Bloomberg
Index Services
LimitedBenchmark Statement for
Bloomberg BFIXBloomberg Index Services Limited

A Bloomberg Professional Services offering

This benchmark statement (this “Statement”) is provided by Bloomberg Index Services Limited (“BISL” and, with its affiliates,“Bloomberg”) as the administrator of the Bloomberg BFIX (the “Benchmark” ) and is intended to meet the requirements ofthe European Union’s regulation on indices used as benchmarks in financial instruments and financial contracts or tomeasure the performance of investment funds (Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8June 2016, herein the “BMR”), including the regulatory technical standards (“RTS”) promulgated thereunder, as and to theextent the EU BMR and related RTS were “on-shored” in the UK from 1 January 2021 (the “BMR”).
.
Requirement [Regulatory
Reference](1)

Benchmark Family Information

General disclosure
requirements

The benchmark statement shallstate:

Date of publication:
31 October 2019(a) the date of publicationof the statement and,
where applicable, the dateof its last update;

Date of last update:
22 December 2023(b) where available, theinternational securities
identification number(ISIN) of the benchmark or
benchmarks; alternatively,
for a family of benchmarks,
the statement may provide
details of where the ISINs
are publicly accessible freeof charge;

BISL does not assign ISINs to all of the Indices.

(c) whether the benchmark,or any benchmark in thefamily of benchmarks, isdetermined using
contributions of input data;

The Indices do not utilize contributions of input data.

(d) whether the benchmark
or any benchmark in thefamily of benchmarks
qualifies as one of thetypes of benchmarks listed
under Title III of Regulation(EU) 2016/1011, including
the specific provision by
virtue of which thebenchmark qualifies as that
type.

None of the Indices are ‘regulated-data benchmarks’, ‘interest rate benchmarks’or ‘commodity benchmarks’ as those terms are defined in the BMR. In addition,none of the Indices are ‘critical benchmarks’ or ‘significant benchmarks’ as thoseterms are defined in the BMR. All of the Indices would be deemed ‘nonsignificant’.

Users should be aware that ISINs may have been obtained on the Indices by third
parties and, in doing so, such third parties may have supplied inaccurate or
incomplete information with regard to the underlying Index or may have obtained
multiple ISINs for the same Index. Users should contact BISL if they have questions
regarding the proper identification of its Indices.
BISL does assign a unique Financial Instrument Global Identifier (“FIGI”) to its
Indices. FIGIs may be found at https://openfigi.com/ by searching for the relevant
Index within the family.

[RTS 1(1)]Global Family of Indices2

Bloomberg Index Services Limited(2)

The benchmark statement shallclearly and unambiguously
define the market or economic
reality measured by the
benchmark and thecircumstances in which suchmeasurement may become
unreliable.
[BMR 27(1)(a)]In defining the market or
economic reality, thebenchmark statement shall
include at least the following
information:(a) a general description of themarket or economic reality.

A Bloomberg Professional Services offering

Market or economic reality measured by the benchmark family:
The Bloomberg BFIX (“BFIX” or the “Benchmark”), provides Spot, Forward and
Non-Deliverable Forward (“NDF”) rate fixings for certain currencies and metals.
As used in this benchmark statement, the term "fixings" refers only to such Spot,
Forward and NDF rates and not to any other rate, calculation or other informationthat may be related to, or associated with, such fixings that are made available byBloomberg. Based on pricing provided by the Bloomberg Generic Price (“BGN”)
and Bloomberg Generic Price Executable ("BGNE"), BFIX is made broadly
available to the investment community with the objective of providing FX fixings
that are reliable, representative, and transparent for the currency and metals
markets around the world.
The BFIX Index methodology is available here.

Participants in the foreign exchange (FX) markets underlying the fixings include
central banks and national governments, banks and other financial institutions,
corporates engaged in hedging activities and speculative traders. The FX
market trades approximately $5 trillion per day.

