9M—50,000
position key pos:13215 · issuer key iss:144 COMADD+$7.8M+32,930$9.1M$16.9M33,46666,396
position key pos:11024 · issuer key iss:1014 ISHARESNEW+$16.4M+240,475$0$16.4M—240,475
position key pos:15560 · issuer key iss:1973 COMNEW+$16.0M+220,000$0$16.0M—220,000
position key pos:11170 · issuer key iss:421 COMADD+$7.7M+155,604$8.2M$16.0M213,988369,592
position key pos:16477 · issuer key iss:760 COM SHS CL ANEW+$15.8M+540,000$0$15.8M—540,000
position key pos:14766 · issuer key iss:2259 SHSADD+$8.6M+149,854$7.1M$15.8M131,457281,311
position key pos:15612 · issuer key iss:2009 COMNEW+$15.3M+265,000$0$15.3M—265,000
position key pos:11791 · issuer key iss:1333 CL A CALLNEW+$15.2M+400,000$0$15.2M—400,000
position key pos:17299 · issuer key iss:2076 ORD SHSADD+$472K+1,577,621$14.5M$15.0M4,345,3215,922,942
position key pos:11606 · issuer key iss:1702 COMTRIM+$370K−9,590$14.0M$14.4M174,847165,257
position key pos:12594 · issuer key iss:951 COMADD+$2.8M+8,841$11.5M$14.2M90,74099,581
position key pos:13463 · issuer key iss:1942 COM SER AADD+$2.2M+100,000$12.0M$14.2M415,928515,928
position key pos:10376 · issuer key iss:1461 CL AADD−$2.0M+41,086$16.1M$14.1M148,552189,638
position key pos:15631 · issuer key iss:1841 COMTRIM−$1.3M−23,794$15.0M$13.8M401,594377,800
position key pos:16727 · issuer key iss:991 COMTRIM−$4.1M−73,947$17.1M$13.1M254,304180,357
position key pos:10194 · issuer key iss:1593 COMADD+$9.0M+139,739$4.0M$13.0M81,202220,941
position key pos:11582 · issuer key iss:1267 COM NEWTRIM−$12.0M−68,197$24.8M$12.8M155,89587,698
position key sid:sec:prov:be176e77eb8e8343181c9cdad494dc39 · issuer key cusip6:37954Y LITHIUM BTRY ETFNEW+$12.8M+172,000$0$12.8M—172,000
position key pos:16694 · issuer key iss:1302 COM NEWTRIM−$78.5K−50,000$12.6M$12.5M1,000,000950,000
position key pos:12154 · issuer key iss:822 COMADD+$8.4M+158,542$4.1M$12.5M65,864224,406
position key pos:15524 · issuer key iss:236 COMADD+$4.4M+95,000$7.8M$12.2M175,000270,000
position key pos:10809 · issuer key iss:1858 COMADD+$3.8M+57,400$8.4M$12.2M75,000132,400
position key pos:10499 · issuer key iss:469 CL A COMNEW+$12.1M+58,779$0$12.1M—58,779
position key sid:sec:prov:03a8d614b00ecef565651990155645eb · issuer key cusip6:37954Y GLOBAL X URANIUMTRIM+$593K−19,300$11.5M$12.0M268,100248,800
position key pos:17976 · issuer key iss:547 COMTRIM+$1.2M−1,914$10.7M$12.0M19,48917,575
position key pos:17728 · issuer key iss:1455 COMNEW+$11.9M+137,604$0$11.9M—137,604
position key pos:10705 · issuer key iss:2209 COM SHSADD+$281K+8,174$10.9M$11.2M97,472105,646
position key pos:10357 · issuer key iss:1786 COMNEW+$11.2M+30,000$0$11.2M—30,000
position key pos:14175 · issuer key iss:95 COMADD+$1.1M+9,852$9.9M$11.0M43,01952,871
