August 2024

Benchmark Methodology Change andCessation Policy
Refinitiv Benchmark Services (UK) Limited

Version: 5.0
Issue Date: 20 August 2024

RBSL Benchmark Methodology Internal Review Policy

Contents
1

Introduction ............................................................................................................................................................................. 3

2

Benchmark Methodology Change Policy ................................................................................................................................ 4

3

Benchmark Cessation Policy .................................................................................................................................................. 6

4

Record Keeping .................................................................................................................................................................... 10

5

Document Review Cycle ....................................................................................................................................................... 10

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RBSL Benchmark Methodology Internal Review Policy

1 Introduction
1.1

Regulatory Environment

London Stock Exchange Group (“LSEG”) is a leading global financial markets infrastructure and data provider, trusted to deliver
excellence by customers, partners and markets around the world. We play a vital social and economic role in the world’s financial
system. With our trusted expertise and global scale, we enable the sustainable growth and stability of our customers and theircommunities.
LSEG offers benchmark and index solutions through FTSE Russell. FTSE Russell is a global index provider of benchmarks,
analytics and data with capabilities across asset classes. FTSE Russell’s indices are used by clients to inform asset allocation
decisions, support portfolio construction and conduct risk and performance analysis. FTSE Russell has two authorised benchmark
administrators:-

1.2

Refinitiv Benchmark Services (UK) Limited (“RBSL”) is authorised in the UK by the FCA under the UK Benchmark
Regulation (“UK BMR”) and in accordance with the relevant obligations of the International Organisation of
Securities Commissions (“IOSCO”) Principles for Financial Benchmarks.
FTSE International Limited (“FIL”) is authorised in the UK by the FCA under the UK BMR and in accordance withthe relevant obligations of the International Organisation of Securities Commissions (“IOSCO”) Principles for
Financial Benchmarks.
Document Scope

This document is, unless specifically provided otherwise, applicable to all benchmark families that are categorised as Critical,
Significant or Non-significant per the thresholds designated in the BMR, as well as specific Benchmark classes such as Regulateddata, Interest Rate and Commodity Benchmarks.
1.3

Purpose of Document

This document contains the RBSL Benchmark Methodology Change and Benchmark Cessation Procedures.
These procedures are published in accordance with Article 28(1) of the BMR, which requires an administrator to “publish, together
with the Benchmark statement referred to in Article 27, a procedure concerning the actions to be taken by the administrator in theevent of changes to or the cessation of a Benchmark which may be used in the United Kingdom in accordance with Article 29(1).
The procedure may be drafted, where applicable, for families of Benchmarks and shall be updated and published whenever amaterial change occurs”.
1.4

Notice to Supervised Entities

Supervised Entities that use Benchmarks are required, as per Article 28(2) of the BMR, to “produce and maintain robust written
plans setting out the actions that they would take in the event that a Benchmark materially changes or ceases to be provided. Where
feasible and appropriate, such plans shall nominate one or several alternative Benchmarks that could be referenced to substitute theBenchmarks no longer provided, indicating why such Benchmarks would be suitable alternatives. The supervised entities shall, uponrequest, provide the relevant competent authority with those plans and any updates and shall reflect them in the contractual
relationship with clients.”.

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RBSL Benchmark Methodology Change and Cessation Policy

2 Benchmark Methodology Change Policy
2.1

Introduction

Each RBSL Benchmark shall be subject to an internal review on at least an annual basis.
The relevant Product Manager is responsible for reviewing the methodologies and implementing the internal review process.

2.2

Trigger for Change Procedures

These change procedures can be triggered for a Benchmark Methodology from a range of sources, including but not limited to:

2.3

a)

a periodic review of a Benchmark Methodology as described in the RBSL Benchmark Internal Review Policy;b)on the recommendation of RBSL or the relevant Benchmark Oversight Committee;c)on the recommendation of management within Refinitiv’s Content Operations division, Benchmarks and Indices divisionor the Compliance department;d)issues raised by stakeholders including Users of a Benchmark;e)relevant regulatory or industry developments; orf)back testing result update.