(b) the geographicalboundaries, if any, of themarket or economic reality;(c) any other information thatthe administrator reasonably
considers to be relevant or
useful to help users or
potential users of thebenchmark to understand therelevant features of the market
or economic reality, including
at least the following elements
insofar as reliable data on
these elements is available:(i) information on actual or
potential participants inthe market;(ii) an indication of the sizeof the market or economic
reality.
[RTS 1(2)]Global Family of Indices3

Bloomberg Index Services Limited(3)

In defining the potential
limitations of the benchmark
and the circumstances inwhich the measurement of themarket or economic reality
may become unreliable, thebenchmark statement shall
include at least:(a) a description of thecircumstances in which theadministrator would lacksufficient input data to
determine the benchmark inaccordance with themethodology;(b) where relevant, adescription of instances when
the accuracy and reliability ofthe methodology used for
determining the benchmark
can no longer be ensured,
such as when theadministrator deems theliquidity in the underlying
market as insufficient;

A Bloomberg Professional Services offering

Benchmark Limitations:Though the Benchmark is designed to be representative of the markets theymeasure or otherwise align with their stated objective, they may not be
representative in every case or achieve their stated objective in all instances. It is
designed and calculated strictly to follow the rules of the methodology, and any
BFIX fixing or other output is limited in its usefulness to such design andcalculation.
Markets can be volatile, including those market interests which the Benchmark
intends to measure or upon which the Benchmark is dependent in order toachieve its stated objective. For example, illiquidity can have an impact on thequality or amount of data available to the Administrator for calculation and may
cause the Benchmark to produce unpredictable or unanticipated results.
In addition, market trends and changes to market structure may render theobjective of the unachievable or to become impractical to replicate by investors.
In particular, the BFIX is designed to represent the current value of the underlying
currency pairs. FX markets are subject to a variety of risks and potential limitations,
including the widespread use of leverage in FX trading, political risk associatedwith governments controlling (or attempting to control) the value of theircurrencies, appreciation/devaluation risks and interest rate risk. For certain
markets, the BFIX is subject to illiquidity and low transaction volumes.

(c) any other information thatthe administrator reasonably
considers to be relevant or
useful to help users andpotential users to understandthe circumstances in which themeasurement of the market or
economic reality may become
unreliable, including adescription of what might
constitute an exceptional
market event.
[RTS 1(3)](4)

The benchmark statement shalllay down technicalspecifications that clearly andunambiguously identify theelements of the calculation of
the benchmark in relation towhich discretion may be
exercised, the criteria
applicable to the exercise ofsuch discretion and theposition of the persons thatcan exercise discretion, and

The Indices are rules-based (methodology available here), and their construction
is designed to consistently produce values without the exercise of expert
judgment or discretion. Nevertheless, BISL may use expert judgment or discretion
with regards to the following:▪
▪
▪

Index restatements
Extraordinary circumstances during a market emergency
Data interruptions, issues, and closures

When expert judgment or discretion is required, BISL undertakes to be consistentin its application, with recourse to written procedures outlined in themethodology of the Indices and internal procedures manuals. In certain

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Bloomberg Index Services Limited

how such discretion may besubsequently evaluated.
[BMR 27(1)(b)]In specifying the controls andrules that govern any exerciseof judgement or discretion by
the administrator or any
contributors in calculating thebenchmark or benchmarks, thebenchmark statement shall
include an outline of each stepof the process for any ex post
evaluation of the use of
discretion, together with aclear indication of the positionof any person(s) responsible
for carrying out theevaluations.

A Bloomberg Professional Services offering

circumstances exercises of expert judgment or discretion are reviewed by senior
members of BISL management and Bloomberg Compliance teams, and arereported to the Product, Risk & Oversight Committee (PROC), BISL’s governancecommittee, which operates under the supervision of BISL’s oversight function, theBenchmark Oversight Committee (BOC). BISL also maintains and enforces a codeof ethics to prevent conflicts of interest from inappropriately influencing index
construction, production, and distribution, including the use of expert judgment
or discretion.

[RTS 1(4)](5)

