March 2024

Complaints, Operational Enquiries &Price Challenges Handling Policy
Refinitiv Benchmark Services (UK) Limited
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Complaints, Operational Enquiries & Price Challenges Handling Policy

ContentsIntroduction ........................................................................................................................................................................................... 3
Regulatory Environment .................................................................................................................................................................... 3
Document Scope ............................................................................................................................................................................... 3
Purpose of Document ........................................................................................................................................................................ 3
Supervised Entity Statement ............................................................................................................................................................. 3
Benchmark Stakeholder Statement ................................................................................................................................................... 3
Making Operational Enquires/Price Challenge or a Complaint.............................................................................................................. 4
Making an Operational Enquiry or Price Challenge ........................................................................................................................... 4
Making a Complaint ........................................................................................................................................................................... 4
Handling Operational Enquiries/Price Challenges & Complaints .......................................................................................................... 5
Reviewer Independence .................................................................................................................................................................... 5
Receipt & Acknowledgement ............................................................................................................................................................. 5Investigation ...................................................................................................................................................................................... 5
Response .......................................................................................................................................................................................... 5
Record Keeping .................................................................................................................................................................................... 6
RBSL Record Keeping Policy ............................................................................................................................................................ 6
Document Review Cycle ....................................................................................................................................................................... 6
Document Review Frequency ............................................................................................................................................................ 6
Terms & Abbreviations .......................................................................................................................................................................... 7

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Introduction
Regulatory Environment
Refinitiv Benchmark Services (UK) Limited (“RBSL”), administers, calculates and distributes Benchmarks across multiple asset
classes across global jurisdictions.
RBSL administers a number of Benchmarks in accordance with the relevant obligations of the International Organisation ofSecurities Commissions (“IOSCO”) Principles for Financial Benchmarks, the UK Benchmark Regulation (“BMR”), and the Multilateral
Instrument 25-102 Designated Benchmarks and Benchmark Administrators ("CSA Rule").
RBSL is authorised and regulated in the UK by the Financial Conduct Authority (“FCA”), FCA Reference Number 610678. RBSL isdesignated and regulated in Canada by the Ontario Securities Commission ("OSC") and the Autorité des marchés financiers("AMF") on behalf of all members of the Canadian Securities Administrators ("CSA").

Document Scope
This document is, unless specifically provided otherwise, applicable to Benchmark Families that are categorised as Critical,Significant or Non-significant per the thresholds designated in the BMR, as well as specific benchmark classes such as Regulateddata, Interest Rate and Commodity Benchmarks.

Purpose of Document
This document defines the RBSL procedures for receiving, investigating, and retaining records of both Benchmark complaints andBenchmark operational enquiries as per the requirements set out in Article 9 of the BMR.
RBSL will treat all price challenges and complaints seriously and are committed to responding appropriately and consistently.

Supervised Entity Statement
Supervised entities that use a Benchmark are responsible for the production and maintenance of their own robust written planssetting out the actions that they would take in the event that a benchmark materially changes or ceases to be provided.

Benchmark Stakeholder Statement
Subscribers and other Stakeholders who have financial instruments that reference Administered Benchmarks are responsible fortaking steps to make sure that:a)b)

Contracts or other financial instruments that reference an Administered Benchmark have robust fall-back provisions in theevent of material changes to, or cessation of, the referenced Benchmark.
Stakeholders, including clients of stakeholders are aware of the possibility that various factors, including external factors
beyond the control of the Administrator, might necessitate material changes to a Benchmark.

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Making Operational Enquires/Price Challenge or aComplaint
Making an Operational Enquiry or Price Challenge
A Price Challenge is a request from a user or a stakeholder to verify and confirm the accuracy of one or more of the published
Benchmark rates, inputs to those rates (if publicly available), or whether a specific benchmark determination is representative ofmarket value.
Operational enquiries do not meet the definition of a complaint and include Benchmark Price Challenges. However, RBSL may
decide to treat an operational enquiry or series of operational enquiries as a formal complaint.
Operational enquiries must be submitted to Refinitiv Benchmark Operations by e-mail and should contain as much information as
possible, including your name, your title, the institution you represent, your e-mail address and telephone number, to enable theoperational enquiry to be investigated in a timely manner.
The email address to raise WM/Refinitiv FX Spot & Forwards benchmark related price challenge and operational enquiries is:
wmr.ops@lseg.com
The email address to raise Core Commodity benchmark related price challenge and operational enquiries is:index_queries@lseg.com
The email address to raise Convertible Indices related price challenge and operational enquiries is: CB_Index_Feedback@lseg.com
The e-mail address to raise Tokyo Swap Rate (TSR) related price challenge and operational enquiries is:
asiabenchmarkoperations@lseg.com
The email address to raise any other benchmark related price challenge and operational enquiries is:
BenchmarkOperations@lseg.com

Making a Complaint
A complaint is any expression of formal dissatisfaction made to RBSL in relation to any aspect of the benchmark administration
process.
If an index user, market participant, index constituent or other party wishes to raise a complaint regarding services provided byRBSL they should raise the complaint via Client Services detailing the basis for their complaint.
The submission should contain as much information as possible including, but not limited to the name of the benchmark, thedate/time of the rate(s) in question, the nature of the complaint, the impact (if any) to you or your firm, and the intended outcome of
the complaint.
Complaints must include your name, your title, the institution you represent, your e-mail address and telephone number, to enable
the complaint responded to in a timely manner.
The e-mail address to submit Benchmark related complaints is: :info@ftserussell.com

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Complaints, Operational Enquiries & Price Challenges Handling Policy

Handling Operational Enquiries/Price Challenges &Complaints
Reviewer Independence
Reviews will be managed independently of any personnel who may have been involved in the subject-matter of the complaint oroperational enquiry.
Operational Enquiries, including Price Challenges, will be managed by a member of the Refinitiv Operations team.
Complaints will be reviewed by an independent member of the Client Services team.

