Bloomberg Index Services Limited

Bloomberg Index
Services Limited:
Benchmark Procedures
Handbook
September 2024

Bloomberg Index Services Limited: Benchmark Procedures Handbook

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Table of Contents
1.

Introduction

3

2.

Governance Structure

3

3.

Conflicts of Interest

5

4.

Benchmark and Methodology Changes

6

5.

Cessation Policy

7

6.

User Fall-Back Provisions

8

7.

Restatement Policy

88.

Expert Judgment and Discretion

109.

Market Disruptions Events

10

10.

Complaints

112

1. Introduction
PurposeThis document aims to provide stakeholders with guidance on various general policies and procedures relating to theprovision of benchmarks by Bloomberg Index Services Limited (“BISL”). The provision of individual benchmarks may be
governed by multiple documents (including this document) and should be read in conjunction with each document
referred to in the respective benchmark methodology to fully understand the calculation of the benchmark. Additionally,
individual benchmarks may differ from the approaches detailed in this document; please refer to each benchmark’s
respective methodology for the specific policies and procedures applicable to each benchmark.
Design Principles
BISL aims to broadly meet the following core design principles in its benchmarks. The benchmark ought to be:•

representative of the market or asset class being measured, and desired risk exposures sought by benchmark
users;•

replicable, offering a sufficiently sized universe without unnecessary turnover and transaction costs; and•objective and transparent, with clearly defined and objective rules.

Benchmarks administered by BISL are designed to meet these fundamental criteria, as all benchmarks are designed to
be rules-based with inclusion determined by transparent eligibility criteria that have been set to measure different asset
classes accurately and comprehensively.

2. Governance Structure
Benchmark Regulation
BISL is authorized by the UK’s Financial Conduct Authority to conduct benchmark administration under the UK BMR1.
BISL can be found on the FCA’s register and remains available for use by EU supervised entities during the EU BMR
transition period.
Governance Structure
BISL uses three primary committees to provide overall governance and oversight of its benchmark administration
activities:● The Product, Risk & Operations Committee (“PROC”) is responsible for the first line of control over the creation,
design, production and dissemination of benchmarks administered by BISL.
● The oversight function is provided by Bloomberg’s Benchmark Oversight Committee (“BOC”). The BOC is
independent of the PROC and is responsible for the review and challenge of the BISL Board of Directors and the
PROC regarding relevant aspects of the provision of Benchmarks by BISL, as set out in the UK BMR.
● The Risk Committee (“RiskCo”) advises the Board, the PROC and the BOC on the Company’s overall risk appetite,
tolerance and strategy and oversees the Company’s risk exposure and risk strategy.
BISL also organises Index Advisory Council (“IAC”) meetings for certain families of benchmarks. The IAC meetings afforda cross-section of various market participants the opportunity to offer feedback regarding Bloomberg’s benchmarks
and related services which, in turn, will enable Bloomberg to improve the benchmarks and related services. Each IAC
meeting is for advisory purposes only and has no decision-making power or function. Bloomberg will decide unilaterally
whether, and how, to respond to any feedback, comment, or recommendation that results from an IAC meeting.

Regulation (EU) 2016/1011 of the Parliament and the Council of the European Union on indices used as benchmarks infinancial instruments and financial contracts or to measure the performance of investment funds and associated secondary
legislation ((“EU BMR”), as such regulation forms part of “retained EU law” (as defined in the European Union (Withdrawal)
Act 2018 as amended) (“UK BMR”).

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Benchmark Oversight Committee
The BOC has been established by BISL’s Board of Directors (“Board”) and meets at least quarterly. It is composed of atleast three voting members, including a Chair, who are not directly involved in the provision of any BISL benchmark.
Membership of the BOC is based on a combination of seniority, global outlook, and diverse experience acrossBloomberg L.P’s business and operations. Each member must possess sufficient market knowledge and expertise, beable to commit the necessary time, and not have been subject to sanctions of an administrative or criminal nature
relating to financial services.
BOC members are required to declare any conflicts of interest and will recuse themselves from voting on related
matters, although they may provide advisory input with the approval of the other BOC members.
Members may be removed or replaced with Board approval. Any changes to membership, including replacements andremovals, require Board approval and are documented in the BOC meeting minutes.
The BOC responsibilities include, but are not limited to:•

Reviewing and challenging reports from BISL to ensure that benchmark definitions and methodologies are reviewed
annually, new benchmarks and changes are approved, and third-party services are in line with policies;•

Overseeing the design and operation of the benchmark control framework, including receiving information fromvarious stakeholders, and assessing the results of internal and external audits;•

Overseeing procedures for benchmark changes and terminations, addressing escalated errors or client complaints,
and considering the materiality of identified conflicts of interest, and determining measures to mitigate them; and•Assessing and challenging decisions related to the provision of benchmarks to ensure compliance with UK BMR
requirements and acting in case of suspicious activities or misconduct, including reporting to relevant regulatory
authorities if necessary.