position key pos:13607 · issuer key iss:485 COMADD+$1.2M+50,000$9.8M$11.0M350,000400,000
position key pos:16143 · issuer key iss:448 COM NEWNEW+$10.9M+28,085$0$10.9M—28,085
position key pos:10925 · issuer key iss:1309 CLASS A COMTRIM−$3.0M−68,189$13.6M$10.6M155,89587,706
position key pos:11219 · issuer key iss:1925 COMNEW+$10.5M+70,132$0$10.5M—70,132
position key pos:13589 · issuer key iss:584 COMNEW+$10.5M+122,624$0$10.5M—122,624
position key pos:12151 · issuer key iss:1391 COMTRIM−$4.6M−342,616$14.9M$10.2M925,788583,172
position key pos:11120 · issuer key iss:749 COMTRIM−$5.0M−138,605$15.2M$10.1M338,898200,293
position key pos:13160 · issuer key iss:1012 MSCI EMG MKT ETFNEW+$9.9M+175,009$0$9.9M—175,009
position key pos:12492 · issuer key iss:810 COM NEWNEW+$9.9M+34,889$0$9.9M—34,889
position key pos:15321 · issuer key iss:1602 STATE STREET SPDNEW+$9.9M+100,000$0$9.9M—100,000
position key pos:15005 · issuer key iss:415 COMADD+$654K+3,863$9.2M$9.9M31,17935,042
position key pos:17670 · issuer key iss:1145 COMTRIM−$3.1M−21,060$12.9M$9.8M35,07614,016
position key sid:sec:prov:fb4dd60b1539f2f6470b821b0dced66b · issuer key cusip6:G21307 COM CL ATRIM+$1.6M−85,000$8.2M$9.8M2,010,6651,925,665
position key pos:12759 · issuer key iss:1867 COM SHSNEW+$9.7M+1,028,818$0$9.7M—1,028,818
position key pos:15152 · issuer key iss:1000 S&P500 EQL WGTTRIM−$278M−1,449,322$287M$9.6M1,499,10049,778
position key pos:11621 · issuer key iss:1253 COM NEWADD+$1.2M+10,811$8.3M$9.5M46,94557,756
position key pos:12600 · issuer key iss:694 COMTRIM−$6.6M−106,073$16.0M$9.3M220,173114,100
position key pos:16942 · issuer key iss:1410 COM CL BADD+$1.7M+464,187$7.6M$9.3M564,9141,029,101
position key pos:15755 · issuer key iss:1719 COMADD+$3.2M+76,967$6.0M$9.2M48,000124,967
position key pos:16278 · issuer key iss:390 COMTRIM−$16.9M−57,126$26.1M$9.2M107,60650,480
position key pos:17793 · issuer key iss:1061 COMNEW+$9.2M+300,542$0$9.2M—300,542
position key pos:16729 · issuer key iss:1054 COMNEW+$9.2M+456,944$0$9.2M—456,944
position key pos:14857 · issuer key iss:51 COMTRIM−$3.0M−9,000$12.1M$9.1M42,00033,000
position key pos:17217 · issuer key iss:273 COMADD+$3.1M+44,519$6.0M$9.1M86,219130,738
position key pos:12987 · issuer key iss:1979 COMNEW+$9.0M+65,000$0$9.0M—65,000
position key pos:12359 · issuer key iss:566 COM NEWADD+$361K+10,836$8.5M$8.9M123,000133,836
position key sid:sec:prov:dfc258937165c462fd1ad3d4e37e4beb · issuer key cusip6:03938L NY REGISTRY SHTRIM−$218K−28,851$9.1M$8.9M200,000171,149
position key pos:18039 · issuer key iss:1025 COMTRIM−$9.3M−26,097$18.1M$8.8M56,11730,020
position key pos:10483 · issuer key iss:777 COMNEW+$8.8M+35,702$0$8.8M—35,702
position key pos:16804 · issuer key iss:1945 COMADD+$1.5M+12,609$7.3M$8.8M41,63054,239