A benchmark statement shallcontain at least the rationale
for adopting the benchmark
methodology and proceduresfor the review and approval ofthe methodology.
[BMR27(2)(b)]In specifying the procedures
for review of the methodology,
the benchmark statement shallat least outline the proceduresfor public consultation on any
material changes to themethodology.
[RTS 1(5)]The Administrator will review the Benchmark (both the rules of construction anddata inputs) on a periodic basis, not less frequently than annually, to determine
whether they continue to reasonably measure the intended underlying market
interest, the economic reality or otherwise align with their stated objective. Morefrequent reviews may result from extreme market events and/or material changes
to the applicable underlying market interests.
Criteria for data inputs include reliable delivery and active underlying markets. An
active market is defined as one in which (a) BFIX has received from BGN at least
one bid and ask price in the fixing window, and (b) the bid and ask are within 30
seconds of each other. In no event will BFIX take a BGN price that is from a single
source. If no qualified BGN price can be produced within a fixing window, theprevious fix will be carried forward.
Other than as set forth in the methodology, there are no minimum liquidity
requirements for fixing constituents and/or minimum requirements or standards
for the quantity or quality of the input data.
The review will be conducted by product managers of the Benchmark at least
annually or as otherwise appropriate in light of significant market changes or otherdevelopments.
Any resulting change to the Methodology deemed to be material (discussed
below) will be subject to the review of the PROC under the oversight of the BOC,
each of which committees shall be provided all relevant information and materials
it requests relating to the change. Details regarding the PROC and BOC aredescribed below.
BISL’s Index administration is also subject to Bloomberg’s Compliance function
which periodically reviews various aspects of its businesses in order to determine
whether it is adhering to applicable policies and procedures, and assess whether
applicable controls are functioning properly.

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A Bloomberg Professional Services offering

Material changes related to the Benchmark will be made available in advance toaffected stakeholders whose input will be solicited. The stakeholder engagement
will set forth the rationale for any proposed changes as well as the timeframe andprocess for responses. The Administrator will endeavour to provide at least two
weeks for review prior to any material change going into effect. In the event ofexigent market circumstances, this period may be shorter. Subject to requests forconfidentiality, stakeholder feedback and the Administrator’s responses will bemade accessible upon request.
In determining whether a change to a Benchmark fixing is material, the following
factors shall be taken into account:•
The economic and financial impact of the change;•
Whether the change affects the original purpose of the Index; and/or•
Whether the change is consistent with the overall objective of the Index
and the underlying market interest it seeks to measure
In addition to material changes, BISL may from time to time terminate one or more
Indices (“Discontinued Indices”), whether due to changes in market structure, alack of requisite data, insufficient usage, or for other regulatory or practicalconcerns. The process for terminating such Discontinued Indices is as follows:
The PROC will review proposed terminations, taking into account the reasons fortermination, the impact on users (if any), the availability of alternative products andother such factors. If termination is approved, users will be provided as much priornotice as is reasonable under the circumstances, typically 90 days. In the event
there is little or no known usage identified, the Discontinued Indices may beterminated with less (or no) notice, as applicable. In the event the Discontinued
Indices are licensed for use as the basis of an ETF or other widely-available
financial product or is otherwise determined by BISL to be an importantbenchmark without reasonable substitutes, the notice period may be extended,
as warranted. Any advance notice period is subject to BISL being reasonably able
to continue administering and calculating such benchmark during such period (forexample, BISL has access to requisite data on commercially reasonable terms, isnot subject to any litigation or other claims, has adequate internal resources andcapabilities, etc.). Terminations and associated user engagement decisions madeby the PROC are subject to review by BISL's oversight function, the BOC.
BFIX Advisory Councils (BACs)
BFIX Advisory Councils (“BAC”) are composed of key market participants andother influential individuals to assist Bloomberg in setting BFIX priorities, todiscuss potential rules changes and to provide ideas for new products. BACs are
generally constituted on an annual basis. While potential changes are discussed
through this process, all feedback received is non-binding and all final decisions
on benchmark index rules are made by the BOC review after the review period
has ended. Bloomberg is also in constant and ongoing engagement with its users
through various channels, including via help desks, sales personnel and directcommunication with product personnel. To help ensure BFIX remains an accurate
representation of currency and metals markets, it endeavors to meaningfully
incorporate these engagements into improvements in processes and service. This
concept of shared ownership enables Bloomberg to produce the most relevant
fixings and helps ensure responsiveness to user requirements.
(6)

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The benchmark statement shallprovide notice of thepossibility that factors,
including external factors
beyond the control of theadministrator, may necessitatechanges to, or the cessation of
the benchmark.

A Bloomberg Professional Services offering

Users should be aware that factors, including external factors beyond the controlof BISL, may necessitate changes to, or the cessation of the Indices or components
thereof. For example, markets measured by the Benchmark may undergo
structural changes which may affect the liquidity of underlying inputs of the fixingsof the Benchmark. In addition, regulatory changes can adversely impact theeffectiveness of methodology design.

