CME Group Petroleum Index
IOSCO Compliance Statement

CME Group Benchmark Administration Limited

Publication Date: July 5th, 2023

Introduction
CME Group Benchmark Administration Limited (CBA or the Administrator) has created the CME Group
Petroleum Index, representing a single price for a basket of underlying energy futures listed for trading on
NYMEX, one of the CME Group Designated Contract Markets (DCMs).
The CME Group Petroleum Index (the Index or the Benchmark) is listed in points on a starting value of100.00, set on launch date (3rd August 2020). The value of the Index changes daily, relative to the movementon the underlying components, according to the calculation methodology detailed herein.
The Benchmark is administered by CBA, registered under EU Benchmark Regulation (EU Regulation
2016/1011). CBA is authorized and supervised by the UK Financial Conduct Authority (FCA (UK)).
The Calculation Agent of the Index is Chicago Mercantile Exchange Group Inc. (CME Group), with whom theAdministrator has a calculation agent agreement in place.

Regulatory and IOSCO Compliance
The Index is a benchmark designed on the basis of industry best practices and on the IOSCO Principles for
Financial Benchmarks1. This will include but not be limited to the creation of an Oversight Committee and apublished Methodology. The Index is also subject to a full audit process. Material changes to the Methodology
are announced via public consultation and any changes such as a re-balancing of the constituent components
shall be announced with a notice period of at least 1 (one) month. Where a change occurs, the Index will not
be reset to a value of 100.00, but the price change versus the previous day (prior to the change) will bepreserved.
Capitalised terms not otherwise defined in this document have the meaning given to them in the IOSCO
Principles for Financial Benchmarks Final Report of July 2013.

1https://www.iosco.org/library/pubdocs/pdf/IOSCOPD415.pdf

2© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance

1. Overall
Responsibility oftheAdministrator

The Administrator should retain primary
responsibility for all aspects of the
Benchmark determination process. For
example, this includes:a) Development: The definition of the
Benchmark and Benchmark
Methodology;b) Determination and Dissemination:
Accurate and timely compilation andpublication and distribution of the
Benchmark;2. Oversight ofThird Partiesc) Operation: Ensuring appropriate
transparency over significant decisions
affecting the compilation of the
Benchmark and any related
determination process, including
contingency measures in the event ofabsence of or insufficient inputs, market
stress or disruption, failure of criticalinfrastructure, or other relevant factors;
andd) Governance: Establishing credible
and transparent governance, oversightand accountability procedures for the
Benchmark determination process,including an identifiable oversightfunction accountable for thedevelopment, issuance and operation of
the Benchmark.
Where activities relating to the
Benchmark determination process areundertaken by third parties - for example
collection of inputs, publication or wherea third party acts as Calculation Agent the Administrator should maintainappropriate oversight of such third
parties. The Administrator (and its
oversight function) should consider
adopting policies and procedures that:a) Clearly define and substantiate
through appropriate written
arrangements the roles and obligationsof third parties who participate in the
Benchmark determination process, aswell as the standards the Administrator
expects these third parties to comply
with;

CME Group Benchmark Administration
Limited (CBA) Comment
CBA is the Administrator for the CMEGroup Petroleum Index with primary
responsibility for all aspects of the
Benchmark determination process.
The CME Group Petroleum Index
Benchmark Methodology has been
approved by Petroleum Index OversightCommittee. Details of the Methodology areavailable on the CBA website.
The benchmark is calculated eachbusiness day and published on the CMEGroup website and distributed through
CME Group data services. Subscribers tothe benchmark will be alerted of any delays
through the CME Group website.
The CME Group Petroleum Index is
calculated in accordance with the approved
Methodology (see 1(a) above), which
includes applicable contingency measures.

CBA has established an independent
Oversight Committee to review thebenchmark definition and provides
challenge on all aspects of the benchmark
determination process. The terms ofreference of the Oversight Committee areavailable on the CBA website.
CME Inc. is the calculation and distribution
agent of the CME Group Petroleum Index.

CBA has in place agreements with CME
Inc. for the provision of calculation agent
and Benchmark dissemination services
relating to the CME Group Petroleum
Index. Those agreements include details of
required standards and obligations tomaintain minimum service levels.

3© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidanceb) Monitor third parties’ compliance withthe standards set out by the
Administrator;c) Make Available to Stakeholders andany relevant Regulatory Authority theidentity and roles of third parties who
participate in the Benchmark
determination process; andd) Take reasonable steps, including
contingency plans, to avoid undue
operational risk related to theparticipation of third parties in the
Benchmark determination process.

3. Conflicts ofInterest for
Administrators

This Principle does not apply in relation
to a third party from whom an
Administrator sources data if that third
party is a Regulated Market or
Exchange.
To protect the integrity andindependence of Benchmark
determinations, Administrators should
document, implement and enforce
policies and procedures for theidentification, disclosure, management,
mitigation or avoidance of conflicts ofinterest. Administrators should review
and update their policies andprocedures as appropriate.
Administrators should disclose any
material conflicts of interest to theirusers and any relevant Regulatory
Authority, if any.
The framework should be appropriately
tailored to the level of existing or
potential conflicts of interest identified
and the risks that the Benchmark posesand should seek to ensure:

CME Group Benchmark Administration
Limited (CBA) Comment
CBA monitors third parties through key
performance indicators and regularstakeholder meetings.
CME Inc. is the calculation agent of the
CME Group Petroleum Index. CME Inc. isa distribution agent of the Benchmark.

CBA has business continuity plans in place
for all aspects of the CME Group
Petroleum Index, including contingency
measures for IT system failures and issues
associated with dissemination of the
Benchmark. The calculation agent
agreement with CME Inc. contains
provisions designed to mitigate operationalrisk.
The CME Group Petroleum Index uses
data sourced from NYMEX, a DesignatedContract Market regulated by the
Commodity Futures Trading Commission(CFTC).
CBA has policies and procedures for the
avoidance of conflicts of interest in thedetermination of benchmarks. These
policies are approved by the board andperiodically reviewed.
All entities within CME Group are required
to maintain and operate effective
organisational and administrative
arrangements with a view to taking all
reasonable steps to identify, monitor andmanage all conflicts of interest including
conflicts between itself and its customers.
CBA maintains a stand-alone conflicts ofinterest register, identifying the inherent
conflicts of interest within the firm, whilesetting out appropriate measures tomanage and mitigate those conflicts.
CBA’s board members must abide by the
CME Group Conflicts of Interest Policy,
which sets out requirements governing,among other things, the disclosure ofconflicts by board members and thesituations in which board members areprohibited from participating in decisions of
the board.
CME Group employees are also subject to
the CME Conflicts of Interest Policy andPersonal Trading Policy, Confidentiality
and Data Protection Policy and Gifts and4© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance

CME Group Benchmark Administration
Limited (CBA) Comment
Entertainment Policy. CME Group’s
employment contracts require that
employees comply with all relevant policies
and procedures of CBA.
Any violation of the Conflicts of Interest
Policy may result in disciplinary action
against the board member or employee.

a) Existing or potential conflicts ofinterest do not inappropriately influence
Benchmark determinations;b) Personal interests and connections orbusiness connections do notcompromise the Administrator’s
performance of its functions;c) Segregation of reporting lines within
the Administrator, where appropriate, toclearly define responsibilities andprevent unnecessary or undisclosed
conflicts of interest or the perception ofsuch conflicts;d) Adequate supervision and sign-off byauthorised or qualified employees prior
to releasing Benchmark determinations;e) The confidentiality of data,
information and other inputs submitted
to, received by or produced by the
Administrator, subject to the disclosure
obligations of the Administrator;f) Effective procedures to control theexchange of information between staff
engaged in activities involving a risk of
conflicts of interest or between staff andthird parties, where that information may

The Administrator’s Compliance Monitoringteam is responsible for ensuring that the
Conflicts of Interest Management Policy isadhered to. This is conducted via periodic
reviews of business areas/units.
CME Group staff involved in the productionof benchmarks are prohibited from having
direct investment exposure to thosebenchmarks. Members of the OversightCommittee are required to disclose any
conflicts of interest.
CBA has policies and procedures in place
to avoid conflicts of interest. This includes
obligations on CME Group staff to avoid
and declare conflicts of interest.
CBA is an authorised benchmark
administrator, supervised by the FCA (UK)with clear segregation of reporting lines.
As further described below, access to data
within CME Group is strictly controlled by
the “Data Access Request” process, anddata will not be released or shared with amember of staff unless it is required fortheir role. In combination with thedifferentiated reporting lines, this provides
a strong control framework that prevents
conflicts of interest, or the perception ofsuch conflicts.
Authorised and qualified staff supervise theprocess of the release of the Benchmark
determinations. Any issues involved in thecalculation or dissemination of the
Benchmark by CME Inc. are escalated to
the relevant manager at CBA.
CME Group implements group-wide
policies and procedures to ensure theconfidentiality of data and information.

CME Group staff are subject to mandatory
annual compliance training andcertification, which includes procedures oncontrol of exchange of information.

5© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance
reasonably affect any Benchmark
determinations; andg) Adequate remuneration policies that
ensure all staff who participate in the
Benchmark determination are notdirectly or indirectly rewarded or
incentivised by the levels of the
Benchmark.
An Administrator’s conflict of interest
framework should seek to mitigate
existing or potential conflicts created byits ownership structure or control, or due
to other interests the Administrator’s
staff or wider group may have in relation
to Benchmark determinations. To thisend, the framework should:

CME Group Benchmark Administration
Limited (CBA) Comment

CME Group compensation andremuneration ensures salaries and benefits
are not linked to the value of the calculated
Benchmarks.

CME Group has in place multiple controlsthat seek to mitigate or control potential
conflicts created by its ownership structure.
These include the development of aconflicts register identifying potential
conflicts and seeking to remove or control
those. Above this, CME Group maintains
confidentiality and access control policies
and controls which are established topermit persons who need to know
information to use and have access to
it. In particular, CBA operational staff haveseparate reporting lines to those working
within the exchanges/MTFs that supply thetransaction data for the benchmark
calculation.
In addition, access and use of CME Group
Confidential or Highly Sensitive data isstrictly limited to employees that have abusiness reason to access and/or use theinformation. If a department, team or
employee requires access to CME Group
Confidential or CME Group Highly
Sensitive data for a new business purpose,requests are submitted through the Data
Access Request (“DAR”) process forreview and consideration. More details
and examples of data requests that fall into
this process can be found in the CMEGroup Confidentiality and Data Protection
Policy which can be found on the CMEGroup website.

a) Include measures to avoid, mitigate
or disclose conflicts of interest that may
exist between its Benchmark
determination business (including all
staff who perform or otherwise
participate in Benchmark production
responsibilities), and any other businessof the Administrator or any of its
affiliates; andb) Provide that an Administrator
discloses conflicts of interest arisingfrom the ownership structure or the

As set out above, CME Group maintains
firm wide policies and procedures tomitigate and avoid a conflict of interest.

CBA is supervised by the FCA (UK) andwill make available details of its conflict of

6© 2023 CME Group. All rights reserved.

IOSCO Principle

4. Control
Framework for
Administrators

IOSCO Principles - Detailed Guidancecontrol of the Administrator to its
Stakeholders and any relevant
Regulatory Authority in a timely manner.
An Administrator should implement anappropriate control framework for theprocess of determining and distributing
the Benchmark. The control framework
should be appropriately tailored to themateriality of the potential or existing
conflicts of interest identified, the extent
of the use of discretion in the
Benchmark setting process and to thenature of Benchmark inputs and outputs.
The control framework should be
documented and available to relevant
Regulatory Authorities, if any. A
summary of its main features should be
Published or Made Available to
Stakeholders.
This control framework should be
reviewed periodically and updated as
appropriate. The framework should
address the following areas:a) Conflicts of interest in line with
Principle 3 on conflicts of interests;b) Integrity and quality of Benchmark
determination:i. Arrangements to ensure that thequality and integrity of Benchmarks ismaintained, in line with principles 6 to 15
on the quality of the Benchmark andMethodology;
ii. Arrangements to promote the integrityof Benchmark inputs, including
adequate due diligence on input
sources;iii. Arrangements to ensureaccountability and complaints
mechanisms are effective, in line withprinciples 16 to 19; andiv. Providing robust infrastructure,policies and procedures for the
management of risk, including
operational risk.

CME Group Benchmark Administration
Limited (CBA) Commentinterest register to its regulatory authority
upon request.
CBA has implemented a Risk and Control
Framework consistent with CME Group
policies and procedures, with certain
details outlined below.

