February 2024

Benchmark Regulation FAQ
Refinitiv Benchmark Services (UK) Limited (RBSL)

London Stock Exchange Group (“LSEG”) is a leading global financial markets infrastructure and data provider, trusted to deliver
excellence by customers, partners and markets around the world. We play a vital social and economic role in the world’s financialsystem. With our trusted expertise and global scale, we enable the sustainable growth and stability of our customers and theircommunities.
LSEG offers benchmark and index solutions through FTSE Russell. FTSE Russell is a global index provider of benchmarks,analytics, and data with capabilities across asset classes. FTSE Russell’s indices are used by clients to inform asset allocation
decisions, support portfolio construction and conduct risk and performance analysis. FTSE Russell has two authorised benchmark
administrators:••

FTSE International Limited (“FIL”) is authorised in the UK by the FCA under the UK Benchmark Regulation (“UK BMR”);
andRBSL is authorised in the UK by the FCA under the UK BMR and designated as a benchmark administrator for CDOR
under the Canadian Securities Administrators Benchmark Rule (“CSA Benchmark Rule”) and Ontario Securities
Commission Rule 25-101 (“OSC Rule”). For the list of benchmarks currently administered by RBSL please visit FTSE
Russell benchmarks (the “RBSL Benchmarks”).

What is UK Benchmark Regulation (UK BMR)?
The FCA describes UK BMR as:
Legislation that regulates the provision of, contribution to and use of a wide set of benchmarks.
The Benchmarks Regulation (BMR) aims to ensure benchmarks are robust and reliable, and to minimise conflicts of interest inbenchmark-setting processes. UK BMR is the onshored EU regulation (EU BMR), which builds on the IOSCO Principles for
Financial Benchmarks and applies to any benchmark used within the UK.
The legislation affects three broad groups:–Benchmark Administrators – a company that provides benchmarks–

Supervised Contributors – a company provides data specifically for the calculation of a benchmark–Benchmark Users – a market participant using a benchmark for one of the uses defined below. Benchmark Users must not use
benchmarks in the UK unless the benchmark is provided by an authorised/registered UK administrator or has been endorsed,
recognised, or an equivalence decision has been adopted.

More information is available on FCA website.

What does UK BMR affect?
UK BMR affects all published indices ‘used’ in the UK in financial instruments, financial contracts, or by funds.
UK BMR makes a distinction between an Index and Benchmark. An Index is any figure that is published or made available to thepublic and which is regularly determined by the application of a formula or other method of calculation on the basis of the value ofone or more underlying assets or prices. A Benchmark is a specific subset of Indices, and in addition to fulfill the requirements to beBenchmark Regulation – FAQ

an Index, must fulfill certain requirements to be caught by the Regulation. An Index is considered a Benchmark if and only if it is‘used’ to:–Determine the amount payable under a financial instrument or financial contract;–

Determine the value of a financial instrument;–

Measure the performance of an investment fund for the purpose of:–tracking the return;–defining the asset allocation or a portfolio; or–computing the performance fees.

For more definition and guidance on the definition of usage under the UK BMR, please refer to Article 3(7) of the onshored EU BMR
as well as ESMA’s Q&As.

Does UK BMR affect more than just benchmarks?
UK BMR affects all data points that fulfill the definition of an Index and that are used for one of the cases defined as a Benchmark.
Those using an Index as a Benchmark in the UK must ensure that it is administered by an authorised Benchmark Administrator.
Entities providing an Index that will be considered a Benchmark must ensure the benchmarks can be used in the UK. If an entity thatowns or calculates a benchmark is not authorised, we are happy to discuss options to ensure that the benchmark is UK BMR compliant.

What does UK BMR mean for Benchmark Users?
As a Benchmark User, the regulation may mean you need to look for alternative indices and benchmarks to continue yourinvestments, trading or investment processes.
Our guidance is to conduct an inventory of all the benchmarks or data points you use as a benchmark for transactional purposes
within the UK. Then look to the FCA Register for confirmation on whether the provider of the data is approved as an authorised
Benchmark Administrator.

Does the legislation only affect the UK?
No, the definition of benchmarks and their usage is not region specific thus creating two categories based on where theadministrator is located, namely UK benchmarks and third-country benchmarks.
Therefore, if a third-country benchmark is used within the UK it also needs to adhere to the regulation.
Both the EU BMR and UK BMR provide third country transition periods during which third country (non-EU and non-UK,respectively) administrators can continue providing benchmarks for use by EU and UK supervised entities, respectively. Currently,
the EU BMR and UK BMR transition periods are due to expire after 31 December 2025 and 2030, respectively.
Please note that UK BMR is an onshored EU regulation (EU BMR), which is similar legislation but for the EU.