43. Conflicts of Interest
Overview
BISL is a wholly-owned subsidiary of Bloomberg L.P. (collectively with its affiliates, Bloomberg). BISL is an independent
benchmark administrator and neither BISL nor Bloomberg issue, underwrite or act as placing agent or market maker forany securities or financial products and are not involved in investment fund administration. As such, many of the inherent
conflicts of interest that might arise with respect to more traditional financial services providers do not apply.
BISL recognises that potential conflicts of interest may arise in acting as a benchmark administrator. Potential sources ofconflicts may include those between BISL employees, stakeholders, service providers, third parties, Bloomberg andbenchmark users. Such potential conflicts include the following:••••

Employees, stakeholders and directors may have competing outside business interests.
Organisational structure, whereby committee members or direct line managers may have broader roles within
Bloomberg which may conflict with carrying out their role for BISL.
Outsourced service providers who may have a competing interest with the constitution and/or performance ofthe benchmark.
Third parties, including Bloomberg affiliates who provide data, including input data, to BISL benchmarks andmay have competing mandates or strategies.

BISL has robust governance and oversight structures in place (discussed above) and is committed to conducting its
business in accordance with the highest ethical standards, consistent with guidelines that prevent and manage actualor potential conflicts of interest, in order to best serve its clients as well as to comply with applicable regulatory
standards.
BISL has established a conflicts of interest policy and related procedures for the identification, disclosure, management,
mitigation and avoidance of actual or potential conflicts of interest.
In addition, BISL has other policies and procedures in place addressing potential conflicts of interest, including those
on:
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•
•
•
•
•
•
•
•

Information Security;
Confidential Information;
Gifts and Entertainment;
Personal Account Dealing;
Disclosure of Outside Interests;
Anti-Bribery;Anti-Corruption;
Hiring and Remuneration; andWhistleblowing.

Pursuant to these policies, among other things, employees engaged in the provision of benchmarks are also subject toholding periods and pre-approval requirements for securities transactions. In addition, employees may not have theircompensation based on the performance (level) of the benchmarks BISL administers and employees are prohibitedfrom misusing confidential information for their personal gain or improper purposes.
Identifying Conflicts
BISL periodically examines its business practices to identify activities that may cause a conflict of interest. To facilitate
this review, all BISL employees, governance and oversight committee members and members of BISL’s board of
directors disclose outside business activities at least annually.

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Data Providers and Data Extrapolation
Bloomberg benchmarks are rules-based, and their construction is designed to consistently produce benchmark levels
without the exercise of discretion in the day-to-day calculation. Unless otherwise specified in the methodology
document for a particular benchmark, the benchmarks are produced without the interpolation or extrapolation of
input data.
In addition, BISL seeks to avoid contributions of input data that may be subject to the discretion of the source of suchdata and instead seeks to use input data that is readily available and/or distributed for a number of non-index or
benchmark-creation purposes. Accordingly, unless otherwise specified in the methodology document for a particularbenchmark, the benchmarks require no ‘contributors’ to produce and no codes of conduct with any such sources are
required.
Policies and Training
BISL requires mandatory compliance training for all BISL employees including new joiners, oversight committee andboard members on the conflicts of interest policy and other policies and procedures addressing conflicts, as noted
above.
Material Residual Conflicts
Having regard to the governance, controls, and procedures in place to mitigate the potential conflicts of interest
identified, BISL does not consider there to be any residual material conflicts.

4. Benchmark and Methodology Launch & Changes
New methodologies are prepared by the relevant product managers and must be approved by BISL compliance prior
to publication. In certain circumstances, for example, where there is a new data source, outsourcing, input data
contribution, manual processes or other potential risks associated with the benchmark deemed material, the proposed
launch of a benchmark may be escalated to the PROC for approval.
BISL will review the benchmarks (both the rules of construction and data inputs) on a periodic basis, to determine
whether they continue to reasonably measure the intended underlying market interest, the economic reality orotherwise align with their stated objective. Out-of-cycle reviews may result from extreme market events, market
feedback, lack of requisite data and/or material changes to the applicable underlying market interests.
If there is any resulting change to the methodology, BISL will first determine whether a proposed change to abenchmark is material taking into account the following factors:
The economic, financial and/or operational impact of the change;Whether the change affects the original purpose of the Benchmark; and/or

Whether the change is consistent with the overall objective of the Benchmark and the underlying market
interest it seeks to measure.