Receipt & Acknowledgement
On receipt of a complaint or operational enquiry, a relevant member of the Client Services team will:•••

Escalate the issue to the relevant department best placed to address the complaint and ensure they have all theinformation provided relating to it.
Confer with the complainant if necessary to ensure the nature of the inquiry or complaint is fully understood.
Seek to acknowledge receipt of the complaint within one business day.

Investigation
This procedure is designed to ensure that investigations of complaints and operational enquiries are conducted in a timely and fairmanner and that the outcome of the investigation is communicated within a reasonable period of time.
Investigations of operational issues are conducted by Refinitiv Benchmark Operations in a timely and fair manner and the outcomeof the investigation is communicated to the complainant within a reasonable period of time.
The investigation shall be conducted competently, diligently, and impartially, obtaining additional information as necessary.
The investigation shall assess fairly, consistently, and promptly:
a)
b)
c)

the subject matter;
if a complaint should be upheld or if an operational enquiry is credible;
the action that may be appropriate.

The investigation may involve a consultation with relevant subject matter experts to ensure the investigation is handled fairly andtaking into account all the relevant facts.
The resolution time for a complaint will vary according to the nature of the issue and the level of investigation it may require. The
Client Services Team will provide regular updates as to the status of the issue and anticipated timescales to resolution.
Where appropriate, complaints and operational enquiries may be reported and escalated to the relevant governance forums,
including the RBSL Board and/or the relevant benchmark Oversight Committee.

Response
The complaint or operational inquiry, including the outcome of the investigation, and, if appropriate, details of any proposed remedialaction, shall be addressed and responded to in a timely manner and explained in a way that is fair, clear and not misleading. If thefinal resolution determines that a recalculation or reissue of data is required, a client notice will be issued to all affected users
detailing the decision. After this has been sent, a member of the Client Services team will contact the complainant with the outcomeof their complaint.

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In all cases of a complaint, a written response will be provided to the complainant by the Client Service team. A Complaint oroperational enquiry will be deemed as resolved or settled whereby a Final Response and/or further clarifications on the Final
Response to the Complainant and no challenge is received within four weeks of RBSL’s final response.

Record Keeping
RBSL Record Keeping Policy
RBSL must maintain relevant records in accordance with the RBSL Records Keeping Policy.
The RBSL Records Keeping Policy states that all documents related to a complaint, including those emails submitted by acomplainant to the appropriate channels, shall be kept for a minimum period of seven years on restricted and secure servers usedby RBSL.

Document Review Cycle
Document Review Frequency
This document must be reviewed on an annual or ad hoc basis to ensure it remains appropriate and consistent with the regulatory
requirements and industry standards.

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Terms & Abbreviations
For the purposes of this document, the following capitalised terms and abbreviations shall, unless specifically provided otherwise,
have the meanings set out in the Table of Definitions and Abbreviations below:
TermDefinition

Administration

includes all stages and processes involved in the production and dissemination of a Benchmark,including:a)Collecting, analysing and/or processing information or expressions of opinion for thepurposes of the determination of a Benchmark;b)

Determining a Benchmark through the application of a formula or another method of
calculating the information or expressions of opinions provided for that purpose; andc)

Dissemination to users, including any review, adjustment and modification to thisprocess.

Administrator

means the legal person having control over the Provision of a Benchmark, RBSL.

AMFAutorité des marchés financiers

Benchmarkmeans any index by reference to which the amount payable under a financial instrument or afinancial contract, or the value of a financial instrument, is determined, or an index that is used tomeasure the performance of an investment fund with the purpose of tracking the return of suchindex or of defining the asset allocation of a portfolio or of computing the performance fees

Benchmark Administrator

See AdministratorBMR

UK Benchmark Regulation

Commodity Benchmark

means a Benchmark that fulfils the conditions laid down in Article 3(23) of the BMR

Critical Benchmark

means a benchmark other than a regulated-data benchmark that fulfils any of the conditions laid
down in Article 20(1) of the BMR and which is on the list established by the Commission

CSA

Canadian Securities Administrators

CSA Rule

Multilateral Instrument 25-102 Designated Benchmarks and Benchmark Administrators

EUEuropean Union

FCA

Financial Conduct Authority

Interest Rate Benchmark

means a benchmark which is determined on the basis of the rate at which banks may lend to, orborrow from, other banks, or agents other than banks, in the money market

IOSCO

International Organization of Securities Commissions

Non-Significant
Benchmarkmeans a benchmark that does not fulfil the conditions laid down in Articles 20(1) and 24(1) of theBMR

OSC

Ontario Securities Commission

Policymeans this Policy

Regulated-data
Benchmarkmeans a benchmark determined by the application of a formula defined in Article 3(24) of theBMR

Regulatory Authority

means a governmental or statutory body (not being a Self-Regulatory Organization) withresponsibility for securities and/or commodities and futures regulation

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Significant Benchmark

means a benchmark that fulfils the conditions laid down in Article 24(1) of the BMR

Supervised Entity

means an entity that fulfils the conditions laid down in Article 3(17) of the BMR

RBSL

Refinitiv Benchmark Services (UK) Limited

FTSE Russell

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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
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Sydney +61 (0) 2 7228 5659

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