BENCHMARKDESCRIPTION OF SERVICES
AND CONFLICTS OF INTERESTDISCLOSURE STATEMENT
Benchmark statement

What are the services offered by Refinitiv?

Refinitiv through its wholly owned subsidiary, Refinitiv
Benchmark Services Limited (“RBSL”), provides the WM/Refinitiv
FX Benchmarks: a global foreign exchange rate benchmark
service offering spot, forward and non-deliverable forward
foreign exchange benchmark rates (each a “benchmark rate”
and together the “benchmark rates”) at fixed points throughout
the global trading day. Refinitiv strives to maintain an open andongoing dialogue with its subscribers about the potential conflictsof interest associated with the offering of the WM/Refinitiv FXBenchmarks.

Refinitiv provides a global foreign exchange rate benchmark
service, offering spot, forward and non-deliverable forwardbenchmark rates for specific currency pairs at fixed points
throughout the global trading day. The most actively traded (i.e.,most liquid) spot currency pairs for which Refinitiv establishes abenchmark rate are referred to as the “trade currencies”, because
these benchmark rates are primarily established using actual trade
execution and order data from identified third-party global foreignexchange trading platforms.

This document is intended to generally describe the WM/R FXBenchmarks and any actual or potential conflicts of interest that wehave identified that may arise in connection with the offering of thebenchmark rates. Our client service representatives are available
to answer or arrange an answer to any questions you may haveregarding the benchmark rates.
You also have access to additional information about theWM/R FX Benchmarks at refinitiv.com/wmr.
While Refinitiv has attempted to identify in this document thematerial conflicts of interest that may arise in connection with theoffering of the WM/R FX Benchmarks, Refinitiv may have failed to
identify all such actual or potential conflicts of interest, and otherconflicts of interests may arise in the future.
Your use of the benchmark rate service offered by Refinitiv will bedeemed to constitute your consent for Refinitiv to provide such abenchmark rate service to you even though the actual or potential
conflicts of interest identified herein in relation to such services
may exist.

The remaining spot currency pairs, as well as all deliverable andnon-deliverable forward currency pairs, are called “non-trade”
or “quote” currencies, meaning that Refinitiv establishes thesebenchmark rates primarily using the indicative bid and offer rates
from identified third-party global foreign exchange platforms.
The global platforms from which Refinitiv obtains trade execution,order and indicative bid and offer rate data are collectively
referred to herein as the “data providers”. As of the date of thisdisclosure statement, the data providers for the trade and quotecurrencies are Refinitiv Transaction Services Limited (“RTSL”),
EBS Dealing Resources Limited (“EBS”) and, in certain limited
circumstances, Currenex, Inc. Refinitiv has the discretion, at any
time and without notice, to change the entity or entities that areacting as data providers for any particular currency pair. Refinitiv
may also change the number of such entities that are used tosource trade execution, order or indicative bid and offer rate data
to calculate the benchmark rate for any particular currency pair.
Refinitiv provides a more detailed description of the benchmark
rates and the methodology used to calculate these benchmark
rates at refinitiv.com/wmr.