[BMR 27(1)(c)](7)

The benchmark statement shalladvise users that changes to,or the cessation of, thebenchmark may have an
impact upon the financial
contracts and financial
instruments that reference thebenchmark or themeasurement of theperformance of investment
funds.

If financial product issuers or investment managers choose to use one of the
Benchmark as a reference in a financial product or an investment fund, they should
consider the possibility that factors, including external factors, may necessitatechanges to, or the cessation of the Benchmark or components thereof, including
the potential need to terminate or modify the terms of a financial product resulting
from the termination of the calculation of one or more of the Benchmark.

[BMR 27(1)(d)](8)

A benchmark statement shallcontain at least the definitions
for all key terms relating to thebenchmark.

All key terms and other relevant information are set forth in the methodology for
the Benchmark available here.

[BMR 27(2)(a)](9)

The administrator shall review
and, where necessary, update
the benchmark statement foreach benchmark or family ofbenchmarks in the event of any
changes to the information to
be provided under this Article
and at least every two years.

BISL shall review this Statement on a periodic basis, at least once every two years,
or as otherwise warranted in the event of any material changes to the information
provided herein.

[BMR 27(1)]In addition to the cases
referred to in the third
subparagraph of Article 27(1)of Regulation (EU) 2016/1011,
an update of the benchmark
statement shall be required
whenever the information
contained in the statementceases to be correct or
sufficiently precise, andGlobal Family of Indices7

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A Bloomberg Professional Services offering

including in any event in thefollowing cases:(a) whenever there is a change
in the type of the benchmark;(b) whenever there is amaterial change in themethodology used for
determining the benchmark
or, if the benchmark statement
is for a family of benchmarks,
in the methodology used for
determining any benchmark
within the family ofbenchmarks.

[RTS 6](10)

A benchmark statement shallcontain at least the criteria andprocedures used to determine
the benchmark, including adescription of the input data,
the priority given to different
types of input data, theminimum data needed todetermine a benchmark, theuse of any models or methodsof extrapolation and any
procedure for rebalancing theconstituents of a benchmark's
index.

Input Data
As described under “Market or economic reality measured by the benchmark
family” in row (2) above, BFIX fixing calculations are based upon BFIX uses
Bloomberg’s BGN and BGNE as its pricing sources and only accepts quotes that
contain both a bid and ask, which are the most appropriate for FX transaction
pricing.
Criteria for data inputs include reliable delivery and active underlying markets. An
active market is defined as one in which (a) BFIX has received from BGN at least
one bid and ask price in the fixing window, and (b) the bid and ask are within 30
seconds of each other. In no event will BFIX take a BGN price that is from a single
source. If no qualified BGN price can be produced within a fixing window, theprevious fix will be carried forward.

[BMR 27(2)(c)]Interpolation
When calculating cross currency fixings, where it is necessary to align different
settlement dates, BFIX may interpolate between the available BFIX forward tenors
in order to calculate the necessary adjustments to the resultant BFIX.
[For greater detail regarding the criteria and procedures used to determine the
Indices, please refer to the publicly-available methodology for the Indicesavailable here.](11)

A benchmark statement shallcontain at least the controls
and rules that govern any
exercise of judgement or
discretion by the administrator
or any contributors, to ensure
consistency in the use of suchjudgement or discretion.

The Indices are rules-based, and their construction is designed to consistently
produce values without the exercise of expert judgment or discretion.
Nevertheless, BISL may use expert judgment or discretion with regards to thefollowing:• Index restatements• Extraordinary circumstances during a market emergency• Data interruptions, issues, and closures

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Bloomberg Index Services Limited[BMR27(2)(d)]For the purpose of providing
information on the controls
and rules that govern any
exercise of judgment or
discretion in the calculation of
the benchmark or of the familyof benchmarks, the benchmark
statement shall at least:

A Bloomberg Professional Services offering

When expert judgment or discretion is required, BISL undertakes to be consistentin its application, with recourse to written procedures outlined in the methodologyof the Indices and internal procedures manuals. In certain circumstances exercisesof expert judgment or discretion are reviewed by senior members of BISL
management and Bloomberg Compliance teams, and are reported to the PROC,BISL’s governance committee, which operates under the supervision of BISL’s
oversight function, the BOC. BISL also maintains and enforces a code of ethics toprevent conflicts of interest from inappropriately influencing index construction,
production, and distribution, including the use of expert judgment or discretion.