Flags: no row carries a flag.

1–20 of the 100 changes on this page

1–100 of 332 changes
Mark-to-market only (no share change) · 8

Positions whose share count is identical in both quarters; the value changed with price, not with a decision.

Positions held with no share change into quarter 2026-03-31
position matched across quarters by exact reported CUSIP over a registry gap — producer-reconciled identity, never a name match identity_reconciled_by_cusipthe reported share count is unchanged across the pair; this build's data classified the change from its reported value; builds from 2026-09-10 on read it as NO CHANGE classified_by_value · EXIT = absent this quarter: disposed, delisted, under confidential treatment, or reported instead by an affiliated manager — the filing does not say which · change not classifiable: value undisclosed on one side of the quarter pair, or neither shares nor value can classify it · NO CHANGE = the share count is identical in both quarters; the value moved only with price, so the row is mark-to-market and never an ADD or a TRIM (NEW / ADD / TRIM / EXIT / NO CHANGE) · NO PRIOR = this filer has no comparable holdings list for the previous quarter on record — a first filing under this registration, or a quarter reported inside an affiliated manager's filing — so the position is not called a new stakederived by Public Filings from the published aggregate; NULL means the source did not disclose a usable value — never zeroreported unit changed across the pair (SH↔PRN); the share delta is withheld rather than fabricated shares_unit_mismatchPrev valueCurr valuePrev sharesCurr shares
position key sid:sec:prov:0befaea9161cd0690da52313a43e4b88 · issuer key cusip6:29970N COMNO CHANGE−$5.6M0$14.7M$9.1M3,686,1403,686,140
position key pos:14553 · issuer key cusip6:00214Q INNOVATION ETFNO CHANGE−$817K0$6.7M$5.9M87,57787,577
position key pos:11654 · issuer key iss:1847 CL A CALLNO CHANGE−$2.6M0$8.2M$5.6M500,000500,000
position key pos:10798 · issuer key iss:2283 SHSNO CHANGE−$263K0$5.8M$5.5M40,00040,000
position key sid:sec:prov:9886204f7314eeb6ea4d19d9d7721d16 · issuer key cusip6:78468R STATE STREET SPDNO CHANGE+$998K0$2.3M$3.3M17,95517,955
position key pos:18083 · issuer key iss:1781 COMNO CHANGE+$286K0$2.7M$3.0M50,00050,000
position key pos:10703 · issuer key iss:389 COMNO CHANGE−$310K0$1.1M$807K71,01571,015
position key pos:13432 · issuer key iss:411 COMNO CHANGE+$92.2K0$390K$482K680680

Flags: no row carries a flag.

Newest filing in this build: 2026-07-31. Per-row filing dates are on each receipt.
Truncated by Public Filings. Changes compare every position with a security identifier, new and exited included; holdings without one are counted, not compared. methodology §13F ↗