Additionally, for EU Paris-aligned Benchmarks and EU Climate Transition Benchmarks only, BISL will consider if a
proposed methodology change relates to one of the following elements of the methodology, as in such case themethodology change is likely to be relevant to the objective of climate change mitigation and may be considered amaterial change:•
the criteria applied to exclude assets or companies that are associated with a level of carbon footprint or a levelof fossil fuel reserves that are incompatible with inclusion in the benchmark;•the criteria for the determination of the decarbonisation trajectory; and•the type and source of data used to determine the decarbonisation trajectory for scope 1 carbon emissions, scope
2 carbon emissions, scope 3 carbon emissions, and whether the data uses the Product and Organisation Environmental
Footprint methods or global standards such as the Financial Stability Board’s Taskforce on Climate-related Financial
Disclosures;6

the calculation of the total carbon emissions of the index; or(for EU Paris-aligned Benchmarks only) the formula or calculation that is used to determine whether theemissions are in line with the objectives of the Paris Agreement.

If a proposed methodology change to an EU Paris-aligned Benchmark or an EU Climate Transition Benchmark does not
relate to one of these factors, BISL will assess whether the proposed change is material, either because it is relevant to
the objective of climate change mitigation in another respect or through consideration of the other factors set out above.
Material changes related to the benchmarks together with the key elements of the methodology that would, in BISL’sview, be affected by the proposed material change, will be made available in advance to stakeholders whose input will
be solicited via a consultation. The stakeholder engagement will set forth the rationale for any proposed changes aswell as the timeframe and process for responses. BISL endeavors to provide at least two weeks for the consultation
period, however the length of the consultation period may vary taking into account factors including complexity of the
topic, market circumstances, materiality and client impact.
During the consultation process, in addition to feedback received from stakeholders via the public consultation
process, BISL may solicit feedback from IAC members and/or other relevant stakeholders who may be specifically
impacted by proposed methodology changes. Subject to requests for confidentiality, stakeholder feedback and BISL’s
responses will be made accessible upon request.
Following the end of the consultation, the relevant information is reviewed by BISL, which will make a decision on themethodology change. The decision will be announced to stakeholders at the same time, detailing the changes andtime-frame for implementation. BISL will endeavor to provide at least two weeks for review prior to any materialchange going into effect. In the event of extreme market circumstances, such as a shift in the market or regulatory
structure of the underlying economic reality which requires a change to the methodology to maintainrepresentativeness, this period may be shorter. Methodology changes will be reflected in updated versions of theapplicable methodology document.
Where methodology changes are not deemed material, BISL may make changes to the methodology without a formal
public consultation and will publish revised methodologies to stakeholders at the same time. BISL reserves the right toconsult with stakeholders on all changes whether or not they are deemed by BISL to be material.

5. Cessation Policy
BISL may from time to time terminate a benchmark (“Discontinued Benchmark”) for a number of reasons including, but
not limited to:• Changes in market structure• Lack of requisite data
• Poor quality of data
• The input data no longer represents the market or economic reality it is intended to measure• Insufficient number of constituents eligible for inclusion for a given methodology• Insufficient usage• Superseded by another BISL benchmark• Regulatory or practical concerns• The benchmark no longer meets its stated objective, or• Any other condition which makes the benchmark no longer representative of the market or economic reality it isintended to measure.
The process for terminating a Discontinued Benchmark is as follows:• For a Discontinued Benchmark that has known usage, the PROC will review the proposed termination of the
Discontinued Benchmark, taking into account the reasons for the proposed termination, the impact on
stakeholders (if any), the availability of alternative products and any other factors it considers appropriate in
the circumstances.
•

The PROC at its discretion may decide to consult with stakeholders regarding the proposal to terminate theDiscontinued Benchmark. In deciding whether to consult with stakeholders, the PROC may consider the known
usage of the Discontinued Benchmark and potential impact to stakeholders and/or market. Stakeholder
consultations will also be undertaken when the methodology of the relevant benchmark specifies that a
consultation is required.
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•

If the PROC approves the termination, users of the Discontinued Benchmark will be provided with as muchprior notice of the termination as is reasonable in the circumstances, typically 90 days. If the Discontinued
Benchmarks is widely used or otherwise determined by BISL to be an important benchmark without areasonable substitute, the notice period may be extended, as warranted.

•

The PROC may determine that it is appropriate to provide shorter prior notice or no prior notice of thetermination of the Discontinued Benchmark if circumstances exist that are beyond the control of BISL, including
material changes to the underlying market, lack of access to required data, regulatory change or political events,that materially affects the ability of BISL to administer the Discontinued Benchmark.