CBA has implemented a conflicts ofinterest policy in line with IOSCO Principle
3. See details above.
i. The CME Group Petroleum Index is
calculated in accordance with the approved
Methodology. Any deviation from theapproved Methodology requires additional
review by the Oversight Committee.
ii. Input data to the Benchmark calculation
are settlement prices of regulated future
markets operated by NYMEX. Settlement
prices are determined following a waterfall
methodology, including transactions andexecutable orders. CBA has performed due
diligence on the depth and liquidity of themarket and is satisfied as to the adequacyof its controls, and that the transactions
and executable orders on the market are a
sufficient input to the CME Group
Petroleum Index.
iii. CME Group has in place a complaints
procedure which is published on the CMEGroup website. The procedures takeaccount of the particular requirements for a
Benchmark Administrator to receive anddeal appropriately with complaints that
relate to the calculation of the benchmark.
CBA is subject to audit reviews and has

7© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidancec) Whistleblowing mechanism:
Administrators should establish aneffective whistleblowing mechanism tofacilitate early awareness of any
potential misconduct or irregularities that
may arise. This mechanism should allow
for external reporting of such cases
where appropriate.

d) Expertise:i. Ensuring Benchmark determinations
are made by personnel who possess therelevant levels of expertise, with aprocess for periodic review of theircompetence; andii. Staff training, including ethics andconflicts of interest training, andcontinuity and succession planning for
personnel.
Where a Benchmark is based on
Submissions: Administrators should
promote the integrity of inputs by:a) Ensuring as far as possible that theSubmitters comprise an appropriately
representative group of participants
taking into consideration the underlying
Interest measured by the Benchmark;b) Employing a system of appropriate
measures so that, to the extent possible,
Submitters comply with the Submission
guidelines, as defined in the Submitter
Code of Conduct and the Administrators’
applicable quality and integrity
standards for Submission;c) Specifying how frequently
Submissions should be made andspecifying that inputs or Submissions
should be made for every Benchmark
determination; andCME Group Benchmark Administration
Limited (CBA) Comment
regulatory obligations, aligned with
Principles 16 to 19.
iv. CBA has implemented a Risk andControl Framework for the management of
its benchmarks, which lists categories ofrisk and controls to mitigate against them.
This is part of the CME Group Enterprise
Risk framework.
CME Group maintains internal policies andprocedures for the reporting of actual or
perceived misconduct.
In addition, CBA allows for external
whistleblowing throughinternationalcompliance@cmegroup.com.
All complaints related to CBA are reviewed
by Compliance and reported to OversightCommittee.
i. Calculation of Benchmarks are performedby personnel who possess the relevant
levels of experience and expertise,including by performing similar functions inrelation to other Benchmarks and operating
CME’s market data business. CME Group
employs an annual performance review
policy.
ii. CME Group requires staff to undergo
mandatory annual compliance training,
including conflicts of interest and ethics.
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.

N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.

8© 2023 CME Group. All rights reserved.

IOSCO Principle

5. Internal
Oversight

IOSCO Principles - Detailed Guidanced) Establishing and employing measures
to effectively monitor and scrutinise
inputs or Submissions. This should
include pre-compilation or prepublication monitoring to identify andavoid errors in inputs or Submissions, aswell as ex-post analysis of trends andoutliers.
Administrators should establish an
oversight function to review and provide
challenge on all aspects of the
Benchmark determination process. Thisshould include consideration of thefeatures and intended, expected or
known usage of the Benchmark and themateriality of existing or potential
conflicts of interest identified.
The oversight function should be carriedout either by a separate committee, orother appropriate governancearrangements. The oversight function
and its composition should beappropriate to provide effective scrutinyof the Administrator. Such oversightfunction could consider groups ofBenchmarks by type or asset class,provided that it otherwise complies withthis Principle.
An Administrator should develop andmaintain robust procedures regarding its
oversight function, which should be
documented and available to relevant
Regulatory Authorities, if any. The mainfeatures of the procedures should be
Made Available to Stakeholders. These
procedures should include:a) The terms of reference of theoversight function;b) Criteria to select members of theoversight function;c) The summary details of membershipof any committee or arrangement
charged with the oversight function,
along with any declarations of conflictsof interest and processes for election,
nomination or removal and replacementof committee members.
The responsibilities of the oversightfunction include:

CME Group Benchmark Administration
Limited (CBA) Comment
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.

A CME Group Petroleum Index OversightCommittee has been established to provide
challenge on all aspects of the benchmark
determination process.
Terms of Reference for the committee arein place defining committee membershipand responsibilities. Oversight Committee
members are required to provide conflictsof interest disclosures.
The CME Group Petroleum Index
Oversight Committee comprises industry
experts with the appropriate expertise toprovide challenge and effective scrutiny of
the Administrator, such as market
expertise, control and risk expertise,
operational expertise, benchmark andregulation expertise, general financial
market expertise, or legal and complianceexpertise.
CBA has established an independent
Oversight Committee for the CME Group
Petroleum Index.

The Oversight Committee has clearly
defined Terms of Reference, which can be
Made Available to Stakeholders uponrequest.
The Oversight Committee membershipselection is outlined in the OversightCommittee Terms of Reference.
The process for the nomination, removal
and replacement of committee members isoutlined in the Terms of Reference. A
conflicts of interest register is maintained
for members of the Oversight Committee.

9© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidancea) Oversight of the Benchmark design:i. Periodic review of the definition of the
Benchmark and its Methodology;
ii. Taking measures to remain informed
about issues and risks to the
Benchmark, as well as commissioning
external reviews of the Benchmark (asappropriate);iii. Overseeing any changes to the
Benchmark Methodology, including
assessing whether the Methodology
continues to appropriately measure theunderlying Interest, reviewing proposed
and implemented changes to the
Methodology, and authorising orrequesting the Administrator toundertake a consultation with
Stakeholders where known or its
Subscribers on such changes as per
Principle 12; andiv. Reviewing and approving proceduresfor termination of the Benchmark,including guidelines that set out how theAdministrator should consult with
Stakeholders about such cessation.

b) Oversight of the integrity ofBenchmark determination and control
framework:
i. Overseeing the management andoperation of the Benchmark, including
activities related to Benchmark
determination undertaken by a third
party;
ii. Considering the results of internal andexternal audits, and following up on theimplementation of remedial actions
highlighted in the results of these audits;and