(a) indicate the position ofeach function or body who
may exercise discretion;(b) outline each step of the expost evaluation process for theuse of discretion.
[RTS 27(1)(4)](12)

A benchmark statement shallcontain at least the procedures
which govern thedetermination of thebenchmark in periods of stressor periods where transaction
data sources may beinsufficient, inaccurate or
unreliable and the potential
limitations of the benchmark insuch periods.

See “Benchmark Limitations” in row (3) above.

[BMR 27(2)(e)](13)

A benchmark statement shallcontain at least the proceduresfor dealing with errors in input
data or in the determination of
the benchmark, including
when a re-determination of thebenchmark is required.
[BMR 27(2)(f)]Periods of inability to provide a fixing are generally dictated by anticipatedperiods where there is no active market, such as holidays or off-trading hours forless frequently traded currencies. Bloomberg has robust controls and proceduresin place to minimize unanticipated fixing failures and their impact. In the event ofsuch an unanticipated failure, BFIX would determine whether the event occurred
during an active market. If so, BFIX will endeavour to publish the fixing or revised
fixing as soon as practicable. If no qualified BGN or BGNE price can be produced
within a fixing window, the previous fix will be carried forward.
BISL makes every effort to provide accurate calculation of BFIX fixings. However,to the extent a material error in a fixing is uncovered following its publication anddissemination, a notification will be sent to BFIX clients alerting them of such error
and the expected date of a revised publication, if warranted. BISL considers thefollowing factors to determine whether to restate. Not all conditions need to bepresent to warrant a restatement, and certain factors may be more determinativethat others depending on the circumstances of the given error.
A.

The relative importance of the data field impacted by the error;

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A Bloomberg Professional Services offering

B.
C.
D.
E.
F.

When the error occurred and when it was discovered;
The number of fixings affected;
Whether the impacted fixings are linked to tradable products;
The magnitude of the error;
The burden of restatement on client re-processing relative to the impactof the error;
G. The impact of the restatement on analytical tools.
Any decisions to amend and/or republish a BFIX rate will be reported to the PROC
after implementation.
Bloomberg reserves the right not to amend or republish any BFIX rate after the
publication of the rate for the same currency on the following business day in the
United States of America.
Bloomberg will retain records relating to any amendment to or republication of a
BFIX rate for a minimum period of 5 years.
(14)

A benchmark statement shallcontain at least theidentification of potential
limitations of the benchmark,including its operation in
illiquid or fragmented markets
and the possible concentrationof inputs.

See “Benchmark Limitations” in row (3) above.

[BMR 27(2)(g)](15)

Specific disclosure
requirements for regulated
data benchmarks.

Not applicable.

In addition to the information
to be included pursuant to
Article 1, for a regulated-databenchmark or, whereapplicable, family of regulateddata benchmarks, thebenchmark statement shallstate at least the following in its
description of the input data:(a) the sources of the input
data used;(b) for each source, therelevant type , as listed in
Article 3(1)(24) of Regulation(EU) 2016/1011.
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Specific disclosure
requirements for interest
rate benchmarks

A Bloomberg Professional Services offering

Not applicable.

1. In addition to the information
to be included pursuant to
Article 1, for an interest ratebenchmark or, whereapplicable, family of interest
rate benchmarks, thebenchmark statement shall
include at least the following
information:(a) a reference alerting users to
the additional regulatory
regime applicable to interest
rate benchmarks under Annex
I to Regulation (EU) 2016/1011;(b) a description of thearrangements that have been
put in place to comply withthat Annex.
[RTS 3](17)

Specific disclosure
requirements for commodity
benchmarks

Not applicable.

In addition to the information
to be included pursuant to
Article 1, for a commodity
benchmark or, whereapplicable, family ofcommodity benchmarks, thebenchmark statement shall at
least:(a) indicate whether therequirements of Title II of, orAnnex II to, Regulation (EU)2016/1011 apply to thebenchmark, or family ofbenchmarks as prescribed by
Article 19 of that Regulation;(b) include an explanation as
to why Title II of or, as the casemay be, Annex II to that
Regulation applies;(c) include in the definitions of
key terms a concise

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A Bloomberg Professional Services offering

description of the criteria thatdefine the relevant underlying
physical commodity;(d) where applicable, indicate
where the explanations are
published that theadministrator is required to
publish under paragraph 7 ofAnnex II to that Regulation.
[RTS 4](18)

Specific disclosure
requirements for criticalbenchmarks

Not applicable.