How can FTSE Russell help?
Central banks, national regulators and local authorities around the world look to FTSE Russell as the pre-eminent provider ofbenchmarks. RBSL is one of FTSE Russell’s authorised benchmark administrators under the UK Benchmark Regulation.
By becoming an authorised administrator in July 2018, initially under EU BMR, we were one of the first index and benchmark service
providers able to provide BMR compliant benchmarks and BMR compliant solutions.

FTSE Russell

2

Benchmark Regulation – FAQ

What is RBSL?
RBSL is a benchmark administrator and currently administers the following benchmarks:–WMR London 4pm Closing Spot Rates, WMR Spot, Forward and NDF benchmark rates;–Canadian Dollar Offered Rate (“CDOR”);–Saudi Arabian Interbank Offered Rate (“SAIBOR”) and Saudi Arabian Interbank Bid Rate (“SAIBID”);–

FTSE/CoreCommodity CRB® Index;–FTSE Convertible Indices;–FTSE Term SONIA (“RTS”);–

Tokyo Swap Rates;–FTSE USD IBOR Cash Fallbacks; and–FTSE Term €STR.

What are the Transition Provisions?
Since authorisation in 2018, RBSL was listed on the ESMA Register for Benchmark Administrators. In accordance with ESMA’s
public statement on 1 October 2020, at the end of the Brexit transition period (31 December 2020), UK Benchmark Administrators(including RBSL) have been removed from the ESMA register and are now third country administrators under the EU Benchmark
Regulation (‘EU BMR’).
However, EU BMR provided a third-country transition period during which third country administrators (including RBSL) can continue
providing benchmarks (including all RBSL benchmarks) for use by EU supervised entities. The EU transition period expires on 31
December 2025.
This does not affect RBSL’s authorisation with the UK FCA as a UK Benchmark Administrator, and RBSL will continue to appear on
the UK FCA Register. In accordance to the FCA’s public statement on 1 December 2020, at the end for the Brexit transition period(31 December 2020), UK benchmark administrators (including RBSL) are now listed on the FCA’s new Benchmark Register.
Similarly, UK BMR provided a third-country transition period during which third country administrators can continue providing
benchmarks for use by UK supervised entities. The UK transition period is currently until 31 December 2030.

What do we mean by ‘measure the performance of an investment fund’ in theBMR disclaimer?
As the BMR indicates, the measurement of the performance of an investment fund should be understood as a measurement for thepurpose of tracking the return of an index, defining the asset allocation of a portfolio or computing performance fees.

What is RBSL’s commitment post Brexit?
RBSL intends to make its FCA regulated benchmarks available to supervised users in the EU following the end of the third country
transitional period, which expires on until 31 December 2025.
RBSL maintains a clear commitment to its users of its benchmarks that it shall continue to provide benchmarks within the EU postBrexit. The transition period will enable RBSL to ensure regulatory permission is gained under EU BMR before the end of the period.

More Questions?
For any generic BMR related questions, please email: EUBMR1@lseg.com.
For any specific queries regarding the BMR disclaimer, please email: EUBMRdisclaimerqueries@lseg.com

FTSE Russell

3

ABOUT FTSE RUSSELL
FTSE Russell is a leading global provider of index and benchmark solutions, spanning diverse asset classes and investment objectives. As a trusted
investment partner we help investors make better-informed investment decisions, manage risk, and seize opportunities.
Market participants look to us for our expertise in developing and managing global index solutions across asset classes. Asset owners, asset
managers, ETF providers and investment banks choose FTSE Russell solutions to benchmark their investment performance and create investment
funds, ETFs, structured products, and index-based derivatives. Our clients use our solutions for asset allocation, investment strategy analysis andrisk management, and value us for our robust governance process and operational integrity.
For over 35 years we have been at the forefront of driving change for the investor, always innovating to shape the next generation of benchmarks
and investment solutions that open up new opportunities for the global investment community.
CONTACT US
To learn more, visit lseg.com/ftse-russell; email info@ftserussell.com; or call your regional Client Service team office:
EMEA +44 (0) 20 7866 1810

