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Contents

1. Introduction ............................................................................................................................3

2. Overview of the Company ......................................................................................................3

3. Key Index Families.................................................................................................................4

4. MOEX’s Approach to Implementation of the IOSCO Principles for Financial Benchmarks......6

5. Governance over the Benchmarking Process and Control Framework...................................7

6. Executives’ Statement............................................................................................................9

7. Independent Assurance Report................................................................................................10

8. IOSCO Principles and Responses........................................................................................12
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1. Introduction

The "Principles for Financial Benchmarks" published by the International Organization of Securities 

Commissions ("IOSCO") on 17 July 2013 (hereinafter referred to as “Principles” or “IOSCO 

Principles”) represent an overarching framework of Principles for use in financial markets. These 

Principles set out standards that should be complied by organisations that administer financial 

benchmarks (“Benchmark Administrators”).

In accordance with the requirements of the IOSCO Principles, Benchmark Administrators should 

publicly disclose the extent of their compliance with the Principles annually. This Statement of 

Compliance relates to the declaration of compliance by Public Joint-Stock Company «Moscow 

Exchange MICEX-RTS» (hereinafter referred to as “MOEX” or “Company”) with the IOSCO 

Principles for its index families.

The Statement of Compliance describes MOEX’s control procedures that have been designed to 

achieve the related control objectives identified by MOEX to comply with the provisions of the IOSCO 

Principles as at 29 May 2015.

CJSC Ernst & Young Vneshaudit (hereinafter referred to as “EY”) was appointed by the Company

to provide an opinion as at 29 May 2015 whether anything has come to the auditor’s attention that 

the Statement of Compliance does not fairly describe the control procedures as designed and that 

the control objectives related to the requirements of the IOSCO Principles will have not been 

achieved if the described control procedures were complied with satisfactorily.

2. Overview of the Company

MOEX together with its subsidiary trading venues (hereinafter referred to as “MOEX Group”) is the 

exchange group, which was created as a result of merger of two exchanges: CJSC MICEX 

(established in 1992) and OJSC RTS (established in 1995).

MOEX Group provides infrastructure for trading shares, bonds, currencies, investment units,

including units of exchange traded funds (ETF), money market instruments, commodities and 

derivatives (including OTC derivatives).

At the same time MOEX acts as a Benchmark Administrator for the indices and other financial 

indicators (hereinafter referred to as “Index” and together “Indices” or “Benchmark” and together 

“Benchmarks”), calculated on the basis of the data generated at MOEX Group trading venues.

MOEX and its 100% subsidiary Closed joint-stock company “MICEX Stock Exchange” (hereinafter 

referred to as “MICEX SE”) have exchange licences to carry out organised trading for for the range 

of instrument (such as currencies, derivatives, securities as well as repo operations) and are 

responsible for the overall administration of the benchmarking process in relation to indices which 

are based on market data generated at their trading venues.

MOEX Group’ governance structure with respect to the benchmarking process:

Independent 

Committees of 

Stakeholders

Company

Supervisory Body

Management Body

100%

Subsidiary

MOEX

Supervisory Board

Executive Board

MICEX SE

Board of Directors

Management Board
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MOEX maintains its business based on market demand and needs of market participants and other 

interested and/or potentially interested third parties (hereinafter referred to as “Stakeholder” and 

together “Stakeholders”). In order to increase transparency of the further market development and 

its infrastructure Supervisory Board of MOEX and Board of Directors of MICEX SE are responsible 

for the appointment of members of Independent Committees of Stakeholders (hereinafter referred 

to as “Committee” and together “Committees” or “Independent Committees of Stakeholders”)

which perform the independent oversight function related to the benchmarking process: 

(1) Supervisory Board of MOEX is responsible for the appointment of members of:

(i) FX Market Committee, and 

(2) Board of Directors of MICEX SE is responsible for the appointment of members of:

(i) REPO Committee;

(ii) Collective Investment Market Committee;

(iii) Index Committee.

Based on consultation with the respective Committee Executive Board of MOEX (hereinafter referred 

to as “Executive Board” or “Executive Board of MOEX”) and Management Board of MICEX SE 

(hereinafter referred to as “Management Board” or “Management Board of MICEX SE”) manage 

the process of benchmarking.