Analysis and Materiality

Analysis: Once the Change Procedures are initiated for a Benchmark Methodology, RBSL will conduct an analysis of the impact ofthe proposed change on the Benchmark and will determine whether the proposed change:a)b)

is beneficial to the quality and representativeness of the Benchmark with respect to the underlying market or reality thatit represents; andconstitutes a material or non-material change to the Benchmark Methodology. In making such determinations, RBSL willseek the advice and feedback of the relevant Benchmark Oversight Committee.

Determine the materiality: In determining the materiality of the proposed change, RBSL will have regard to:a) any fundamental change to the process by which the Benchmark is determined;b) any change to the underlying market or reality represented by the Benchmark or any significant change to howthat underlying market or reality is represented;c) where applicable, whether any change to the panel of Contributors would adversely and materially affect the
representativeness of the input data used in the Benchmark determination; andd) whether the change would significantly alter a Benchmark value after the usual rounding is applied to that
Benchmark.
In order to assess potential materiality, RBSL may seek informal views from Benchmark Users.
For the avoidance of doubt, changes to document formatting shall not constitute a material change to a Benchmark Methodology.
If RBSL determines that the change is beneficial to the quality and representativeness of the Benchmark with respect to theunderlying market or reality that it represents but does not constitute a material change to the Benchmark Methodology, RBSL shallamend and publish the Benchmark Methodology.
If RBSL determines that the change is beneficial to the quality and representativeness of the Benchmark with respect to theunderlying market or reality that it represents and does constitute a material change to the Benchmark Methodology, RBSL shallfollow its Consultation Process described below.

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RBSL Benchmark Methodology Change and Cessation Policy

2.4

Stakeholder Consultation

For a proposed change to a Benchmark Methodology that constitutes a material change defined in 2.3, RBSL shall issue a
consultation document with the purpose of soliciting comments and feedback. The consultation document shall include the proposedchange to the Methodology, the rationale for proposing the change, the reason the proposed change is material, any regulatory or
legal implications of the proposed changes, and an impact assessment of the proposal. The consultation document shall include
RBSL’s assessment as to whether the representativeness of the Benchmark and its appropriateness for its intended use are
impacted by the proposed change.
Consultation papers are reviewed and agreed by the relevant Benchmark Oversight Committee and approved by RBSL before
publication.
The consultation document shall be issued to stakeholders including known Users of Benchmark, Contributors to the Benchmark if
applicable, Redistributors of the Benchmark, and Market Advisory Committee Members if applicable. The consultation document
shall also be published on the Refinitiv website and will be made available on request to any third party.
The consultation document shall specify a period for the consultation which will be set in accordance with the circumstances andurgency surrounding the proposed change, but will typically be two weeks. Comments received and RBSL’s response to thosecomments will be accessible after any consultation, except where confidentiality has been requested by the originator of thecomments.
2.5

Implementation

Following the end of a consultation, RBSL will give due consideration to any feedback received. RBSL will publish an outcome of theconsultation and may include anonymised comments frequently received and RBSL's response to such feedback if appropriate.
Following receipt of feedback, RBSL will determine whether to proceed with the change whilst also considering the advice of therelevant Benchmark Oversight Committee in making such determination. All material changes to a benchmark methodology are
subject to final approval by RBSL.
If the determination is to proceed with the proposed change, RBSL will announce that determination and set out the applicableeffective dates for the confirmed change. The notice period shall depend on the nature of the Benchmark and the confirmed change.
If the determination is not to proceed, RBSL will announce that determination.
The amended Benchmark Methodology and, if applicable, Benchmark Statement documents will be issued following announcementof a confirmed change.
2.6

Force Majeure

Exceptional events may necessitate an immediate change to a Benchmark Methodology. In such exceptional circumstances, RBSL
may elect not to follow this Procedure, but will provide as much notice as is practicable.
Following such a change RBSL will conduct an internal review of the Methodology in accordance with the RBSL Benchmark Internal
Review Procedures.