Asia-PacificNorth America +1 877 503 6437

Hong Kong +852 2164 3333
Tokyo +81 3 6441 1430
Sydney +61 (0) 2 7228 5659Disclaimer© 2024 London Stock Exchange Group plc and its applicable group undertakings (“LSEG”). LSEG includes (1) FTSE International Limited (“FTSE”), (2) Frank Russell Company(“Russell”), (3) FTSE Global Debt Capital Markets Inc. and FTSE Global Debt Capital Markets Limited (together, “FTSE Canada”), (4) FTSE Fixed Income Europe Limited (“FTSE FIEurope”), (5) FTSE Fixed Income LLC (“FTSE FI”), (6) FTSE (Beijing) Consulting Limited (“WOFE”) (7) Refinitiv Benchmark Services (UK) Limited (“RBSL”), (8) Refinitiv Limited (“RL”)
and (9) Beyond Ratings S.A.S. (“BR”). All rights reserved.
FTSE Russell® is a trading name of FTSE, Russell, FTSE Canada, FTSE FI, FTSE FI Europe, WOFE, RBSL, RL, and BR. “FTSE®”, “Russell®”, “FTSE Russell®”, “FTSE4Good®”,“ICB®”, “Refinitiv”, “Beyond Ratings®”, “WMR™”, “FR™” and all other trademarks and service marks used herein (whether registered or unregistered) are trademarks and/or service
marks owned or licensed by the applicable member of LSEG or their respective licensors and are owned, or used under licence, by FTSE, Russell, FTSE Canada, FTSE FI, FTSE FI
Europe, WOFE, RBSL, RL or BR. FTSE International Limited is authorised and regulated by the Financial Conduct Authority as a benchmark administrator. Refinitiv Benchmark
Services (UK) Limited is authorised and regulated by the Financial Conduct Authority as a benchmark administrator.
All information is provided for information purposes only. All information and data contained in this publication is obtained by LSEG, from sources believed by it to be accurate andreliable. Because of the possibility of human and mechanical inaccuracy as well as other factors, however, such information and data is provided “as is” without warranty of any kind.
No member of LSEG nor their respective directors, officers, employees, partners or licensors make any claim, prediction, warranty or representation whatsoever, expressly or impliedly,
either as to the accuracy, timeliness, completeness, merchantability of any information or LSEG Products, or of results to be obtained from the use of LSEG products, including but notlimited to indices, rates, data and analytics, or the fitness or suitability of the LSEG products for any particular purpose to which they might be put. The user of the information assumes
the entire risk of any use it may make or permit to be made of the information.
No responsibility or liability can be accepted by any member of LSEG nor their respective directors, officers, employees, partners or licensors for (a) any loss or damage in whole or inpart caused by, resulting from, or relating to any inaccuracy (negligent or otherwise) or other circumstance involved in procuring, collecting, compiling, interpreting, analysing, editing,transcribing, transmitting, communicating or delivering any such information or data or from use of this document or links to this document or (b) any direct, indirect, special,consequential or incidental damages whatsoever, even if any member of LSEG is advised in advance of the possibility of such damages, resulting from the use of, or inability to use,such information.
No member of LSEG nor their respective directors, officers, employees, partners or licensors provide investment advice and nothing in this document should be taken as constituting
financial or investment advice. No member of LSEG nor their respective directors, officers, employees, partners or licensors make any representation regarding the advisability ofinvesting in any asset or whether such investment creates any legal or compliance risks for the investor. A decision to invest in any such asset should not be made in reliance on any
information herein. Indices and rates cannot be invested in directly. Inclusion of an asset in an index or rate is not a recommendation to buy, sell or hold that asset nor confirmation thatany particular investor may lawfully buy, sell or hold the asset or an index or rate containing the asset. The general information contained in this publication should not be acted upon
without obtaining specific legal, tax, and investment advice from a licensed professional.
Past performance is no guarantee of future results. Charts and graphs are provided for illustrative purposes only. Index and/or rate returns shown may not represent the results of theactual trading of investable assets. Certain returns shown may reflect back-tested performance. All performance presented prior to the index or rate inception date is back-testedperformance. Back-tested performance is not actual performance, but is hypothetical. The back-test calculations are based on the same methodology that was in effect when the index
or rate was officially launched. However, back-tested data may reflect the application of the index or rate methodology with the benefit of hindsight, and the historic calculations of anindex or rate may change from month to month based on revisions to the underlying economic data used in the calculation of the index or rate.
This document may contain forward-looking assessments. These are based upon a number of assumptions concerning future conditions that ultimately may prove to be inaccurate.
Such forward-looking assessments are subject to risks and uncertainties and may be affected by various factors that may cause actual results to differ materially. No member of LSEG
nor their licensors assume any duty to and do not undertake to update forward-looking assessments.
No part of this information may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise,
without prior written permission of the applicable member of LSEG. Use and distribution of LSEG data requires a licence from LSEG and/or its licensors.