Reported positions — 2026-03-31

1–100 of 256 issuers · $3.0B disclosed value over 270 rows · 0 undisclosed-value rows
View
This build carries one quarter for this manager: 2026-03-31. Notable managers carry four published quarters, others two.
Positions BW Gestao de Investimentos Ltda. reported for the quarter ended 2026-03-31, as that filer reported them
This list carries reported issuer names and security identities, without a dated ticker mapping. Symbols are not inferred from names.a position composed from a base filing plus NEW-HOLDINGS amendments keeps every source row here; the composition's latest filed date is the one shown served from this build's published holdings (derived from the filer's own reported rows); every row resolves to its filingShare of total reported value, calculated only when the full position list has disclosed values. This is 13F long value, not total assets.value undisclosed on the filing: retained and counted, excluded from sums, never shown as $0SharesWt
—ISHARES TR
5 positions · 5 reported rows
Rows BW Gestao de Investimentos Ltda. reported for ISHARES TR, as it reported them
ISHARES TR · RUSSELL 2000 ETF · PUT CUSIP — $223M900,000
ISHARES TR · CORE S&P500 ETF CUSIP — $196M300,036
ISHARES TR · RUSSELL 2000 ETF · CALL CUSIP — $37.2M150,000
ISHARES TR · EXPANDED TECH · CALL CUSIP — $32.0M400,000
ISHARES TR · MSCI EMG MKT ETF CUSIP — $9.9M175,009
ticker not yet mapped
$498M1,925,04516.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)STATE STR SPDR S&P 500 ETF T · TR UNIT · PUT CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$260M400,0008.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)TESLA INC
2 positions · 2 reported rows
Rows BW Gestao de Investimentos Ltda. reported for TESLA INC, as it reported them
TESLA INC · COM · PUT CUSIP — $74.4M200,000
TESLA INC · COM CUSIP — $11.2M30,000
$85.5M230,0002.8%
—SELECT SECTOR SPDR TR
2 positions · 2 reported rows
Rows BW Gestao de Investimentos Ltda. reported for SELECT SECTOR SPDR TR, as it reported them
SELECT SECTOR SPDR TR · STATE STREET UTI CUSIP — $41.3M900,000
SELECT SECTOR SPDR TR · STATE STREET HEA CUSIP 81369Y209 $29.5M201,000
ticker not yet mapped
$70.8M1,101,0002.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)RB GLOBAL INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$69.5M725,2362.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)TENET HEALTHCARE CORP · COM NEW CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$60.5M320,4802.0%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)INVESCO QQQ TR · UNIT SER 1 · PUT CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$57.7M100,0001.9%
—GLOBAL X FDS
3 positions · 3 reported rows
Rows BW Gestao de Investimentos Ltda. reported for GLOBAL X FDS, as it reported them
GLOBAL X FDS · GLOBAL X COPPER CUSIP 37954Y830 $31.3M410,050
GLOBAL X FDS · LITHIUM BTRY ETF CUSIP 37954Y855 $12.8M172,000
GLOBAL X FDS · GLOBAL X URANIUM CUSIP 37954Y871 $12.0M248,800
ticker not yet mapped
$56.1M830,8501.9%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)ECHOSTAR CORP · CL A CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$39.9M340,5341.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)NUTANIX INC
2 positions · 2 reported rows
Rows BW Gestao de Investimentos Ltda. reported for NUTANIX INC, as it reported them
NUTANIX INC · CL A CUSIP — $23.9M629,564
NUTANIX INC · CL A · CALL CUSIP — $15.2M400,000
$39.1M1,029,5641.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CAPITAL ONE FINL CORP
2 positions · 2 reported rows
Rows BW Gestao de Investimentos Ltda. reported for CAPITAL ONE FINL CORP, as it reported them
CAPITAL ONE FINL CORP · COM · CALL CUSIP — $27.4M150,000
CAPITAL ONE FINL CORP · COM CUSIP — $9.2M50,480
$36.6M200,4801.2%
—SABLE OFFSHORE CORP · COM SHS CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
ticker not yet mapped
$35.2M2,129,1051.2%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)BROADCOM INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$30.9M99,9001.0%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CAPRI HOLDINGS LIMITED
2 positions · 2 reported rows
Rows BW Gestao de Investimentos Ltda. reported for CAPRI HOLDINGS LIMITED, as it reported them
CAPRI HOLDINGS LIMITED · SHS CUSIP — $21.1M1,197,136
CAPRI HOLDINGS LIMITED · SHS · CALL CUSIP — $7.0M400,000
$28.1M1,597,1360.9%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)AMERICAN AIRLINES GROUP INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$26.5M2,468,0000.9%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)SHERWIN WILLIAMS CO · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$25.0M77,8580.8%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)UIPATH INC
2 positions · 2 reported rows
Rows BW Gestao de Investimentos Ltda. reported for UIPATH INC, as it reported them
UIPATH INC · CL A CUSIP — $18.2M1,638,950
UIPATH INC · CL A · CALL CUSIP — $5.6M500,000
$23.7M2,138,9500.8%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)BLACKSTONE INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$22.5M195,5800.7%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)ECOLAB INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$21.9M82,3540.7%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)DICKS SPORTING GOODS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$21.5M108,3650.7%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)SOUTHERN CO · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$20.2M209,2920.7%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)AMERICAN ELEC PWR CO INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$20.1M153,2480.7%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)ALCOA CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$20.1M302,3580.7%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)MEDLINE INC · COM CL A CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$19.6M440,0000.7%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)XCEL ENERGY INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$19.4M244,2370.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)COMFORT SYS USA INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$19.3M14,0230.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)MICROSOFT CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$19.2M51,8090.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)ROSS STORES INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$19.0M87,6910.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)PARKER-HANNIFIN CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$18.9M21,0680.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)TALEN ENERGY CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$18.8M58,9840.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CONSOLIDATED EDISON INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$18.5M163,0420.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)GLOBANT S A · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$18.2M395,5240.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CENTURY ALUM CO · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$18.1M308,7580.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)PAN AMERN SILVER CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$17.3M316,1990.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)FREEPORT MCMORAN INC · CL B CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$17.0M289,8320.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)VENTURE GLOBAL INC · COM CL A CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$16.9M1,074,3450.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)MICRON TECHNOLOGY INC · COM · PUT CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$16.9M50,0000.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)APPLE INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$16.9M66,3960.6%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)ISHARES SILVER TR · ISHARES CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$16.4M240,4750.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)WILLIAMS COS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$16.0M220,0000.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CENTERPOINT ENERGY INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$16.0M369,5920.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)FORGENT POWER SOLUTIONS INC · COM SHS CL A CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$15.8M540,0000.