Description of Services and Conflicts of Interest Disclosure Statement

Are the foreign exchange rates published by Refinitiv
fit for purpose?
The foreign exchange benchmark rates calculated and publishedby Refinitiv are designed to generally reflect the foreign exchange
market at the time of each benchmark fix, and are not intended
as a composite picture of all foreign exchange transaction activity
at that or any other time. The foreign exchange benchmark rates
calculated and published by Refinitiv are used by subscribers
for a range of purposes including, but not limited to: equity andbond index calculations, financial reporting (i.e., conversion of
global currency holdings into a base rate), foreign exchange trade
execution benchmark pricing, creation and settlement of financial
instruments, portfolio valuations and performance measurements,
and as the conversion rate in certain financial products. Each
subscriber should independently determine whether the use ofa benchmark rate and, in particular, a benchmark rate calculated
pursuant to the methodology employed by Refinitiv, is appropriate
for the intended objective of that subscriber.
The methodology used by Refinitiv may produce results consistent
with one subscriber’s objective, but not another’s. For example,
Refinitiv does not take transaction size into account whencalculating its foreign exchange benchmark rates. Accordingly,
subscribers who use the foreign exchange benchmark rates
primarily for valuing financial instruments may be impacted
differently by this methodology decision, compared with subscribers
who use the foreign exchange benchmark rates in circumstanceswhere the size of the foreign exchange transaction is relevant – forexample, establishing the price at which foreign exchangetransactions are to be executed with their clients. There may beforeign exchange benchmark rates that are designed for more
specific purposes, and therefore have characteristics that arebetter tailored to your specific objectives.
Recently, there has been increased scrutiny regarding foreignexchange benchmark rates and market practices, relating to theiruse in the foreign exchange market. This has resulted in – andmay continue to result in – increased regulatory guidance that
may impact the methodology (e.g., the number and quality of thedata providers or benchmark fixing window, as defined below) by
which the benchmark rates are calculated by Refinitiv. In response
to such regulatory guidance, we may be required or otherwise
voluntarily elect to alter the methodology by which the benchmark
rates are calculated, in a way that may not be beneficial for all
subscribers.
Refinitiv does not provide any advice to subscribers as to theappropriateness of its foreign exchange benchmark rates fora particular purpose or claim that its methodology is the best,or even an appropriate, methodology for any particular purpose
for which a benchmark rate might be used. Refinitiv also may, on
its own initiative or in response to future regulatory requirements,introduce new foreign exchange benchmark rates or discontinue all2or a portion of its benchmark rate service, or alter the methodology
by which its foreign exchange benchmark rates are calculated
and validated. Refinitiv may also increase, decrease or change thenumber of data providers from which trade execution, order andindicative bid and offer rates are sourced, any or all of which may
present unique risks to a subscriber depending on that subscriber’s
intended use of the foreign exchange benchmark rates.
Refinitiv may discontinue its benchmark rate service, in whole
or in part, and alter the methodology by which its foreignexchange benchmark rates are calculated and validated. This
includes by increasing, decreasing or changing the number ofdata providers. In addition, there are operational risks associatedwith calculating and publishing any foreign exchange benchmark
rate. Therefore, subscribers are solely responsible for assessing
and understanding the potential impact of those considerations
and risks on their own operations or valuations, and the potential
need for alternative foreign exchange benchmark rates during
periods when the foreign exchange benchmark rates published by
Refinitiv are not available, or when a change in the methodology
by which they are calculated renders them unsuitable for theintended objective of that subscriber. For example, if a subscriber
is using our foreign exchange benchmark rates to value afinancial instrument, present comparability of data at different times,
or evaluate trends over a period of time, any change in themethodology, quality or number of data providers may produce
benchmark rates that would differ from the benchmark rates
determined using the prior methodology or data providers. This
could materially impact the valuation of any financial instrument orcomparison or trend analysis.
Refinitiv is not responsible for considering the interests ofsubscribers individually, or as a group, in determining whether
to make any such change. Refinitiv shall not be liable for any
disruption to or financial impact on a subscriber’s businessdue to any delay in or cessation of publishing, unavailability of
any of its foreign exchange benchmark rates, changes to themethodology by which those foreign exchange benchmark
rates are calculated and validated, or unsuitability of the foreignexchange benchmark rates for the intended objective of that
subscriber. There are subscribers who may have a financial orother interest in understanding the methodology by which theforeign exchange benchmark rates are calculated and validated
by Refinitiv. Therefore, they may attempt to influence or proposechanges to that methodology to their advantage (e.g., byadvocating for a longer or shorter period over which we source
actual trade execution and order data, or by advocating for moreor fewer sources of data used to calculate the benchmark rates).
The interests of these subscribers may not align with, and may be
adverse to, the interests of other subscribers. If successful, such
efforts may result in benchmark rates that are unsuitable for theintended objective of a particular subscriber.

Description of Services and Conflicts of Interest Disclosure Statement

What are the conflicts of interest that may arise
between Refinitiv or any of its subscribers and dataproviders?
Refinitiv currently sources transaction and other data used in thecalculation of its benchmark rates from three data providers:
RTSL, EBS and Currenex.

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calculation and distribution of the benchmark rates. RBSL sources
transaction and other data from RTSL, another Refinitiv Groupsubsidiary. This means that RTSL, along with EBS and Currenex,
provides data inputs that help to determine the WM/Refinitiv FX
benchmark rates. In addition, RBSL relies on Refinitiv Limited to
distribute the benchmark rates to subscribers, via the Refinitiv®
Eikon, who have entered into direct licensing arrangements.

Refinitiv has several validation processes that it believes aredesigned to identify and appropriately address off-market
rates while calculating a benchmark rate. However, Refinitiv
has established the current methodology for calculating andvalidating foreign exchange benchmark rates based upon its own
judgment as to the measures and thresholds that are appropriate.
This has been done without regulatory direction, i.e., a set ofrules for monitoring or surveying the trading activity that takes
place on any of its data providers’ platforms for manipulative ordisruptive behavior. The information that Refinitiv obtains fromits data providers is not sufficient to determine whether any third
party participating on the data providers’ platforms is engaging
in manipulative or disruptive behavior, or otherwise engaging
in conduct that could adversely impact market participants inthe foreign exchange market. Refinitiv relies primarily on its data
providers to monitor manipulative and disruptive behavior on
their platforms that may impact the quality of the transaction
and other data provided to Refinitiv for use in the calculationof the benchmark rates and to otherwise comply with relevant
regulations and best practices in these areas, although any suchmonitoring by these data providers will likely be focused on thespecific trading platform services offered by the relevant data
provider and not the integrity of the foreign exchange benchmark
rates published by Refinitiv.

