EMEA-APAC Complaints Procedure
CME GROUP
PROCEDURE
DOCUMENT NO:

PROCEDURE
DOCUMENT
ISSUED BY:

CONTACT INFORMATION:

N/AInternational
ComplianceInternationalCompliance@cmegroup.com

DATE PROCEDURE
DOCUMENT
ORIGINALLY ISSUED:DATE PROCEDURE
DOCUMENT LASTREVISED:

August 2020

September 2023

Purpose and scope
The purpose of this Procedure is to set out details on the management of customer complaints to ensure that they are handed
fairly and effectively, in a prompt and transparent manner and in accordance with applicable regulatory requirements (including,but not limited to, Article 26 of the MiFID organisational requirements Delegated Regulation1 and Article 9 of the UK Benchmarks
Regulation2 applicable to CME Group Benchmark Administration Limited as a benchmark administrator). In accordance with thoserequirements, this Procedure shall be published on the CME Group website.
Great importance is placed on customer interests and this Procedure provides an opportunity to investigate, address and improve
services for customers.
This Procedure applies to the following regulated CME Group entities in the EMEA and APAC regions (hereafter “Regulated Entities”):• BrokerTec Europe Limited (UK)• NEX SEF Limited (UK)
• CME Group Benchmark Administration Limited (UK)
• CME Amsterdam B.V. (Netherlands)

1

 OMMISSION DELEGATED REGULATION (EU) 2017/565 of 25 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the CouncilC
as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive and the UK onshoredversion of the same as amended and transposed into the laws of the United Kingdom pursuant to the European Union (Withdrawal) Act 2018 and the EuropeanUnion (Withdrawal Agreement) Act 2020.

2

 EGULATION (EU) 2016/1011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 June 2016 on indices used as benchmarks in financial instruments
Rand financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No
596/2014, as amended and transposed into the laws of the United Kingdom pursuant to the European Union (Withdrawal) Act 2018, the Benchmarks (Amendmentand Transitional Provision) (EU Exit) Regulations 2019 and the European Union (Withdrawal Agreement) Act 2020.

1EMEA-APAC Complaints Procedure | © 2023 CME Group. All rights reserved.

Complaints management
The Compliance function is responsible for maintaining the complaints management process on behalf of the Regulated Entities.
In accordance with this, the Compliance function has established and implemented a transparent complaints management
procedure for the prompt and effective handling of complaints.
Communications with customers about complaints shall be made in a clear manner, in plain language that is easy to understand,and shall ensure the complaint is replied to without undue delay.

Definition of a complaint
A complaint is defined as:
Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, orfailure to provide, a financial service or a redress determination which alleges that the complainant has suffered (or may suffer)
financial loss or material inconvenience.
For a matter to be treated as a complaint, the dissatisfaction should relate to a specific aspect of the service being provided which
would not include:•	A desire from the customer to see additional or supplementary features (e.g. service developments that are outside thescope of the existing agreement for services);•	Circumstances that are entirely out of the control of the Regulated Entities (e.g. relating to the acts (or failures to act) of one
or more customers using the service in question);• Challenges on the basis of existing and agreed fee structures;•	Dissatisfaction with general policies or with the exercise of discretion where no unprofessional or other misconduct, mistake,lack of care, unreasonable delay, bias or lack of integrity is alleged; or• Claims where the complainant is clearly not acting in good faith.
As it relates to CME Group Benchmark Administration Limited, these procedures cover all eligible complaints including, but notlimited to:i) whether a specific benchmark determination is representative of market value;ii) a proposed change to the benchmark determination process;iii) an application of the methodology in relation to a specific benchmark determination;iv) other decisions in relation to the benchmark determination process.

Complaints procedure
All complaints shall be treated fairly and as promptly as possible.
INITIAL HANDLINGThe person receiving the complaint may attempt to resolve the issue to the satisfaction of the customer. If this is successful, then thedetails of the resolved complaint shall be sent to InternationalCompliance@cmegroup.com for record keeping and reporting purposes.
If however the dissatisfaction persists after initial efforts to resolve the matter, the complaint shall be passed to Compliance forfurther handling.
The person receiving the complaint should also make clear that customers may also direct their complaint, at any time, directly tothe Compliance function at InternationalCompliance@cmegroup.com.
Where an individual person has been formally appointed by a Regulated Entity as a Complaints Officer, then that person shall be
informed of any complaint pertaining to that Regulated Entity and shall lead the handling of any such complaint by Compliance.

2EMEA-APAC Complaints Procedure | © 2023 CME Group. All rights reserved.

HANDLING BY COMPLIANCE(a)	Acknowledgment of receipt	Compliance will promptly acknowledge the receipt of thecomplaint by way of a written confirmation to thecustomer, indicating that the complaint is being
investigated independently, and that a response will be
provided in due course including findings and anycorrective action.	Compliance will also notify the senior manager of therelevant business line detailing the circumstances of thecomplaint.
(b)	Investigation	The investigation of the complaint shall be led byCompliance. Any required information or explanation will
be sought from relevant business or support functions, ordirectly from the customer if necessary.	The investigation shall determine whether the complaint is
upheld, and if so, what corrective actions may beappropriate in response to the issue.	Compliance shall conclude the investigation as quickly aspossible and will ensure the complainant is kept informedof the progress of the measures being taken for thecomplaint’s resolution.

(c)	Response	The conclusions of the investigation shall be communicatedpromptly, and in clear language, to the customer. In theevent that a complaint is partially or fully rejected, reasons
shall be given with a reasonable level of detail.	In the event that complainant is dissatisfied with theoutcome, Compliance will inform the client about theiroptions, including potential referral to an alternative disputeresolution body where appropriate. A list of such bodies
located in the European Union is available via the link below:
https://ec.europa.eu/consumers/odr/main/?event=main.adr.
show2. In the UK, clients may be able to refer the matter tothe Financial Ombudsman Service.
(d)	Reporting	Compliance shall report on a regular basis (and at leastquarterly) to the Board or CEO of the relevant Regulated
Entity concerning any complaints made in respect of that
entity’s services.	Such reporting shall include an analysis of the root causesof any complaints and any measures deemed appropriate
to remedy such root causes.

Record keeping
Compliance shall maintain a record of all complaints received and managed under this Procedure, including:• The legal entity and service that is the subjectof the complaint;• The outcome and conclusions of the investigation;• The customer who made the complaint(including name and any account number);• Any remedial actions taken as a result of the complaint;• The date on which the complaint was received;• The date on which a final response was given;• Any correspondence received from or sent to thecustomer in connection with the complaint.

• The circumstances of the complaint;

Oversight and review of procedure
CME Group will periodically audit and monitor compliance with this Procedure as necessary and appropriate. This Procedure is
subject to review as needed but at least on an annual basis.
REVISION HISTORY FOR EMEA-APAC COMPLAINTS PROCEDUREDATEREVISION

August 2020

Stand-alone document createdJune 2022

Periodic review – updates to Regulated Entity list and legislative references

September 2023

Periodic Review

cmegroup.com© 2023 CME Group Inc. All rights reserved.

PM2982/0923