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)AMRIZE LTD · SHS CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$15.8M281,3110.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)ZIONS BANCORPORATION NATL AS · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$15.3M265,0000.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CLARIVATE PLC · ORD SHS CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$15.0M5,922,9420.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)SOUTHWEST GAS HLDGS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$14.4M165,2570.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)IDACORP INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$14.2M99,5810.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)WARNER BROS DISCOVERY INC · COM SER A CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$14.2M515,9280.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)PLANET FITNESS MASTER ISSUER · CL A CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$14.1M189,6380.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)UGI CORP NEW · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$13.8M377,8000.5%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)INTERNATIONAL FLAVORS&FRAGRA · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$13.1M180,3570.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)H2O AMERICA · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$13.0M220,9410.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)NRG ENERGY INC · COM NEW CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$12.8M87,6980.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)FLAGSTAR BANK NATIONAL ASSOC · COM NEW CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$12.5M950,0000.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)GILDAN ACTIVEWEAR INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$12.5M224,4060.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)BANKUNITED INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$12.2M270,0000.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)UNITED AIRLS HLDGS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$12.2M132,4000.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CLOUDFLARE INC · CL A COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$12.1M58,7790.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CURTISS WRIGHT CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$12.0M17,5750.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)PINNACLE FINL PARTNERS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$11.9M137,6040.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)SHARKNINJA INC · COM SHS CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$11.2M105,6460.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)AMAZON COM INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$11.0M52,8710.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)COLUMBIA BKG SYS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$11.0M400,0000.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CIENA CORP · COM NEW CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$10.9M28,0850.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)NEXTPOWER INC · CLASS A COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$10.6M87,7060.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)VISTRA CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$10.5M70,1320.4%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)DIGITALOCEAN HLDGS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$10.5M122,6240.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)PG&E CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$10.2M583,1720.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)FIRSTENERGY CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$10.1M200,2930.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)GE AEROSPACE · COM NEW CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.9M34,8890.3%
—SPDR SERIES TRUST · STATE STREET SPD CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
ticker not yet mapped
$9.9M100,0000.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CELESTICA INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.9M35,0420.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)LUMENTUM HLDGS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.8M14,0160.3%
—CI&T INC · COM CL A CUSIP G21307106
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
ticker not yet mapped
$9.8M1,925,6650.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)UNITI GROUP LLC · COM SHS CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.7M1,028,8180.3%
—INVESCO EXCHANGE TRADED FD T · S&P500 EQL WGT CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
ticker not yet mapped
$9.6M49,7780.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)MORGAN STANLEY · COM NEW CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.5M57,7560.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)EVERGY INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.3M114,1000.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)PARAMOUNT SKYDANCE CORP · COM CL B CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.3M1,029,1010.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)STIFEL FINL CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.2M124,9670.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)KINROSS GOLD CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.2M300,5420.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)KEYCORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.2M456,9440.3%
—EVE HLDG INC · COM CUSIP 29970N104
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
ticker not yet mapped
$9.1M3,686,1400.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)AFFILIATED MANAGERS GROUP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.1M33,0000.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)BLACK HILLS CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.1M130,7380.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)WINTRUST FINL CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$9.0M65,0000.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)DELTA AIR LINES INC · COM NEW CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.9M133,8360.3%
—ARCELORMITTAL SA LUXEMBOURG · NY REGISTRY SH CUSIP 03938L203
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
ticker not yet mapped
$8.9M171,1490.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)JPMORGAN CHASE & CO · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.8M30,0200.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)FRANCO NEV CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.8M35,7020.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)WASTE CONNECTIONS INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.8M54,2390.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)COREWEAVE INC · COM CL A CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.7M112,5600.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)CELSIUS HLDGS INC · COM NEW CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.7M245,3770.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)VALLEY NATL BANCORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.6M700,0000.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)VERSANT MEDIA GROUP INC · COM CL A CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.5M230,0000.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)REVVITY INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.5M96,8300.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)SOLSTICE ADVANCED MATLS INC · COM SHS CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.4M110,0000.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)JETBLUE AIRWAYS CORP · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.2M1,850,0000.3%
verified against the SEC company list on 2026-09-10 — a reviewed mapping row for this filed issuer name and class (never inferred)PENN ENTERTAINMENT INC · COM CUSIP —
quarter ended 2026-03-31 filed filed 2026-04-28 +28d
$8.0M534,5140.3%
—VARONIS SYS INC
2 positions · 2 reported rows
Rows BW Gestao de Investimentos Ltda. reported for VARONIS SYS INC, as it reported them
VARONIS SYS INC · COM · CALL CUSIP 922280102 $4.3M200,000
VARONIS SYS INC · COM CUSIP 922280102 $3.7M171,584
ticker not yet mapped
$8.0M371,5840.3%