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RBSL Benchmark Methodology Change and Cessation Policy

3 Benchmark Cessation Policy
3.1

Introduction

This document addresses only those cases where RBSL is the Administrator of a Benchmark, as per Article 3(6) of the BMR and by
the IOSCO Principles for Financial Benchmarks. In these cases RBSL will carry out the Administration of Benchmarks in a mannerthat is aligned with the IOSCO Principles for Financial Benchmarks, consistent with any applicable regulation such as the BMR, andin the best interests of the markets each Benchmark serves.
3.2

Potential reasons for the Cessation of a Benchmark

3.2.1

In certain circumstances, it may be necessary for RBSL to cease the provision of a particular Benchmark rate. This may be
due to external factors beyond the control of RBSL, including a market structure change or deterioration in input data
sufficiency for a particular currency, tenor, or instrument. Where further explanation for individual Benchmarks is required
regarding cessation policy, these are detailed within the Appendix Section of this Policy.

3.2.2

RBSL keeps under review:a) the structure and liquidity of the market underlying each Benchmark;b) the representativeness of the input data used to determine each Benchmark, whether this is an automated feed ofdata, submissions from a panel, or other mechanism or combination of mechanisms;c) the products each Benchmark seeks to facilitate or underpin; andd) to the extent feasible, the User base for each Benchmark and the use cases for each Benchmark.

3.2.3

In its review of the above and potentially other factors it may be that RBSL takes the view that the Benchmark is no longer
representative of its intended interest or market, and that this cannot be remedied by a corrective change to the Benchmark
methodology, design, or other aspect of the processes and procedures around the creation and usage of the Benchmark.
All proposed cessations are subject to final approval by RBSL.

3.2.4

In the above case, RBSL will follow the Benchmark Cessation Procedures laid out below. In extreme circumstances RBSL
believes are beyond its control, it may be necessary to follow the Emergency Benchmark Cessation Procedures laid out
below.

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RBSL Benchmark Methodology Change and Cessation Policy

3.3

Benchmark Cessation Procedures

3.3.1

On becoming aware that due to the circumstances listed above or other circumstances that it may be necessary to cease
calculation and distribution of a Benchmark, RBSL will carry out a detailed analysis of the estimated breadth and depth ofusage, including financial contracts, financial instruments, and funds that reference the Benchmark and the economic andfinancial stability impact that might result from the cessation of the Benchmark, to ensure that the response is
proportionate.

3.3.2

RBSL will consider the selection of a credible, alternative Benchmark such as, but not limited to, criteria that seek to match
to the extent practicable the existing Benchmark’s characteristics (e.g. credit quality).

3.3.3

RBSL will consider the practicality of maintaining parallel Benchmarks (where feasible) in order to accommodate an orderlytransition to a new Benchmark.

3.3.4

RBSL will hold an extraordinary Benchmark Oversight Committee meeting to seek advice and a recommendation withregard to the possible cessation the Benchmark.

3.3.5

RBSL will carry out a public consultation to take into account the views of stakeholders and any relevant regulatory bodies
in determining what specific procedures are appropriate and the impact of ceasing a particular Benchmark. Consultation
papers are reviewed and agreed by the relevant Benchmark Oversight Committee and approved by the RBSL before
publication.

3.3.6

In all cases, RBSL will take all reasonable steps to ensure that all Users and other stakeholders are made aware as soon
as possible of any intention or possible necessity to cease a Benchmark.

3.3.7

Such communications will be designed to give Users and stakeholders as much warning as possible of an intention tocease calculation and will be published on RBSL’s website as well as all the usual alert pages maintained on RBSL’s
products.

3.3.8

Following the consultation, RBSL may publish a summary of comments received, and a decision on whether to cease or
not in a Cessation Notice. All cessations are subject to final approval by the RBSL.

3.3.9

If the decision is to cease, RBSL will include an indicative calendar in the Cessation Notice. The calendar may include aperiod of suspension, following which any further comments received will be considered before the final cessation of the
Benchmark.