CME Group Benchmark Administration
Limited (CBA) Commenti. The Oversight Committee will review theMethodology on an annual basis.
ii. General issues and risks to the
Benchmark will be escalated, as
appropriate, to the Oversight Committee
and CBA board for discussion and review.
Meetings of the Oversight Committee andthe CBA board involve presentations on
the performance of the Benchmark. In
exercising its duties as an oversightfunction, CBA will provide all necessary
documents and information to those
governance bodies. The CBA board canrequest external review as appropriate andwill be subject to internal audit reviews on aregular basis.
iii. The Oversight Committee will review
any changes to the Benchmark
Methodology. In addition, the annual
review of the Methodology ensures thecontinued integrity of the Benchmark
determinations. Where appropriate, theOversight Committee may request theAdministrator to consult with the market on
material changes to the Benchmark
Methodology.
iv. CBA has in place, in the Methodology
document, procedures (including
consultation with Stakeholders) that
address the possible cessation of the
Benchmark due to conditions resulting in
the Benchmark no longer representing its
intended interest.
CBA’s control framework encompasses:
i. Service Level Agreements to maintainappropriate oversight of the CME Inc. input
data collection, Calculation Agent andpublication and distribution services.
ii. The review of audit findings and status of
any required remedial actions.

iii. The review and approval of nonstandard procedures used in the
Benchmark determination process,including the use of Expert Judgement.

iii. Overseeing any exercise of Expert
Judgment by the Administrator and10© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance

CME Group Benchmark Administration
Limited (CBA) Comment

ensuring Published Methodologies havebeen followed.

Where conflicts of interests may arisein the Administrator due to its
ownership structures or controllinginterests, or due to other activities
conducted by any entity owning orcontrolling the Administrator or by
the Administrator or any of its
affiliates: the Administrator should
establish an independent oversightfunction which includes a balanced
representation of a range of
Stakeholders where known, Subscribers
and Submitters, which is chosen tocounterbalance the relevant conflict ofinterest.
Where a Benchmark is based on
Submissions: the oversight function
should provide suitable oversight andchallenge of the Submissions by:a)Overseeing and challenging thescrutiny and monitoring of inputs or
Submissions by the Administrator. This
could include regular discussions of
inputs or Submission patterns, defining
parameters against which inputs or
Submissions can be analysed, or
querying the role of the Administrator inchallenging or sampling unusual inputs
or Submissions;b) Overseeing the Code of Conduct for
Submitters;c) Establishing effective arrangements
to address breaches of the Code of
Conduct for Submitters; andd) Establishing measures to detect
potential anomalous or suspicious
Submissions and in case of suspicious
activities, to report them, as well as any
misconduct by Submitters of which it

CBA has established an independent
Oversight Committee consisting of industry
experts.

N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.

N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index..
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index

11
© 2023 CME Group. All rights reserved.

IOSCO Principle

6. Benchmark
DesignIOSCO Principles - Detailed Guidance
becomes aware to the relevant
Regulatory Authorities, if any.
The design of the Benchmark shouldseek to achieve, and result in an
accurate and reliable representation of
the economic realities of the Interest it
seeks to measure, and eliminate factorsthat might result in a distortion of theprice, rate, index or value of the
Benchmark.
Benchmark design should take into
account the following generic nonexclusive features, and other factors
should be considered, as appropriate to
the particular Interest:a) Adequacy of the sample used torepresent the Interest;b) Size and liquidity of the relevantmarket (for example whether there issufficient trading to provide observable,transparent pricing);c) Relative size of the underlying market
in relation to the volume of trading in themarket that references the Benchmark;d) The distribution of trading among
Market Participants (market
concentration);e) Market dynamics (e.g., to ensure thatthe Benchmark reflects changes to theassets underpinning a Benchmark).

7. DataSufficiency

The data used to construct a Benchmark
determination should be sufficient toaccurately and reliably represent theInterest measured by the Benchmark
and should:a) Be based on prices, rates, indices orvalues that have been formed by thecompetitive forces of supply anddemand in order to provide confidence

CME Group Benchmark Administration
Limited (CBA) Comment

The CME Group Petroleum Index
represents a single price for a basket ofunderlying Energy Futures which are listed
for trading on NYMEX. Those are the
NYMEX WTI Crude Oil futures (Commodity
code CL), the NYMEX RBOB Gasoline
futures (Commodity code RB) and the
NYMEX NY Harbor ULSD futures(Commodity code HO).
The CME Group Petroleum Index has been
designed to ensure the Benchmark isrepresentative of its underlying interest andremains robust.
The future contracts are actively traded on
the NYMEX Exchange and settlement
prices are determined on each Globex
trading day according to a waterfall
Methodology, that always ensure thepublication of a settlement price.
In the first quarter of 2023, NYMEX WTI
Crude Oil futures (Commodity code CL)
has averaged open interest of over 1.7
million contracts, the NYMEX RBOB
Gasoline futures (Commodity code RB)
has averaged open interest of over 300
thousand contracts and the NYMEX NY
Harbor ULSD futures (Commodity codeHO) has averaged open interest of over
260 thousand contracts.
Currently there are no financial instrumentsthat reference this Benchmark.
All customer segments are represented
including proprietary trading groups, banks,
hedge funds and asset managers.
The CME Group Petroleum Index
calculation is based on three Energy
NYMEX Futures Contracts. The Settlement
price used in the calculation ensure thebenchmark reflects changes to theunderpinning assets.
The CME Group Petroleum Index is basedon transactions in the NYMEX energy
Futures contracts, which accurately andreliably represents the economic reality the
benchmark is intended to measure.
The input data used in the calculation of
the CME Group Petroleum Index is fromCME Group’s Designated Contracts Market
which are subject to surveillance andmandatory reporting requirements. Details

12© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance
that the price discovery system isreliable; andb) Be anchored by observabletransactions entered into at arm’s length
between buyers and sellers in themarket for the Interest the Benchmark
measures in order for it to function as acredible indicator of prices, rates,
indices or values.
This Principle requires that a Benchmark
be based upon (i.e., anchored in) an
active market having observable BonaFide, Arms-Length Transactions. This
does not mean that every individual
Benchmark determination must be
constructed solely of transaction data.
Provided that an active market exists,
conditions in the market on any given
day might require the Administrator torely on different forms of data tied toobservable market data as an adjunct or
supplement to transactions. Depending
upon the Administrator’s Methodology,
this could result in an individual
Benchmark determination being based
predominantly, or exclusively, on bids
and offers or extrapolations from priortransactions. This is further clarified in
Principle 8.
Provided that subparagraphs (a) and (b)above are met, Principle 7 does notpreclude Benchmark Administratorsfrom using executable bids or offers as ameans to construct Benchmarks whereanchored in an observable market
consisting of Bona Fide, Arms-Lengthtransactions.
This Principle also recognizes thatvarious indices may be designed tomeasure or reflect the performance of arule-based investment strategy, thevolatility or behaviour of an index or
market or other aspects of an active
market. Principle 7 does not preclude
the use of non-transactional data forsuch indices that are not designed torepresent transactions and where thenature of the index is such that nontransactional data is used to reflect what
the index is designed to measure. For
example, certain volatility indices, which
are designed to measure the expectedvolatility of an index of securities

CME Group Benchmark Administration
Limited (CBA) Commentof the Energy Futures contracts and theirvolume and open interest are available on
CME Group website.
The CME Group Petroleum Index is
calculated using daily settlement prices forthe relevant Energy Futures contracts,
traded on a regulated market consisting ofBona Fide, Arms-Length Transactions
between buyers and sellers.
The Settlement prices used in thecalculation of the CME Group Petroleum
Index are based on a waterfall oftransaction and executable bid/offer data,consistent with Principle 8. This is
explained in the Methodology.

13© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance

CME Group Benchmark Administration
Limited (CBA) Comment

transactions, rely on non-transactionaldata, but the data is derived from andthus “anchored” in an actual functioning
securities or options market.

8. Hierarchy ofData Inputs

An Administrator should establish andPublish or Make Available clear
guidelines regarding the hierarchy ofdata inputs and exercise of Expert
Judgment used for the determination of
Benchmarks. In general, the hierarchy ofdata inputs should include:a) Where a Benchmark is dependent
upon Submissions, the Submitters’ own
concluded arms-length transactions in
the underlying interest or related
markets;b) Reported or observed concluded
Arm’s-length Transactions in theunderlying interest;c) Reported or observed concluded
Arm’s-length Transactions in related
markets;d) Firm (executable) bids and offers; ande) Other market information or Expert
Judgments.
Provided that the Data Sufficiency
Principle is met (i.e., an active market
exists), this Principle is not intended torestrict an Administrator’s flexibility touse inputs consistent with the
Administrator’s approach to ensuring thequality, integrity, continuity and reliabilityof its Benchmark determinations, as set
out in the Administrator’s Methodology.
The Administrator should retain flexibility
to use the inputs it believes areappropriate under its Methodology toensure the quality and integrity of its

The published Methodology provides
details the hierarchy of data inputs used in
the determination of the CME Group
Petroleum Index.

N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.

Data inputs used in the calculation of the
CME Group Petroleum Index is based on
CME’s final settlement prices.
N/A – Reported or observed transactions inrelated markets are not used in thecalculation of the CME Group Petroleum
Index.
Data inputs used in the calculation of the
CME Group Petroleum Index is based on
CME’s final settlement prices.
N/A – Expert judgement and other market
information is not used in the calculation of
the CME Group Petroleum Index.
The CME Group Petroleum Index
Benchmark Methodology details the
Administrator’s approach to ensure thequality, integrity, continuity and reliability of
the Benchmark.

14© 2023 CME Group. All rights reserved.

IOSCO Principle

9. Transparencyof Benchmark
Determinations

10. Periodic
Review

IOSCO Principles - Detailed Guidance
Benchmark. For example, certain
Administrators may decide to rely uponExpert Judgment in an active albeit low
liquidity market, when transactions may
not be consistently available each day.
IOSCO also recognizes that there might
be circumstances (e.g., a low liquidity
market) when a confirmed bid or offer
might carry more meaning than anoutlier transaction. Under thesecircumstances, non-transactional datasuch as bids and offers andextrapolations from prior transactions
might predominate in a given
Benchmark determination.
The Administrator should describe andpublish with each Benchmark
determination, to the extent reasonable
without delaying an Administrator
publication deadline:a) A concise explanation, sufficient tofacilitate a Stakeholder’s or Market
Authority’s ability to understand how thedetermination was developed, including,at a minimum, the size and liquidity ofthe market being assessed (meaning
the number and volume of transactions
submitted), the range and averagevolume and range and average of price,
and indicative percentages of each typeof market data that have been
considered in a Benchmark
determination; terms referring to thepricing Methodology should be included(i.e., transaction-based, spread-based orinterpolated/extrapolated);b) A concise explanation of the extent towhich and the basis upon which Expert
Judgment if any, was used inestablishing a Benchmark
determination.
The Administrator should periodicallyreview the conditions in the underlying
Interest that the Benchmark measures
to determine whether the Interest has
undergone structural changes that might
require changes to the design of the
Methodology. The Administrator also
should periodically review whether theInterest has diminished or is nonfunctioning such that it can no longer
function as the basis for a credible
Benchmark.

CME Group Benchmark Administration
Limited (CBA) Comment

The CME Group Petroleum Index will be
published by 17:30EST each business dayin accordance with the CME Clearing
Holiday Calendar.
The settlement prices used as input to the
CME Group Petroleum Index are weighted
according to the open interest of eachfuture contract. As stated by the
Calculation Methodology document, theAdministrator monitors the Open Interest in
the last quarter of each year and calculates
average open interest over that quarter.
Each contract is then "weighted" against
the total open interest quarterly average forthe three constituents

N/A – Expert judgement is not used in thecalculation of the CME Group Petroleum
Index.

CBA periodically reviews the underlying
futures market to ensure the integrity of the
CME Group Petroleum Index. The
Oversight Committee will review theperformance of the Benchmark inaccordance with its terms of reference, toensure its credibility.

15© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance
The Administrator should Publish or
Make Available a summary of such
reviews where material revisions havebeen made to a Benchmark, including
the rationale for the revisions.

11.Content of
the Methodology

The Administrator should document andPublish or Make Available theMethodology used to make Benchmark
determinations. The Administrator
should provide the rationale for adopting
a particular Methodology. The Published
Methodology should provide sufficientdetail to allow Stakeholders tounderstand how the Benchmark is
derived and to assess its
representativeness, its relevance toparticular Stakeholders, and its
appropriateness as a reference forfinancial instruments.
At a minimum, the Methodology should
contain:a) Definitions of key terms;b) All criteria and procedures used todevelop the Benchmark, including input
selection, the mix of inputs used toderive the Benchmark, the guidelinesthat control the exercise of Expert
Judgment by the Administrator, priority
given to certain data types, minimum
data needed to determine a Benchmark,and any models or extrapolation
methods;c) Procedures and practices designed topromote consistency in the exercise ofExpert Judgment between Benchmark
determinations;d) The procedures which govern
Benchmark determination in periods ofmarket stress or disruption, or periods
where data sources may be absent(e.g., theoretical estimation models);e) The procedures for dealing with error
reports, including when a revision of a
Benchmark would be applicable;f) Information regarding the frequency
for internal reviews and approvals of the
Methodology. Where applicable, thePublished Methodologies should also
include information regarding theprocedures and frequency for external
review of the Methodology;

CME Group Benchmark Administration
Limited (CBA) Comment
Changes to the CME Group Petroleum
Index Benchmark Methodology will be
reviewed by the Oversight Committee andas appropriate may request theAdministrator to consult with relevant
Stakeholders and the wider market on any
material changes.
CBA will publish and make available theMethodology of the CME Group Petroleum
Index.