In addition to the information
to be included pursuant to
Article 1, for a criticalbenchmark, or, whereapplicable, a family ofbenchmarks that contains atleast one critical benchmark,the benchmark statement shall
include at least the following
information:(a) a reference alerting users
to the enhanced regulatory
regime applicable to criticalbenchmarks under Regulation(EU) 2016/1011;(b) a statement indicating how
users will be informed of any
delay in the publication of thebenchmark or of any redetermination of thebenchmark, and indicating the(expected) duration of
measures.
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A Bloomberg Professional Services offering“BLOOMBERG®”, BLOOMBERG INDICES, BIX and the names of the other fixings that are part of the Bloomberg currency
and metals family of fixings (collectively referred to as “Bloomberg BFIX” (the “Indices”) are trademarks or service marks ofBloomberg Finance L.P. Bloomberg Finance L.P. and its affiliates, including Bloomberg Index Services Limited, theadministrator of the Indices (collectively, “Bloomberg”) or Bloomberg's licensors own all proprietary rights in the Indices.
Bloomberg does not guarantee the timeliness, accuracy or completeness of any data or information relating to the Indices.
Bloomberg makes no warranty, express or implied, as to the Indices or any data or values relating thereto or results to beobtained therefrom, and expressly disclaims all warranties of merchantability and fitness for a particular purpose withrespect thereto. It is not possible to invest directly in an Index. Back-tested performance is not actual performance. Past
performance is not an indication of future results. To the maximum extent allowed by law, Bloomberg, its licensors, and its
and their respective employees, contractors, agents, suppliers and vendors shall have no liability or responsibility
whatsoever for any injury or damages - whether direct, indirect, consequential, incidental, punitive or otherwise - arising inconnection with the Indices or any data or values relating thereto - whether arising from their negligence or otherwise. This
document constitutes the provision of factual information, rather than financial product advice. Nothing in the Indices shallconstitute or be construed as an offering of financial instruments or as investment advice or investment recommendations(i.e., recommendations as to whether or not to “buy”, “sell”, “hold”, or to enter or not to enter into any other transaction
involving any specific interest or interests) by Bloomberg or a recommendation as to an investment or other strategy byBloomberg. Data and other information available via the Indices should not be considered as information sufficient uponwhich to base an investment decision. All information provided by the Indices is impersonal and not tailored to the needs ofany person, entity or group of persons. Bloomberg does not express an opinion on the future or expected value of any
security or other interest and do not explicitly or implicitly recommend or suggest an investment strategy of any kind.
Customers should consider obtaining independent advice before making any financial decisions. © 2022 Bloomberg. All
rights reserved. This document and its contents may not be forwarded or redistributed without the prior consent of
Bloomberg.

The BLOOMBERG TERMINAL service and Bloomberg data products (the “Services”) are owned and distributed byBloomberg Finance L.P. (“BFLP”) except (i) in Argentina, Australia and certain jurisdictions in the Pacific islands, Bermuda,
China, India, Japan, Korea and New Zealand, where Bloomberg L.P. and its subsidiaries distribute these products, and (ii) in
Singapore and the jurisdictions serviced by Bloomberg’s Singapore office, where a subsidiary of BFLP distributes theseproducts.

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A Bloomberg Professional Services offering

Annex 1 – Climate-Related Disclosures

EXPLANATION OF HOW ESG FACTORS ARE REFLECTED IN THE
BENCHMARK STATEMENTSECTION 1 – CONSIDERATION OF ESG FACTORS
Item 1. Name of the benchmark
administrator.
Item 2. Type of benchmark or family ofbenchmarks.

Bloomberg Index Services Limited

Other Benchmarks

Item 3. Name of the benchmark or family BFIX
of benchmarks.
Item 4. Are there in the portfolio of thebenchmark administrator any EU
Climate Transition Benchmarks, EU
Paris-aligned Benchmarks, benchmarksthat pursue ESG objectives orbenchmarks that take into account ESG
factors?

