March 2024

Refinitiv Benchmark Services (UK) Limited

Statement relating to the IOSCO
Principles for the WMR
Financial Benchmarks

Contents
Principle 1: Overall responsibility of the administrator ........................................................................................................................... 3
Principle 2: Oversight of third parties .................................................................................................................................................... 3
Principle 3: Conflicts of interest for administrators ................................................................................................................................ 3
Principle 4: Control framework for administrators .................................................................................................................................. 4
Principle 5: Internal oversight ................................................................................................................................................................ 4
Principle 6: Benchmark design .............................................................................................................................................................. 4
Principle 7: Data sufficiency .................................................................................................................................................................. 5
Principle 8: Hierarchy of data inputs. ..................................................................................................................................................... 5
Principle 9: Transparency of benchmark determinations....................................................................................................................... 5
Principle 10: Periodic review ................................................................................................................................................................. 5
Principle 11: Content of the methodology.............................................................................................................................................. 6
Principle 12: Changes to the methodology ............................................................................................................................................ 6
Principle 13: Transition .......................................................................................................................................................................... 6
Principle 14: Submitter code of conduct ................................................................................................................................................ 6
Principle 15: Internal controls over data collection ................................................................................................................................ 6
Principle 16: Complaints procedures ..................................................................................................................................................... 6
Principle 17: Audits ............................................................................................................................................................................... 6
Principle 18: Audit trail........................................................................................................................................................................... 7
Principle 19: Cooperation with regulatory authorities ............................................................................................................................ 7

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Refinitiv Benchmark Services (UK) Limited (“RBSL”) is issuing this statement in relation to the IOSCO Principles for Financial
Benchmarks (the “Principles”), which require financial benchmark administrators to certify publicly the extent to which they have
implemented the Principles. The Principles envisage that implementation may be proportionate to the size and risks posed by eachbenchmark, administrator and the relevant benchmark setting process.
RBSL continues to be aligned with the Principles and, in doing so, has taken a proportionate approach where it believes this to bejustified in the circumstances. This document summarises the controls, policies, procedures and governance arrangements thatRBSL has in place, that demonstrate compatibility with the Principles.
Please note that this statement is RBSL’ s own internal assessment of the Principles and not the assessment undertaken by IOSCO
that is referred to in the Financial Stability Board (the “FSB”) Foreign Exchange Benchmarks Consultative Document published on
15 July 2014.

Principle 1: Overall responsibility of the administrator
RBSL is the administrator of the WMR spot, forward and non-deliverable foreign exchange benchmark rates (collectively, the“Benchmarks” and each a “Benchmark”). As the administrator of the Benchmarks, RBSL has primary responsibility for all aspects of
the Benchmark determination process, including the development, determination, and distribution of the Benchmark, ensuring
appropriate transparency and establishing credible and transparent governance, oversight, business continuity, and accountability
procedures. This is stated in RBSL’s publicly available methodology document (the “Methodology”), which is available on its website
at WMR FX Benchmarks | LSEG RBSL has established a Benchmark Oversight Committee (the “Oversight Committee”) to perform
oversight over the Benchmarks and RBSL in its role as Benchmark administrator. Please see Principle 5 below for further
information on the Oversight Committee.
RBSL has internal controls in place that are designed to provide for timely distribution of the Benchmarks. As specified in the
Methodology, RBSL aims to publish each Benchmark within 15 minutes of the fix time for that Benchmark.

Principle 2: Oversight of third parties
RBSL outsources most services involved in the provision of the benchmark family to entities within the wider London Stock
Exchange Group (LSEG). However, input data, including trade, order, and quote data, is provided by certain third-party platform
operators (specifically, EBS, and, in certain limited circumstances, Currenex, Inc. (“Currenex”)) pursuant to licensing agreements.
RBSL has written agreements setting out the roles and obligations of each platform operator. RBSL also monitors compliance withthese agreements and conducts due diligence on each of its platform operators.
RBSL maintains an Outsourcing Framework to manage services outsourced to LSEG entities, which includes Outsourcing
Framework Procedures document, Service Level Agreements, and Outsourcing Inventory. All activities are managed through SLA
together with specified KPIs. Performance against these KPIs is monitored with regular reporting to relevant governance forums,
including the RBSL Board where required.

Principle 3: Conflicts of interest for administrators
RBSL is subject to the Group Conflicts of Interest Policy, but has also implemented its own Conflicts of Interest Procedure document
which sets out how RBSL identifies, discloses, manages, mitigates and avoids actual or potential conflicts of interest. This procedure
is tailored to RBSL’s role as administrator of the Benchmarks. RBSL has also prepared a Conflicts of Interest Disclosure Document.
That document describes actual or potential conflicts of interest that may arise in connection with the offering of the Benchmarks.