Key terms are defined in the published
Methodology.
The criteria and hierarchy of inputs aredescribed in the published Methodology
document.

N/A - Expert Judgement is not used in thecalculation of the CME Group Petroleum
Index.
The procedures governing the Benchmark
determinations in times of stress andmarket disruption are included in the
published Methodology.
Error reporting and republication
procedures are included in the published
Methodology document.
The frequency of review is included in the
published Methodology. Any requiredchanges to the Methodology will be inaccordance with Principle 12.

16© 2023 CME Group. All rights reserved.

IOSCO Principle

12.Changes tothe Methodology

IOSCO Principles - Detailed Guidanceg) The circumstances and procedures
under which the Administrator willconsult with Stakeholders, as
appropriate; andh) The identification of potential
limitations of a Benchmark, including its
operation in illiquid or fragmented
markets and the possible concentrationof inputs.
Where a Benchmark is based on
Submissions, the additional Principle
also applies:
The Administrator should clearly
establish criteria for including andexcluding Submitters. The criteria
should consider any issues arising fromthe location of the Submitter, if in adifferent jurisdiction to the Administrator.
These criteria should be available to any
relevant Regulatory Authorities, if any,and Published or Made Available to
Stakeholders. Any provisions related tochanges in composition, including notice
periods should be made clear.
An Administrator should Publish or
Make Available the rationale of any
proposed material change in its
Methodology, and procedures formaking such changes. These
procedures should clearly define what
constitutes a material change, and themethod and timing for consulting or
notifying Subscribers (and other
Stakeholders where appropriate, taking
into account the breadth and depth of
the Benchmark’s use) of changes.
Those procedures should be consistent
with the overriding objective that an
Administrator must ensure the continued
integrity of its Benchmark
determinations. When changes areproposed, the Administrator should
specify exactly what these changes
entail and when they are intended toapply.
The Administrator should specify howchanges to the Methodology will be
scrutinised, by the oversight function.

The Administrator should develop
Stakeholder consultation procedures inrelation to changes to the Methodologythat are deemed material by the

CME Group Benchmark Administration
Limited (CBA) Comment
The published Methodology document
details the circumstances under which CBA
will consult with Stakeholders and themarket.
The published Methodology details how the
CME Group Petroleum Index shall be
determined in illiquid markets.
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.
N/A – Submissions are not used in thecalculation of the CME Group Petroleum
Index.

CBA will consult with Stakeholders and themarket with regards to material changes to
the CME Group Petroleum Index
Benchmark Methodology.

The CME Group Petroleum Index
Oversight Committee periodically reviews
the Methodology to ensure it continues torepresent its underlying interest. Anychanges will be specified and theirimplementation timeline explained.

CBA may seek to revise the CME Group
Petroleum Index Benchmark Methodology.
Any changes to the Benchmark
Methodology are presented to theOversight Committee for review.
The Benchmark Methodology provides that
CBA will consult with Stakeholders onmaterial changes to the Methodology.
Consultation will ordinarily consist of17© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance
oversight function, and that areappropriate and proportionate to thebreadth and depth of the Benchmark’s
use and the nature of the Stakeholders.
Procedures should:

13.Transitiona) Provide advance notice and a clear
timeframe that gives Stakeholders
sufficient opportunity to analyse andcomment on the impact of suchproposed material changes, having
regard to the Administrator’s
assessment of the overall
circumstances; andb) Provide for Stakeholders’ summarycomments, and the Administrator’ssummary response to those comments,
to be made accessible to all
Stakeholders after any given
consultation period, except where thecommenter has requested
confidentiality.
Administrators should have clear written
policies and procedures, to address theneed for possible cessation of a
Benchmark, due to market structurechange, product definition change, or
any other condition which makes the
Benchmark no longer representative of
its intended Interest. These policies andprocedures should be proportionate to
the estimated breadth and depth ofcontracts and financial instruments thatreference a Benchmark and theeconomic and financial stability impactthat might result from the cessation of
the Benchmark. The Administrator
should take into account the views of
Stakeholders and any relevant
Regulatory and National Authorities indetermining what policies andprocedures are appropriate for aparticular Benchmark.

CME Group Benchmark Administration
Limited (CBA) Comment
publishing of proposals, providing
Stakeholders with a reasonable time torespond and publishing actions as a resultof the consultation. In addition, theOversight Committee can request theAdministrator to consult on any change asappropriate.
Material changes to the Benchmark
Methodology will involve Stakeholder
consultation that provides an opportunity toanalyse and comment on the impact of
those changes.

CBA will make available Stakeholders’summary comments and responses on
consultations regarding a material change
to the CME Group Petroleum Index
Benchmark Methodology as appropriate.

The Administrator constantly monitors therepresentativeness of the Benchmark. If
the benchmark is deemed to be
unrepresentative of the underlying
economic reality due to paucity of input
data or systemic changes in the related
markets, the Administrator will engage theOversight Committee, at the earliest
opportunity.
The Benchmark Methodology contains
details of the steps that the Administrator
needs to take in order to inform therelevant Stakeholders.
The Oversight Committee may direct theAdministrator to consult with Stakeholders
and end-users on material changes to thebenchmark.
The Administrator will publish notice of theconsultation on its website, inviting
feedback from Stakeholders and the wider
market. Notice of a consultation will be
posted at least 1 (one) month prior to thedeadline for responses. The notice will
include the details of the proposed materialchange, the timeline and the rationale forthe change.
Findings of the consultation process andproposed changes to the Benchmark
Methodology recommended as a result of
the consultation, will be presented by the
Administrator to the Oversight Committee18© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance

These written policies and proceduresshould be Published or Made Available
to all Stakeholders.
Administrators should encourage
Subscribers and other Stakeholders who
have financial instruments that referencea Benchmark to take steps to make surethat:a) Contracts or other financial
instruments that reference a
Benchmark, have robust fall-backprovisions in the event of materialchanges to, or cessation of, thereferenced Benchmark; andb) Stakeholders are aware of thepossibility that various factors, including
external factors beyond the control of
the Administrator, might necessitatematerial changes to a Benchmark.
Administrators’ written policies andprocedures to address the possibility ofBenchmark cessation could include thefollowing factors, if determined to bereasonable and appropriate by the
Administrator:a) Criteria to guide the selection of acredible, alternative Benchmark such as,
but not limited to, criteria that seek tomatch to the extent practicable theexisting Benchmark’s characteristics(e.g., credit quality, maturities andliquidity of the alternative market),differentials between Benchmarks, theextent to which an alternative
Benchmark meets the asset/liability
needs of Stakeholders, whether therevised Benchmark is investable, theavailability of transparent transaction
data, the impact on Stakeholders andimpact of existing legislation;b) The practicality of maintaining parallel
Benchmarks (e.g., where feasible,
maintain the existing Benchmark for adefined period of time to permit existing
contracts and financial instruments tomature and publish a new Benchmark)in order to accommodate an orderlytransition to a new Benchmark;CME Group Benchmark Administration
Limited (CBA) Commentfor its consideration.
Feedback to a consultation is considered
confidential, however the Administrator will
publish an anonymized summary with its
conclusions, as soon as it is practical, but
before implementation of any changes.
The Benchmark Methodology describes
the procedures required for the cessationof the benchmark.
The Benchmark Methodology recommends
users of the benchmark to ensure they
have adequate fallback policies andprocedures in the event of the Benchmark
losing its representativeness, due tochanges in the Regulatory Framework
and/or market conditions.

The Benchmark Methodology requires a 6(six) month transition period, in theoccurrence of cessation of the benchmark.
Such transition period is designed toensure that the benchmark continues tooperate in parallel to any substitute.
During such transition, the Administrator isrequired, by the Benchmark Methodology,
to explore alternative arrangements andadvise Stakeholders, including Regulatorsand end-users, about their findings.
The Administrator will endeavour to identify
alternative benchmarks; however, thismight not always be possible due toRegulations or market conditions.

19© 2023 CME Group. All rights reserved.

IOSCO Principle

14.Submitter
Code of Conduct

IOSCO Principles - Detailed Guidancec) The procedures that the Administrator
would follow in the event that a suitable
alternative cannot be identified;d) In the case of a Benchmark or a tenorof a Benchmark that will be discontinued
completely, the policy defining theperiod of time in which the Benchmark
will continue to be produced in order topermit existing contracts to migrate to analternative Benchmark if necessary; ande) The process by which the
Administrator will engage Stakeholders
and relevant Market and National
Authorities, as appropriate, in theprocess for selecting and moving
towards an alternative Benchmark,including the timeframe for any suchaction commensurate with the tenors of
the financial instruments referencing theBenchmarks and the adequacy of noticethat will be provided to Stakeholders.
The Administrator should develop
guidelines for Submitters (“Submitter
Code of Conduct”), which should beavailable to any relevant Regulatory
Authorities, if any and Published orMade Available to Stakeholders.
The Administrator should only use
inputs or Submissions from entities
which adhere to the Submitter Code of
Conduct and the Administrator should
appropriately monitor and record
adherence from Submitters. The
Administrator should require Submittersto confirm adherence to the Submitter
Code of Conduct annually andwhenever a change to the Submitter
Code of Conduct has occurred.
The Administrator’s oversight function
should be responsible for the continuing
review and oversight of the Submitter
Code of Conduct.
The Submitter Code of Conduct should
address:a)
The selection of inputs;b)
Who may submit data andinformation to the Administrator;c)
Quality control procedures to verify
the identity of a Submitter and any
employee(s) of a Submitter who
report(s) data or information and theauthorization of such person(s) to reportmarket data on behalf of a Submitter;

CME Group Benchmark Administration
Limited (CBA) Comment

N/A – The CME Group Petroleum Index isnot based on Submissions

N/A - The CME Group Petroleum Index isnot based on Submissions

N/A - The CME Group Petroleum Index isnot based on Submissions

N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions

20© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidanced) Criteria applied to employees of a
Submitter who are permitted to submit
data or information to an Administrator
on behalf of a Submitter;e)
Policies to discourage the interim
withdrawal of Submitters from surveys
or Panels;f)
Policies to encourage Submitters
to submit all relevant data; andCME Group Benchmark Administration
Limited (CBA) Comment
N/A - The CME Group Petroleum Index isnot based on Submissions

N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions

21© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidanceg)
The Submitters’ internal systems
and controls, which should include:i. Procedures for submitting inputs,
including Methodologies to determine
the type of eligible inputs, in line with the
Administrator’s Methodologies;

CME Group Benchmark Administration
Limited (CBA) Comment
N/A - The CME Group Petroleum Index isnot based on Submissions

ii. Procedures to detect and evaluate
suspicious inputs or transactions,
including inter-group transactions, andto ensure the Bona Fide nature of such
inputs, where appropriate;
iii. Policies guiding and detailing the useof Expert Judgment, including
documentation requirements;
iv. Record keeping policies;v. Pre-Submission validation of inputs,
and procedures for multiple reviews by
senior staff to check inputs;
vi. Training, including training withrespect to any relevant regulation(covering Benchmark regulation or any
market abuse regime);vii. Suspicious Submission reporting;viii. Roles and responsibilities of key
personnel and accountability lines;
ix. Internal sign off procedures bymanagement for submitting inputs;
x. Whistle blowing policies (in line with
Principle 4); andxi. Conflicts of interest procedures andpolicies, including prohibitions on the
Submission of data from Front Office
Functions unless the Administrator issatisfied that there are adequate internal
oversight and verification procedures for
Front Office Function Submissions ofdata to an Administrator (including
safeguards and supervision to addresspossible conflicts of interests as per
paragraphs (v) and (ix) above), thephysical separation of employees andreporting lines where appropriate, theconsideration of how to identify,
disclose, manage, mitigate and avoid

22© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidance

CME Group Benchmark Administration
Limited (CBA) Comment

existing or potential incentives tomanipulate or otherwise influence data
inputs (whether or not in order toinfluence the Benchmark levels),
including, without limitation, throughappropriate remuneration policies andby effectively addressing conflicts ofinterest which may exist between the
Submitter’s Submission activities(including all staff who perform orotherwise participate in Benchmark
Submission responsibilities), and anyother business of the Submitter or of anyof its affiliates or any of their respective
clients or customers.

15. Internal
Controls over
Data Collection

When an Administrator collects datafrom any external source theAdministrator should ensure that there
are appropriate internal controls over its
data collection and transmission

CBA has in place an agreement with CME
Inc. regarding the collection of input datafrom the regulated market on which the
futures contracts are traded, andtransmission of input data to CBA, and23© 2023 CME Group. All rights reserved.