1–20 of the 100 issuers on this page

Change kind and share change are in Position changes above; Congress overlap is planned.

1–100 of 256 issuers · page 1 of 3
One line per issuer, largest first; a row with no issuer key stands on its own line. Open a line for its rows as this filer reported them. The list holds every row this filer reported for the quarter. Issuer totals on the holders pages count each manager's own report once; that never removes a row here. how positions are grouped ↗

Book shape

2026-03-31 · concentration · vs tracked median · tick = median
Top-25 concentration
48.1%below median 80.0%
Concentration index
226 bpsbelow median 446 bps
Positions with value
270 / 270median book 97.5 positions

Concentration uses reported 13F long value, not total assets. The index is withheld when any position lacks a value. Medians are over the 8,748 tracked filers with a 2026-03-31 book; the index median over the 8,662 with a complete book.

holdings whose <value> did not parse — retained and counted, never zero-filled: 0 · share of the period's disclosed value held in the top-N positions; denominator is reported 13F value, not total assets: 48.1% · integer Herfindahl–Hirschman index in basis points over disclosed position values: 226 · QoQ moves: 340

Filing history

AVAILABLE QUARTERS
Available filing periods
PeriodSource
2026-03-31EDGAR ↗

PLANNED sector rotation · Congress overlap · signals for this filer

Complete source filings on SEC EDGAR

The complete filing on EDGAR.

The position list above is served from the published Public Filings build, each position as this filer reported it; where the page cannot embed every reported row, the list says how many it leaves out. This block is provenance, not a substitute: the filing itself is the record, and it is one click away. Public Filings decided on 2026-08-01 to serve this list from its published build; filings newer than this build are on EDGAR.

Open BW Gestao de Investimentos Ltda.'s 13F filings on SEC EDGAR ↗
Notes on this data

Quarter-end holdings as filed

Explore the full published position list and its source filing. This record excludes the manager’s cash, shorts and non-13(f) assets.

Compare consecutive quarters

Position changes retain the producer’s classification and comparability flags. Share counts and reported values describe different changes.

A snapshot, not current holdings

Use the quarter selector to inspect available periods. Unknown values stay unknown and each table states its coverage.

A 13F is a quarterly, long-only snapshot filed up to 45 days late — not current holdings. what a 13F covers ↗

13F reports cover LONG positions in Section 13(f) securities (US exchange-traded equities plus reportable options, warrants, certain convertibles) held by managers with at least $100M in such securities — so managers below that threshold are absent entirely. No short positions, no cash, no non-13(f) assets — not a full portfolio, and not a census of institutional ownership.

Positions are quarter-end snapshots filed up to 45 days late — not current holdings. A position may have been changed or closed before you ever see it, and is older still by however long ago that quarter ended.

Values are the manager's stated market value at quarter-end in era-dependent units (whole dollars for form versions effective 2023-01-03 onward, thousands before), normalized here to whole dollars with unit_basis carried on every record.

Affiliated managers may report the same position (otherManager), so one position can appear under more than one filer.

Positions under confidential treatment may be omitted until a later amendment discloses them.

These are disclosures, not investment advice (ARCHITECTURE.md §5.2 / M2-CONTRACT §5).