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3Principle 4: Control framework for administrators
RBSL has a control framework, which includes:a. An Oversight Committee with responsibility for oversight of the Benchmarks and RBSL’s role as administrator of the
Benchmarks. Please see Principle 5 for more information;b. The Methodology, which sets out, amongst other things, the parameters for any exercise of judgement by LSEG employees;c. A Conflicts of Interest Procedure, which sets out RBSL’s processes for identifying, managing, mitigating and avoiding conflictsof interest;
d. An Outsourcing Framework which ensures all third party service providers to be subject to due diligence and ongoing service
quality monitoring. The due diligence includes assessment across multiple risk domains, such as cyber, BCP, financial
sanctions, data quality, and control environment. The due diligence is completed prior to onboarded and repeated on a periodic
basis.
e. A Price Challenge and Complaints Handling Policy, which sets out RBSL’s processes for handling price challenges andcomplaints;f.

An Operational Risk Framework, which sets out how operational risks are identified, managed and monitored;g. A Controls Matrix which lists the material controls performed for each Benchmark;h. A Standard of Conduct, which contains minimum standards that apply to all RBSL entities, including in relation to conflictsof interest;i.

A whistle blowing register but is also subject to the Group Speak-Up Policy;j.

A training programme for employees, including training to ensure that employees have sufficient Benchmark Regulation
knowledge and expertise. There is also various corporate training requirements covering topics such as Cyber Security, AML,
Ethics and BCP; andk. Regular reviews by LSEG Internal Audit function and Independent Third-Party Auditors, including on-site audits.
RBSL does not provide contribution input data, and as such there are no Submitters for WMR. It has not implemented the measures
set out in Principle 4 that relate to Submitters.

Principle 5: Internal oversightRBSL has established an Oversight Committee. The Oversight Committee Terms of Reference, which lists the responsibilities of theOversight Committee and its current members, is available here: WMR FX Benchmarks | LSEG The Oversight Committee
comprises members selected on the basis of their experience, knowledge and independence from the day-to-day management of
the Benchmarks. The Oversight Committee Terms of Reference permits the Oversight Committee to appoint internal or external
technical advisers as appropriate.
Members of the Oversight Committee are appointed by RBSL. As the Benchmark does not have Submitters, the OversightCommittee’s role does not encompass the Submitter specific provisions of Principle 5.

Principle 6: Benchmark design
The Methodology describes the key features of the Benchmark design, including how it seeks to achieve an accurate and reliable
representation of the interest it seeks to measure and eliminate factors that might result in a distortion of the price, rate, index orvalue of the Benchmark.
On the basis of publicly available volume data produced by the LSEG FX Matching System and EBS, RBSL has determined that the
LSEG FX Matching System and EBS are currently the trading platforms with sufficient liquidity for the currencies for which RBSL
uses their data. To determine whether this remains the case, RBSL internal currency review group conducts regular (as a minimum,
annual) reviews of the data sources.
RBSL also conducts a due diligence process with each of its third-party data providers, which includes periodic supplier review
meetings to discuss their controls, processes and procedures to address any potential unethical trading behaviour.

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4Principle 7: Data sufficiency
The trade currency Benchmarks are calculated primarily by reference to trades executed by parties on an arm’s length basis.
RBSL’s validation process requires a minimum number of observable transactions to be captured before they may be used as datain the calculation of the Benchmarks. RBSL also captures order information for use in the event that insufficient observabletransactions are captured. RBSL does not rely on a solicitation process and the parties using the platforms do not provide the data
to RBSL specifically for the purpose of influencing the benchmark determination. Instead, they use these platforms in their ordinary
course of business. For non-trade currencies, RBSL sources indicative quote rates. Please refer to the Methodology for more
information on how the Benchmark is calculated for both trade currencies and non-trade currencies.
As stated in the Methodology, RBSL recognises that to enable the publication of a meaningful Benchmark, a market in eachcurrency pair represented by that Benchmark must genuinely exist and that market must be active.
However, the economic realities of each applicable currency market will dictate the relative meaning of what “active” means asmarket liquidity varies greatly from a major liquid (e.g. trade) currency to an extremely illiquid (e.g. quote) exotic currency and may
also vary depending on the time of day. Accordingly, RBSL, in certain limited circumstances, defines an active market as one with asingle source, although this situation is generally limited to quote currencies. As stated in the Methodology, RBSL can provide a listof these currencies to its subscribers on request.

Principle 8: Hierarchy of data inputs.
The Methodology describes the order of hierarchy that is applied for alternative data sources and the parameters for the exercise of
any judgement by LSEG personnel.
Please refer to sections 2.3, 2.4, 3.3, 3.4, 4.3 and 4.4 of the Methodology for more information.

Principle 9: Transparency of benchmark determinations
As RBSL currently offers 157 spot fix Benchmarks which it sets either half hourly (trade currency Benchmarks) or hourly (non-tradecurrency Benchmarks) between the hours of 6am Hong Kong time on Monday to 10pm UK time on Friday, it is not operationallypossible for RBSL to publish a description of the Benchmark calculation with each Benchmark. Instead, WMR Methodology
provides, in RBSL’s view, sufficient information on active markets, economic realities, data types and the parameters for any
judgement-based decisions to be made by LSEG employees, to facilitate an understanding of how the Benchmarks are determined.
In addition, if it is necessary for RBSL to use “quote” data instead of trade rates for the trade currencies, RBSL, as standard practice,communicates this to clients via email to inform them. The fact that RBSL may be required to use quote rates in the absence oftrade rates is also highlighted upfront in the Methodology. RBSL will respond to any questions that its subscribers raise on aparticular Benchmark.