Refinitiv has reviewed its governance structure and has identified
that the greatest potential conflict of interest lies in the relationshipbetween RBSL and RTSL. Refinitiv believes that it has implemented
adequate governance arrangements in order to avoid or mitigate
this potential conflict of interest to the greatest extent possible.
Such arrangements include, but are not limited to, the following:

In light of the financial benefit obtained by these data providers
for providing the transaction and other data used by Refinitiv in
calculating the benchmark rates, as well as any potential additional
revenue arising from increased trading activity on their platforms
due to their status as data providers to Refinitiv, these platform
operators might not communicate to Refinitiv concerns relating
to the operation of their platform, including concerns relating tomanipulative or other disruptive behavior by their subscribers.

Market and liquidity risks

Refinitiv relies on these platform operators’ technology to source
the relevant transaction and other data that is used to calculate
the benchmark rates. If there is an issue with the completenessor quality of the data sourced, the integrity and reliability ofthe benchmark rates calculated by Refinitiv may be impacted.
Moreover, if there is a problem with the platform technology,
Refinitiv could experience a delay in receiving the relevant datafrom the platform or degradation in the quality of the data being
received.

What are the conflicts of interest that may arise
between RBSL, RTSL and other relevant Refinitiv
entities?
Refinitiv Benchmark Services Limited (“RBSL”) is the Financial
Conduct Authority-regulated entity that administers the benchmark
rates and has primary responsibility for all aspects of thebenchmark determination process, including the development,• RBSL and RTSL are completely segregated, wholly owned
subsidiaries of Refinitiv. Both entities are governed by their very
own exclusive board of directors, with no individuals serving on
both boards.
• Refinitiv’s WM/R FX Benchmarks and transaction businesses arecompletely separate. They are based in different locations.
The WM/R operations team is in a secure, controlled accessarea, segregated from any transactions business employees
and other non-essential personnel. This strengthens theisolation and control of unapproved access. The personnel ofthe business units are organized into clear, distinct reportinglines, with each business adopting processes and practices
to mitigate the potential for inappropriate influence of thebenchmark determinations.

Are there other risks that may arise in connection
with the use of the benchmark rates?
Each benchmark rate fluctuates over time in accordance withthe underlying trade execution, order or indicative bid and offer
rate data used by Refinitiv as input data for the calculation of
the benchmark rate for a particular currency pair. The value ofa financial instrument or contract that references a particularbenchmark rate may be affected accordingly. During any givenbenchmark fix period, an illiquid market could materially reducethe volume or quality of data sourced by Refinitiv for use in thecalculation of the benchmark rates. For example, where there
is insufficient liquidity on the trading venue from which Refinitiv
receives input data for the trade currencies, the benchmark
rates calculated on the basis of such input data may not be
representative of equivalent exchange rates on other trading
venues, in other markets or at any other time of the day.

Description of Services and Conflicts of Interest Disclosure Statement

In addition, the spot benchmark rates for the quote currencies arecalculated based on indicative bid and offer rates, as opposed toobservable transaction execution data or binding or “committed”
orders on a trading platform. Generally, these quote currencies
are considered currencies for which there is a less active market.
Ultimately, these indicative bid and offer rates are based on thejudgment of the institutions submitting that information to therelevant data provider. They may not be reflective of rates atwhich market participants are able to enter into an arm’s length
foreign exchange transaction. In some instances, the number ofinstitutions contributing indicative bid and offer rates with respect
to a particular quote currency pair may be as little as one.

Operational risks
Notwithstanding any operational safeguards implemented byRefinitiv, there is a risk that a given benchmark rate cannot becalculated in accordance with the required methodology, or that
Refinitiv becomes temporarily unable to calculate and publish abenchmark rate as a result of events outside their reasonable control.
If you would like to learn more about the WM/Refinitiv rates service,please visit our website or contact us by telephone or email.
A service representative will be available 24 hours a day from
Monday 6:00 a.m. Hong Kong Time until Friday 10:00 p.m. UK time.

Legal and regulatory risks
There is a risk that certain entities may be restricted, or in future
become restricted, in their ability to use the benchmark rates due
to legal or regulatory restrictions applying in their jurisdiction.

Client relations:
UK toll-free: 0800 023 4130
International: + 44 (0) 131 376 0007
Email: wmr.sales@refinitiv.com
Operations:
UK toll-free: 0800 028 2551
International: + 44 (0) 131 376 0004
Email: wmreuters.ops@refinitiv.com

Refinitiv is one of the world’s largest providers of financial markets data and infrastructure, serving over 40,000 institutions in approximately 190 countries. It provides leading dataand insights, trading platforms, and open data and technology platforms that connect a thriving global financial markets community – driving performance in trading, investment,
wealth management, regulatory compliance, market data management, enterprise risk and fighting financial crime.

Visit refinitiv.com@Refinitiv
RE1312769/11-20

Refinitiv

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