3.3.10

Typically, Users will be given a six-month notice period prior to the cessation of a benchmark. The exact length of thenotice period would take into consideration relevant factors, including but not limited to:a) the urgency of ceasing the benchmark;b) the length of time Users need to adequately prepare;c) technology issues; andd) legal and / or regulatory provisions

3.3.11

Where possible and appropriate, RBSL will publish along with the Cessation Notice guidance for Users and otherstakeholders on potential alternative or replacement Benchmarks.

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RBSL Benchmark Methodology Change and Cessation Policy

3.4

Additional Benchmark Cessation Procedures for Critical Benchmarks

3.4.1

The following procedures will be performed if the Benchmark being ceased is a Critical Benchmark as defined by theconditions included in Article 20(1) of BMR.

3.4.2

If RBSL intends to cease providing a critical Benchmark, RBSL shall:a) immediately notify its competent authority in writing; andb) within four weeks of such notification submit an assessment of how the Benchmark:i.

is to be transitioned to a new administrator; orii.

is to be ceased to be provided, taking into account the procedure established in Article 28(1).

3.4.3

During the period referred to in point (b), RBSL shall not cease provision of the Benchmark.

3.4.4

Upon receipt of the assessment of RBSL referred to in paragraph 3.4.2, the competent authority shall:a)inform other relevant regulatory bodies and, where applicable, the college established under Article 46; andb)within four weeks, make its own assessment of how the Benchmark is to be transitioned to a new administrator or beceased to be provided, taking into account the procedure established in accordance with Article 28(1).

3.4.5

During the period of time referred to in point (b) of 3.4.2 RBSL shall not cease the provision of the Benchmark without thewritten consent of the competent authority.

3.4.6

Following completion of the assessment referred to in point (b) of 3.4.2, the competent authority shall have the power tocompel RBSL to continue publishing the Benchmark until such time as:a)the provision of the Benchmark has been transitioned to a new administrator;b)

the Benchmark can be ceased to be provided in an orderly fashion; orc)the Benchmark is no longer critical.

3.4.7

For the purposes of 3.4.6, the period for which the competent authority may compel RBSL to continue to publish the
Benchmark shall not exceed 12 months.

3.4.8

By the end of that period, the competent authority shall review its decision to compel RBSL to continue to publish the
Benchmark and may, where necessary, extend the time period by an appropriate period not exceeding a further 12 months.
The maximum period of mandatory administration shall not exceed 24 months in total.

3.4.9

Without prejudice to 3.4.2, in the event that RBSL as the administrator of a critical Benchmark is to be wound down due toinsolvency proceedings, the competent authority shall make an assessment of whether and how the critical Benchmark canbe transitioned to a new administrator or can cease to be provided in an orderly fashion, taking into account the procedure
established in accordance with Article 28(1).

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RBSL Benchmark Methodology Change and Cessation Policy

3.5

Emergency Benchmark Cessation Procedures

It is possible in extremis that circumstances beyond RBSL’s control arise which mean that it is necessary to cease a Benchmark withlittle notice. This may include a sudden change in circumstances or markets that result in it being impossible to collect sufficient data
to produce a viable Benchmark, and impossible to source alternative or back up inputs.
Under these extreme circumstances, RBSL will ensure that all relevant information including back-up plans and, and where possible
and appropriate, information on alternative Benchmarks is published for Users and stake as rapidly as possible, and updates are
given as circumstances evolve.
3.6