Yes

Item 5. Does the benchmark or family ofbenchmarks pursue ESG objectives?

No

Item 6. Where the response to Item 5 is positive, provide below the details (score) in relation to the following
ESG factors: combined ESG factors, environmental, social and governance for each family of benchmarks at an
aggregated level.
The ESG factors shall be disclosed at an aggregated weighted average value at the level of the family ofbenchmarks.
a) List of combined ESG factors:

Details on each ESG factor: N/Ab) List of environmental factors:

Details on each ESG factor: N/Ac) List of social factors:

Details on each ESG factor: N/Ad) List of governance factors:

Details on each ESG factor: N/A

Item 7. Where the response to Item 5 is positive, provide below the details (score) for the benchmark or family ofbenchmarks, in relation the following ESG factors: combined ESG factors, environmental, social and governance,
depending on the relevant underlying asset concerned.
Alternatively, all of this information may be provided in the form of a hyperlink to a website of the benchmark
administrator included in the benchmark statement. The information on the website shall be easily available andaccessible. Benchmark administrators shall ensure that information published on their website remains available
for five years.
The score of the ESG factors shall not be disclosed for each constituent of the benchmark, but shall be disclosed
at an aggregated weighted average value of the benchmark.

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Bloomberg Index Services Limited

A Bloomberg Professional Services offeringa) List of combined ESG factors:

Details on each ESG factor: N/Ab) List of environmental factors:

Details on each ESG factor: N/Ac) List of social factors:

Details on each ESG factor: N/Ad) List of governance factors:

Details on each ESG factor: N/A

Hyperlink to the information on ESG
factors for the benchmark or family ofbenchmarks:

N/A

Item 8. Data and standards used.
a) Description of data sources used toprovide information on the ESG factors inthe benchmark statement.

N/A

Describe how the data used to provide
information on the ESG factors in thebenchmark statement are sourced andwhether, and to what extent, data are
estimated or reported.

b) Reference standards.

N/A

List the supporting standards used forthe reporting under item 6 and/or item 7.

SECTION 2 – ADDITIONAL DISCLOSURE REQUIREMENTS FOR EU CLIMATE
TRANSITION AND EU PARIS-ALIGNED BENCHMARKS
Item 9. Where a benchmark is labelled as ‘EU Climate Transition Benchmark’ or ‘EU Paris-aligned
Benchmark’, benchmark administrators shall also disclose the following information:a)forward-looking year-on-year
decarbonisation trajectory;b) degree to which the IPCC
decarbonisation trajectory (1,5°C
with no or limited overshoot) has
been achieved on average per
year since creation;c)overlap between those benchmarks
and their investable universe, as
defined in Article 1, point (e), of
Commission DelegatedRegulation

N/A

N/A

N/A

(EU) 2020/1818, using the active
share at asset level.

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A Bloomberg Professional Services offering

SECTION 3 – DISCLOSURE OF THE ALIGNMENT WITH THE OBJECTIVES OF THE PARISAGREEMENT
Item 10. By the date of application of this Regulation, for significant equity and bond benchmarks, EU
Climate Transition Benchmarks and EU Paris-aligned Benchmarks, benchmark administrators shall, for eachbenchmark, or where applicable, the family of benchmarks, disclose the following information:
Noa) Does the benchmark align with thetarget of reducing carbon
emissions or the attainment of theobjectives of the Paris Agreement;

Not applicable. The benchmark is not aligned with the target ofb) the temperature scenario, in
reducing carbon emissions or the attainment of the objectives of theaccordance with international
Paris Agreement and therefore no temperature scenario is used.
standards, used for the alignment
with the target of reducing GHG
emissions or the attainment of theobjectives of the Paris Agreement;
Not applicable. There is no temperature scenario provider as noc) the name of the provider of thetemperature scenario is used.
temperature scenario used for thealignment with the target of
reducing GHG emissions or theattainment of the objectives of theParis Agreement;d) the methodology used for themeasurement of the alignment
with the temperature scenario;e)the hyperlink to the website of thetemperature scenario used.

Date on which information has last
been updated and reason for the
update:Not applicable. The benchmark does not use a methodology tomeasure alignment with a temperature scenario as no temperature
scenario is used
Not applicable. There is no temperature scenario used.

28 January 2022. Update of Section 3 disclosures.

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