Principle 10: Periodic review
RBSL has procedures in place to review, at least annually, the applicable market factors (including market conditions and structuralchanges) relating to each Benchmark to ascertain whether it would be appropriate to make any changes to the Methodology.
These reviews include consideration of whether certain underlying conditions in the formulation of the Benchmark remain
appropriate and, in certain circumstances, may lead to the cessation of a particular Benchmark. RBSL has implemented a
Benchmark Methodology Change and Cessation Policy which sets out the circumstances in which any such cessation may arise
and its applicable processes. A copy is available here: Benchmark Regulation | LSEG.

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5Principle 11: Content of the methodology
WMR Methodology is publicly available on FTSE website at WMR FX Benchmarks | LSEG RBSL conducts periodic reviews of its
Methodology and in accordance with the Principles, focuses on providing transparency for its Benchmark subscribers. Accordingly,
RBSL’s view is that the Methodology document published on its website contains sufficient detail to allow subscribers to understandhow the Benchmarks are derived and to assess their representativeness, its relevance to stakeholders and its appropriateness as areference.
As RBSL does not have any Submitters, its Methodology does not include criteria for including and excluding Submitters.

Principle 12: Changes to the methodology
RBSL has a formal process for making changes to its Methodology. Any potential changes are reviewed by the OversightCommittee and the Benchmark Product Committee and are subject to approval by the Benchmark Governance Committee. If the
proposed change is material, there is a recommendation to the Board, with final approval vesting in the Board. If any changes areproposed that may have a material impact on subscribers, they are communicated to subsbcribers, together with the underlying
rationalise, in advance.. .
If, following a review by the Oversight Committee and Benchmark Product Committee and approval by the Benchmark GovernanceCommittee and RBSL Board, a material change is made to the Methodology; RBSL would publish the new Methodology document
to its website at WMR FX Benchmarks | LSEG. In these circumstances, RBSL endeavours to consult with stakeholders and toprovide them with advance notice of any proposed changes as set out in its Benchmark Methodology Change and Cessation Policy.

Principle 13: Transition
RBSL has implemented a Benchmark Methodology Change and Cessation Policy, which is available here: Benchmark Regulation |LSEG .
RBSL highlights to its subscribers and users in the Methodology that they should plan for possible changes to the Benchmarks or
the cessation of a particular Benchmark and that they should ensure that any financial contracts, financial instruments or funds thatreference a Benchmark contain robust written fallback plans and other contingency provisions in the event of material changes to or
cessation of that Benchmark.

Principle 14: Submitter code of conduct
This Principle does not apply to RBSL as RBSL does not have any Submitters.

Principle 15: Internal controls over data collection
As stated above, RBSL sources trade, order and quote data from certain third-party platform operators. RBSL has licensing
agreements in place with each platform operator and conducts due diligence on each platform operator as aligned with the
Outsourcing Framework..
RBSL has technology based internal controls over its data collection, validation and transmission processes. RBSL has
implemented access controls to limit access to the LSEG applications and captured data to LSEG authorised personnel. To help
ensure data integrity, RBSL sources corroborating trade and order data from multiple platform operators in respect of certain tradecurrency pairs.

Principle 16: Complaints procedures
RBSL has implemented and published a Price Challenge and Complaints Handling Policy, which sets out its procedures for handling
price challenges and complaints. A copy of the policy is available here: Benchmark Regulation | LSEG.

Principle 17: Audits

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RBSL, including WMR, is subject to both internal and external audits on a regular basis, including for certain benchmarks andindices specific IOSCO reviews and where required UK BMR regulatory audits.
Subsequent reports are distributed to relevant governance forums, including the RBSL Board, for noting and remediation actions to
any findings are tracked to completion and monitored by Compliance and Risk.

Principle 18: Audit trail
RBSL retains and records all relevant data associated with the calculation of the Benchmarks, including input data collected fromplatform operators; methodologies and models, exercise of expert judgement; deviations from standard procedures; identity of each
person involved in the determination and any queries and responses to data input or published Benchmarks. RBSL maintains a
Record Keeping policy, aligned with the LSEG Record Keeping policy, and retains such records for at least 5 years.

Principle 19: Cooperation with regulatory authorities
RBSL deals with its regulators in an open and cooperative way and discloses to them appropriately anything relating to RBSL of which
they would reasonably expect notice of. In addition, RBSL remains committed to working with relevant regulators as appropriate andhas worked extensively on Global Benchmark Reform, Regulation, and Industry Best Practice, including the IOSCO Principles.
Should you have any questions on this statement, please address them to wmr.sales@lseg.com.

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ABOUT FTSE RUSSELL
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