September 2024

Refinitiv Benchmark Services(UK) LimitedConflicts of Interest Public Disclosure Statement

Introduction
Refinitiv Benchmark Services (UK) Limited (“RBSL”) administers a number of Benchmarks in accordance with the relevant
obligations of the International Organisation of Securities Commissions (“IOSCO”) Principles for Financial Benchmarks, the UK
Benchmark Regulation (“BMR”).
RBSL has in place robust governance arrangements (outlined below) which include a clear organisational structure withwell-defined, transparent and consistent roles and responsibilities, to prevent or manage actual or perceived conflicts of interest
between the firm, directors, managers, members of staff or any person directly or indirectly linked by control, and contributors orusers, and to ensure that, where any expert judgement in the benchmark determination process is required, it is independently andobjectively exercised.
All staff within the LSEG Group, including those undertaking work on behalf of RBSL, are bound by the London Stock ExchangeGroup (“LSEG”) Code of Conduct, which includes policies on organisational and other conflicts of interest. In addition to a Conflictsof Interest policy and procedure, there are other policies and procedures to identify, prevent, manage and mitigate potential conflictsof interest, including:–Anti-Bribery and Corruption;–Gifts and Entertainment;–Hiring and remuneration;–

Whistleblowing;–

Information Security–

Compliance Manual; and–

Personal Account Dealing

Conflicts of Interest Management
RBSL monitors its business and operations to identify activities which may cause an actual or perceived conflict of interest. In
addition, every member of staff is responsible for identifying, reporting and escalating potential conflicts of interest. This ongoingidentification is intended to ensure prevention, management and mitigation of conflicts of interest in order to protect the integrity andindependence in the provision of benchmarks.
Any conflict identified is documented and retained within a conflicts of interest register. The conflicts of interest register is reviewed
on at least an annual basis, or more frequently when a perceived or actual conflict of interest has been identified.
For further information on conflicts relating to WMR, please go to: WMR COI Public Statement.

Governance and Oversight
To oversee its business, RBSL operates a three lines of defence risk management framework and has in place a robust governancestructure for its benchmark administration activities that includes the Board, Governance Forums, Oversight Committees, Risk
Committee, as well as dedicated oversight and control functions. Compliance department members attend all committees providing
assurance over RBSL’s ongoing regulatory compliance.
RBSL’s managers are accountable to the RBSL Board of Directors, themselves subject to the London Stock Exchange Group Codeof Conduct as well as to requirements to manage and disclose conflicts under applicable law.
For further information on RBSL’s control framework, please contact EUBMR1@lseg.com

Benchmark Methodologies and Statements
RBSL’s benchmark methodologies and statements are clearly defined, rules-based and transparent, being publicly available on
FTSE webpages. The benchmark methodologies are designed to define and minimise expert judgement.

Polices and Training
LSEG and RBSL requires staff and RBSL Board members, to undertake mandatory compliance training including training on theLondon Stock Exchange Group Code of Conduct, including conflicts of interest.

Whistleblowing and Confidential Employee Hotline
A dedicated, confidential hotline and reporting portal are available under the London Stock Exchange Group Code of Conduct for
whistleblowing, to enable staff to report any concerns they may have as to an actual or potential breach of the Code, or of laws
or regulation.

FTSE Russell

2

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, assetmanagers, 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