•In the event there is no known usage of the Discontinued Benchmark then PROC approval is not required and
BISL may terminate the Discontinued Benchmark without prior notice.
Any advance notice period is subject to BISL being reasonably able to continue administering and calculatingsuch benchmark during such period (for example, BISL has access to requisite data on commercially reasonable
terms, is not subject to any litigation or other claims, has adequate internal resources and capabilities, etc.).

6. User Fall-Back Provisions
Users and other stakeholders who have financial instruments or other products that reference one or more BISL
benchmarks are encouraged to take steps to ensure that:••

contracts or other financial instruments that reference one or more BISL benchmarks, have robust fall-backprovisions in the event of material changes to, or cessation of, the referenced benchmark(s); andusers or stakeholders are aware of the possibility that various factors, including external factors beyond thecontrol of BISL, might necessitate material changes to the referenced benchmark(s).

7. Restatement Policy
BISL considers the following factors (to the extent relevant to the specific benchmark) to determine whether to restate
and the nature of the restatement. Not all conditions need to be present to warrant a restatement, and certain factors
may be more determinative than others depending on the circumstances of given error.
•
•
•
•
•
•
•
•
•

The relative importance of the data field impacted by the error;
Impact to end investor and/or clients’ non-financial objectives;
When the error occurred and when it was discovered;
The number of benchmarks affected;
Whether the impacted benchmarks are linked to tradable products;
The magnitude of the error;
The impact on the replicability of the benchmark;The burden of restatement on client re-processing relative to the impact of the error; andThe impact of the restatement on analytical tools.

A decision to restate any Benchmark results in the restatement of all impacted Benchmarks. Real-time indices are notconsidered for restatement, all real-time dissemination is considered indicative. Discrepancies discovered after 12months will not be corrected unless BISL in its discretion decides that such restatement is necessary.
Fixed Income
For Fixed Income Benchmarks, the general guidelines followed by BISL described above are applied based on thetype of error or issue identified, however BISL will exercise its discretion and reserves the right to restate or not as
each decision will be determined by the individual circumstances.

8Error categories include:•

Incorrect inclusion•

Incorrect exclusion•

Incorrect security attributes•

Incorrect return attribute•

Incorrect analytical calculation

The error type will then be reviewed against the impact to the benchmark, number of benchmarks impacted, thetiming of the error and other factors deemed relevant for the individual circumstances as outlined in the general
guidelines above when determining whether to restate the Benchmark.
EquityAn error to an equity Benchmark in excess of 3 basis point over one day will automatically be reviewed forrestatement. If the Benchmark in error is a Primary benchmark (listed below) and has occurred in the last 2 businessdays, a restatement will be made for all impacted benchmarks. Errors occurring beyond the last 2 business days will
be evaluated on a case-by-case basis.
Real-time indices are not considered for restatement as all real-time dissemination is considered indicative.
Primary benchmarks:● Bloomberg US Large Cap Equity Index (B500T)● Bloomberg Developed Markets Large & Mid Cap Index (DMTR)● Bloomberg Emerging Markets Large & Mid Cap Index (EMTR)
If the error affects a non-Primary benchmark the following factors will be reviewed to determine whether to restate.
Best efforts will be made to address errors in non-Primary benchmarks as outlined in the table below:
Event

Action (If discovered within 2 business days)

Missed corporate action
Spin-off
Regular cash dividend
Special cash dividend

Restate benchmarks and reissue file

Stock split
Stock dividend, bonus
Mergers & acquisition
Delisting
Reclassification

Update made the next business day; no restatement and no reissuance of files

Change in listing
IPO incorrectly added

Update made at next rebalance

Rebalance
Incorrect add
Incorrect removal

Unless the error is discovered during pro-forma period, update will be made atnext rebalance

Share changes

98. Expert Judgment and Discretion
The benchmarks methodologies are rules-based, and their construction is designed to consistently produce values
without the exercise of expert judgment or discretion under the standard methodology, in day-to-day benchmark
calculation. Nevertheless, BISL may use expert judgment or discretion in certain limited circumstances, with regards tothe following:• Extraordinary circumstances (such as a fundamental shift in the economic or regulatory structure of theunderlying market) during a market emergency;• A market disruption event; or•Interruptions, issues and non-availability of data including input or non-input (e.g. ESG) data.
Discretion refers to the right of BISL to make a determination in calculating a Benchmark with respect to its
methodology. Expert judgement refers to the exercise of discretion with respect to the use of Input Data. Instances of
discretion or expert judgement may include BISL making a decision to modify, derive or substitute input or non-input(e.g. ESG) data points according to what it considers suitable in a particular situation, in order to maintain benchmark
constituents as set out in the methodology and ensure that the benchmark continues to represent the market andeconomic reality that it seeks to measure, and the stated objectives of the benchmark.
Discretion may be applied to (but not limited to) areas of benchmark construction or calculation and may include
actions such as:• Delaying or estimating the value of input or non-input data
• Adjusting the benchmark methodology• Excluding or amending a constituent, input or non-input data
• Mapping of non-input data, such as ESG data, to entities and sub-entities of benchmark constituents / issuers•