Cessation of WM/Refinitiv FX Rates Policy

LSEG through its wholly owned subsidiary Refinitiv Benchmark Services Limited (“RBSL”) provides the WM/R FX Benchmarks; aglobal foreign exchange rate Benchmark service, offering spot, forward, and non-deliverable forward foreign exchange Benchmark
rates (each a “WM/R Benchmark Rate” and together the “WM/R Benchmark Rates”) at fixed points throughout the global tradingday.
In certain circumstances, it may be necessary for RBSL to cease to offer a particular WM/R Benchmark Rate. This may be due toexternal factors beyond the control of RBSL such as a market structure change or deterioration in data sufficiency for a particularcurrency. This policy sets out the process that RBSL follows in relation to any cessation of a WM/R Benchmark Rate.
What process will RBSL follow in relation to a potential cessation of a WM/R Benchmark Rate?
When RBSL identifies a possible cessation event, RBSL will:a)review the circumstances and consider whether RBSL believe that there is a viable alternative to ceasing a particular WM/R
Benchmark Rate;b)where practicable undertake a consultation with key stakeholders and consider any feedback that RBSL feels may identify aviable solution;c)where practicable provide notice to key stakeholders of any cessation of a particular WM/R Benchmark Rate; andd)publish a zero rate while RBSL considers whether to cease a WM/R Benchmark Rate in relation to a particular currency ortenor. In these circumstances RBSL will continue to review the market and availability of data periodically to determine in our
discretion whether to cease to publish a WM/R Benchmark Rate or whether to reinstate that WM/R Benchmark Rate.

Who has approval authority for any cessation of a WM/R Benchmark Rate?
3.6.1 RBSL may need to cease a particular WM/R Benchmark Rate urgently in order to protect the integrity and accuracy of RBSL.
In these circumstances, the decision as to whether to cease a particular WM/R Benchmark Rate shall be made by RBSL andreviewed pre implementation by the Benchmark Oversight Committee and before any consultation materials are published to
stakeholders.
a)Where practicable given time constraints, any potential cessation shall be reviewed and approved by the Benchmark
Oversight Committee prior to implementation.

Alternative Benchmark Ratesa)

In the event of any cessation of a particular WM/R Benchmark Rate, RBSL will attempt to assist our clients in identifying analternative Benchmark rate. However, RBSL recommends that all contracts and other financial instruments that reference a
WM/R Benchmark Rate have robust contingency provisions in the event of material changes to, or cessation of, thereferenced WM/R Benchmark Rate.

b)

Where practicable, upon client request, RBSL will consider the provision of a parallel Benchmark rate to accommodate anorderly transition.

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4 Record Keeping
4.1

Record Keeping Requirements

RBSL must maintain relevant records in accordance with the FTSE Russell Record Retention Policy. Closed public consultations will
be retained on the relevant website or be available upon request.
Product Managers are responsible for keeping a ‘Methodology Review & Change Log’ to note the relevant information for how thechange is reviewed and approved:a)Analysis of the impact (relevant document to be retained where needed);b)

Materiality of the change;c)Consultation document, consultation period, and feedback (relevant document to be retained where needed);d)Determination of whether to proceed with evidence of approval; ande)Updated Methodology with effective date.

RBSL must maintain relevant records when it intends to cease a Benchmark in accordance with the FTSE Russell Record Retention
Policy. Records regarding the cessation such as, rationale, relevant discussions and meeting minutes, key communication points
with regulator, and other key records shall be retained.

5 Document Review Cycle
5.1

Document Review Frequency

This document must be reviewed on at least an annual basis to ensure it remains appropriate and consistent with regulatory
requirements, industry standards, and business changes.

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ABOUT FTSE RUSSELL
FTSE Russell is a leading global provider of index and benchmark solutions, spanning diverse asset classes and investment objectives. As a trusted
investment partner we help investors make better-informed investment decisions, manage risk, and seize opportunities.
Market participants look to us for our expertise in developing and managing global index solutions across asset classes. Asset owners, asset
managers, ETF providers and investment banks choose FTSE Russell solutions to benchmark their investment performance and create investment
funds, ETFs, structured products, and index-based derivatives. Our clients use our solutions for asset allocation, investment strategy analysis andrisk management, and value us for our robust governance process and operational integrity.
For over 35 years we have been at the forefront of driving change for the investor, always innovating to shape the next generation of benchmarks
and investment solutions that open up new opportunities for the global investment community.
CONTACT US
To learn more, visit lseg.com/ftse-russell; email info@ftserussell.com; or call your regional Client Service team office:
EMEA +44 (0) 20 7866 1810

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