Asia-PacificNorth America +1 877 503 6437

Hong Kong +852 2164 3333
Tokyo +81 3 6441 1430
Sydney +61 (0) 2 7228 5659

Disclaimer© 2024 London Stock Exchange Group plc and its applicable group undertakings (“LSEG”). LSEG includes (1) FTSE International Limited (“FTSE”), (2) Frank Russell Company(“Russell”), (3) FTSE Global Debt Capital Markets Inc. and FTSE Global Debt Capital Markets Limited (together, “FTSE Canada”), (4) FTSE Fixed Income Europe Limited (“FTSE FIEurope”), (5) FTSE Fixed Income LLC (“FTSE FI”), (6) FTSE (Beijing) Consulting Limited (“WOFE”) (7) Refinitiv Benchmark Services (UK) Limited (“RBSL”), (8) Refinitiv Limited (“RL”)
and (9) Beyond Ratings S.A.S. (“BR”). All rights reserved.
FTSE Russell® is a trading name of FTSE, Russell, FTSE Canada, FTSE FI, FTSE FI Europe, WOFE, RBSL, RL, and BR. “FTSE®”, “Russell®”, “FTSE Russell®”, “FTSE4Good®”,“ICB®”, “Refinitiv”, “Beyond Ratings®”, “WMR™”, “FR™” and all other trademarks and service marks used herein (whether registered or unregistered) are trademarks and/or service
marks owned or licensed by the applicable member of LSEG or their respective licensors and are owned, or used under licence, by FTSE, Russell, FTSE Canada, FTSE FI, FTSE FI
Europe, WOFE, RBSL, RL or BR. FTSE International Limited is authorised and regulated by the Financial Conduct Authority as a benchmark administrator. Refinitiv Benchmark
Services (UK) Limited is authorised and regulated by the Financial Conduct Authority as a benchmark administrator.
All information is provided for information purposes only. All information and data contained in this publication is obtained by LSEG, from sources believed by it to be accurate andreliable. Because of the possibility of human and mechanical inaccuracy as well as other factors, however, such information and data is provided “as is” without warranty of any kind.
No member of LSEG nor their respective directors, officers, employees, partners or licensors make any claim, prediction, warranty or representation whatsoever, expressly or impliedly,
either as to the accuracy, timeliness, completeness, merchantability of any information or LSEG Products, or of results to be obtained from the use of LSEG products, including but notlimited to indices, rates, data and analytics, or the fitness or suitability of the LSEG products for any particular purpose to which they might be put. The user of the information assumes
the entire risk of any use it may make or permit to be made of the information.
No responsibility or liability can be accepted by any member of LSEG nor their respective directors, officers, employees, partners or licensors for (a) any loss or damage in whole or inpart caused by, resulting from, or relating to any inaccuracy (negligent or otherwise) or other circumstance involved in procuring, collecting, compiling, interpreting, analysing, editing,transcribing, transmitting, communicating or delivering any such information or data or from use of this document or links to this document or (b) any direct, indirect, special,consequential or incidental damages whatsoever, even if any member of LSEG is advised in advance of the possibility of such damages, resulting from the use of, or inability to use,such information.
No member of LSEG nor their respective directors, officers, employees, partners or licensors provide investment advice and nothing in this document should be taken as constituting
financial or investment advice. No member of LSEG nor their respective directors, officers, employees, partners or licensors make any representation regarding the advisability ofinvesting in any asset or whether such investment creates any legal or compliance risks for the investor. A decision to invest in any such asset should not be made in reliance on any
information herein. Indices and rates cannot be invested in directly. Inclusion of an asset in an index or rate is not a recommendation to buy, sell or hold that asset nor confirmation thatany particular investor may lawfully buy, sell or hold the asset or an index or rate containing the asset. The general information contained in this publication should not be acted upon
without obtaining specific legal, tax, and investment advice from a licensed professional.
Past performance is no guarantee of future results. Charts and graphs are provided for illustrative purposes only. Index and/or rate returns shown may not represent the results of theactual trading of investable assets. Certain returns shown may reflect back-tested performance. All performance presented prior to the index or rate inception date is back-testedperformance. Back-tested performance is not actual performance, but is hypothetical. The back-test calculations are based on the same methodology that was in effect when the index
or rate was officially launched. However, back-tested data may reflect the application of the index or rate methodology with the benefit of hindsight, and the historic calculations of anindex or rate may change from month to month based on revisions to the underlying economic data used in the calculation of the index or rate.
This document may contain forward-looking assessments. These are based upon a number of assumptions concerning future conditions that ultimately may prove to be inaccurate.
Such forward-looking assessments are subject to risks and uncertainties and may be affected by various factors that may cause actual results to differ materially. No member of LSEG
nor their licensors assume any duty to and do not undertake to update forward-looking assessments.
No part of this information may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise,
without prior written permission of the applicable member of LSEG. Use and distribution of LSEG data requires a licence from LSEG and/or its licensors.