Maintaining logical Benchmark membership by reviewing constituent characteristics such as country
assignment, float factors, foreign ownership limits, or corporate action applications

When expert judgment or discretion is required, BISL aims to be consistent in its application, with instances of
discretion subject to review by members of BISL. In certain circumstances, exercises of expert judgment or discretion
are reviewed by senior members of BISL management and Bloomberg Compliance teams, and are reported to the
PROC. BISL maintains and enforces policies and procedures to prevent conflicts of interest from inappropriately
influencing benchmark construction, production, and distribution, including the use of expert judgment or discretion.

9. Market Disruptions Events
Market disruption event occurs when there is the occurrence of one or more material events which makes it
impossible or not reasonably practicable for BISL to publish a benchmark level on any benchmark relevant day.
If, on any benchmark relevant day, a market disruption event occurs or is occurring that BISL, in its sole discretion,materially affects the benchmark, BISL may:•

Defer or suspend the calculation and publication of the benchmark and any other information relating to thebenchmark until the next benchmark business day on which such disruption event is not continuing; and/or•

Make such determinations and/or adjustments in relation to (a) the methodology used to calculate thatbenchmark as BISL considers necessary in order to maintain the objectives of the benchmark, or (b) the
benchmark level as BISL considers appropriate in order to preserve the underlying objectives of thebenchmark, including but not limited to calculating a substitute level for the benchmark based on but not
restricted to the last published level of any disrupted benchmark and such level or value may be zero, where,
in the reasonable view of BISL, this would give an objective and accurate determination; and/or•

Discontinue the calculation of the benchmark per the documented cessation procedures1010. Complaints
BISL maintains a written complaints procedures policy, which can be requested on our website by which benchmark
users and other market stakeholders can submit complaints or other feedback including, without limitation,
concerning whether a specific benchmark determination is not representative of the underlying market interest it
seeks to measure, perceived misapplications of benchmark methodologies in relation to a benchmark determinationand other decisions made by BISL in relation to its business and operations.
Complaint Handling Process Summary•

After a complaint is submitted, it will be routed to the appropriate members of the Bloomberg benchmarks
compliance team who will acknowledge the complaint within five business days.

•

Once the complaint is acknowledged it will be reviewed in an impartial, fair and timely manner by complianceand if appropriate, stakeholders within BISL and/or governance committees or other personnel who will
investigate and process the complaint in accordance with BISL internal Complaints Handling Procedures.
Records of any such investigation shall be retained for at least five years or as otherwise required byapplicable law.

•

Depending on the nature of the issue identified in the complaint, the matter will be appropriately escalated to
relevant BISL governance and oversight committees.

•

A written response should be provided to the complainant by the investigating compliance officer once theissue is resolved informing them of the outcome. BISL Compliance may regard a complaint as resolved when a
final response to the complainant has been made and it is reasonable to consider that the complainant will notundertake further action with regards to the Complaint.

•

If a complaint results in a change to a benchmark, such change will be published as soon as possible inaccordance with the terms of the respective benchmark methodology. If warranted, and subject toBloomberg’s internal policies, BISL will report matters to appropriate regulatory authorities and makean appropriate announcement to stakeholders of remedial actions that have been taken to satisfy acomplaint.

More Information
To request a copy of Bloomberg’s complaints policy or to submit a complaint regarding a Bloomberg index or index
determination, please send correspondence to idxcomplaint@bloomberg.net or to the following postal address:
Bloomberg Index Services Limited c/o Bloomberg L.P.,
3 Queen Victoria Street,
London EC4N 4TQ, United Kingdom
Attn: Index Compliance11September 2024

Version Tracker:
Date

UpdateSeptember 2023

Initial publication

January 2024

Update to the Restatement Policy

May 2024

Update to the Cessation Policy

September 2024

Update to the Governance Structure and Benchmark and Methodology Launch & Changes Sections

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Bloomberg Index Services Limited: Benchmark Procedures Handbook

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