IOSCO Principle

16.Complaints
Procedures

IOSCO Principles - Detailed Guidance
processes. These controls should
address the process for selecting thesource, collecting the data andprotecting the integrity andconfidentiality of the data. Where
Administrators receive data from
employees of the Front Office Function,
the Administrator should seek
corroborating data from other sources.
The Administrator should establish andPublish or Make Available a written
complaints procedures policy, by which
Stakeholders may submit complaints
including concerning whether a specific
Benchmark determination isrepresentative of the underlying Interest
it seeks to measure, applications of the
Methodology in relation to a specific
Benchmark determination(s) and other
Administrator decisions in relation to a
Benchmark determination.
The complaints procedures policy should:a)Permit complaints to be submitted
through a user-friendly complaints
process such as an electronic
Submission process;b)
Contain procedures for receiving
and investigating a complaint madeabout the Administrator’s Benchmark
determination process on a timely andfair basis by personnel who are
independent of any personnel who may
be or may have been involved in thesubject of the complaint, advising thecomplainant and other relevant partiesof the outcome of its investigation withina reasonable period and retaining all
records concerning complaints;c)
Contain a process for escalatingcomplaints, as appropriate, to the
Administrator’s governance body; andd) Require all documents relating to acomplaint, including those submitted by
the complainant as well as the
Administrator’s own record, to beretained for a minimum of five years,
subject to applicable national legal or
regulatory requirements.
Disputes about a Benchmarking
determination, which are not formal
complaints, should be resolved by the
Administrator by reference to its
standard appropriate procedures. If acomplaint results in a change in a

CME Group Benchmark Administration
Limited (CBA) Comment
contains an obligation to comply with
protocols in relation to the same that
protect the integrity and confidentiality of
the input data.

CBA has in place policies and procedures
for Stakeholders to submit complaints on
all aspects of the Benchmark determination
process. These policies are available on
the CME Group website

CBA has created an email address(internationalcompliance@cmegroup.com)
to receive and respond to any complaints.
All complaints received will be investigatedby personnel who are independent of any
personnel who may be, or may have been
involved in the subject of the complaint.
Any outcomes are reported back to thecomplainant Stakeholder within areasonable timeframe (proportionate to thenature of the complaint). All records
concerning complaints are kept for a periodof 5 years.

Complaints will also be reported to theOversight Committee and CBA board.
CME Group maintains a record of allcomplaints for 5 years in accordance with
its regulatory obligations.

Changes to the CME Group Petroleum
Index Benchmark Methodology will bemade in accordance with Principle 12.

24© 2023 CME Group. All rights reserved.

IOSCO Principle

17.Audits

18.Audit Trail

IOSCO Principles - Detailed Guidance
Benchmark determination, that should
be Published or Made Available to
Subscribers and Published or Made
Available to Stakeholders as soon as
possible as set out in the Methodology.
The Administrator should appoint an
independent internal or external auditor
with appropriate experience andcapability to periodically review andreport on the Administrator’s adherence
to its stated criteria and with the
Principles. The frequency of audits
should be proportionate to the size andcomplexity of the Administrator’soperations.
Where appropriate to the level ofexisting or potential conflicts of interest
identified by the Administrator (except
for Benchmarks that are otherwise
regulated or supervised by a National
Authority other than a relevant
Regulatory Authority), an Administrator
should appoint an independent external
auditor with appropriate experience andcapability to periodically review andreport on the Administrator’s adherence
to its stated Methodology. The
frequency of audits should be
proportionate to the size and complexityof the Administrator’s Benchmark
operations and the breadth and depth of
Benchmark use by Stakeholders.
Written records should be retained by
the Administrator for five years, subject
to applicable national legal or regulatory
requirements on:a) All market data, Submissions and anyother data and information sources
relied upon for Benchmark
determination;b) The exercise of Expert Judgment
made by the Administrator in reaching a
Benchmark determination;c) Other changes in or deviations fromstandard procedures andMethodologies, including those madeduring periods of market stress or
disruption;d)
The identity of each person
involved in producing a Benchmark
determination; andCME Group Benchmark Administration
Limited (CBA) Comment

CBA is authorised and supervised by the
FCA (UK) and undergoes a regular internal
audit in accordance with its regulatory
requirements. External audits can berequested at any time by the CBA Board,
the Oversight Committee or the internal
audit function.

CME Group retains all records below for aminimum of 5 years.

All input data used in the calculation of the
CME Group Petroleum Index are includedin the record retention policy.
N/A – Expert Judgement is not used todetermine the CME Group Petroleum
Index.
Any deviations from standard procedures
due to market stress or disruption will be
logged and included in the retention policy.

The identity of individuals responsible forthe calculation of the CME Group
Petroleum Index are logged and includedin the record retention policy.

25© 2023 CME Group. All rights reserved.

IOSCO Principle

IOSCO Principles - Detailed Guidancee)
Any queries and responses
relating to data inputs.
If these records are held by a RegulatedMarket or Exchange the Administrator
may rely on these records forcompliance with this Principle, subject toappropriate written record sharing
agreements.
When a Benchmark is based on
Submissions, the following additional
Principle also applies:
Submitters should retain records for five
years subject to applicable national legal
or regulatory requirements on:a)
The procedures andMethodologies governing theSubmission of inputs;b)
The identity of any other person
who submitted or otherwise generated
any of the data or information provided
to the Administrator;c)Names and roles of individuals
responsible for Submission andSubmission oversight;d) Relevant communications between
submitting parties;e) Any interaction with the Administrator;

19. Cooperation
with Regulatory
Authoritiesf) Any queries received regarding data
or information provided to the
Administrator;g)
Declaration of any conflicts ofinterests and aggregate exposures to
Benchmark related instruments;h)Exposures of individual
traders/desks to Benchmark related
instruments in order to facilitate audits
and investigations; andi) Findings of external/internal audits,
when available, related to Benchmark
Submission remedial actions andprogress in implementing them.
Relevant documents, Audit Trails andother documents subject to these
Principles shall be made readily
available by the relevant parties to therelevant Regulatory Authorities incarrying out their regulatory or
supervisory duties and handed overpromptly upon request.

CME Group Benchmark Administration
Limited (CBA) Comment
All queries and responses will be logged
and included in the record retention policy.

N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions

N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions
N/A - The CME Group Petroleum Index isnot based on Submissions

N/A - The CME Group Petroleum Index isnot based on Submissions

CBA is an authorised Benchmark
Administrator, authorised and supervisedby the FCA (UK) and will cooperate withappropriate requests from regulatory
authorities having competent jurisdiction
over CBA as requested.

26© 2023 CME Group. All rights reserved.

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