The Executive Board of MOEX consists of five members and it is accountable to the Supervisory 

Board of MOEX (hereinafter referred to as “Supervisory Board” or “Supervisory Board of MOEX”).

The Management Board of MICEX SE consists of three members and it is accountable to the Board 

of Directors of MICEX SE (hereinafter referred to as “Board of Directors” or “Board of Directors 

of MICEX SE”).

The Supervisory Board of MOEX consists of fifteen members including five independent directors. 

The Board of Directors of MICEX SE consists of five members. Members of the Supervisory Board 

and the Board of Directors are appointed at the respective general shareholders meeting of MOEX 

and MICEX SE.

3. Key Index Families

The MOEX Index Family is represented by the major indices of the Russian financial market which 

are widely used by asset managers, traders and analysts all over the world to develop investment 

strategies and perform benchmarking of investment strategies. MOEX is constantly working to 

expand its range of indices, improve product support, and refine the rules regulating market data 

usage for all types of clients. The MOEX Index Family includes a wide range of different indices for

equities, bonds, repo market, currency and other indices. Indices are based on predefined 

transparent rules and formulas which were stated in the separate documents for Stakeholders in 

order to be able to determine the level of the Index at any time (hereinafter referred to as 

“Methodology” and together “Methodologies” or “Benchmark Methodologies”). MOEX’s Indices

are unique and have a competitive advantage, and as a result, they are relied upon by Stakeholders.

The most famous equity indices are the MICEX Index and the RTS Index, which are well-known as 

the key indicators of the Russian Stock Market which represent the dynamics of the 50 most liquid 

stocks of the Russian largest issuers. The constituents of the Second Tier Index include medium 

and small capitalized Russian equities. And finally, the Broad Market Index is a unified index top list 
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of the broad Russian equity market. All Equity Indices follow a unified index design approach based

on global best practices and local market expertise.

MOEX’s Bond Indices have been designed to measure the performance of various segments of the 

Russian bond market by duration and credit grade.

MOEX’s Multi-asset indices are composite indices which were developed for the needs of Russian 

pension system and comprised of stocks and bonds admitted to trading on MICEX SE and being 

eligible for using as investment vehicles by Russian Pension Funds according to the Russian 

legislation (hereinafter referred as “Pension Indices”). These indices are designed to reflect three 

possible investment strategies by key asset classes: conservative, moderate and aggressive.

Repo Rate indicators reflect money and credit market conditions, currency fixings − different

currencies rates to the Russian Rouble. 

The list and the description of MOEX’s indices are publicly available on MOEX’s web-site

http://moex.com/en/indices. The Statement of Compliance relates to the list of indices as presented 

below as of the date of this report:

MAIN EQUITY INDICES

MICEX Index

RTS Index

Blue Chip Index

Second-Tier Indices*

Broad Market Indices*

SECTORAL EQUITY INDICES*

Oil & Gas

Electric Utilities

Telecommunication

Metals & Mining

Industrials

Financials

Consumer & Retail

Chemicals

Transport

THEMATIC EQUITY INDICES

MICEX10 Index

MICEX Innovation Index

MICEX Siberia Index

MAIN BOND INDICES**

MOEX Government Bond Indices

MOEX Corporate Bond Indices

MOEX Municipal Bond Indices

MOEX Aggregate Bond Indices

OTHER BOND INDICES***

Corporate Bond Index Series

Government Bond Index Series

Municipal Bond Index Series

MULTI-ASSETS INDICES (PENSION INDICES)

Conservative index

Moderate index

Aggressive index
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REPO RATE INDICATORS

Stock repo market indicators

Stock repo with CCP market indicators

Bond repo market indicators

OFZ repo with CCP market indicators 

FX FIXINGS

FX Ruble Fixing

FX EUR/RUB Fixing

FX EUR/USD Fixing

FX CNY/RUB Fixing

INDICATIVE RATES FOR SWAPS

Indicative rate for swaps (ON)

Indicative rate for swaps USD/RUB (TERM)

* Indices are RUB and USD denominated.

** Indices are calculated by “total return” method or “clean price” method.

*** Indices series are segregated by term and credit quality of the issuer.

4. MOEX’s Approach to Implementation of the IOSCO Principles for 

Financial Benchmarks

MOEX has developed the processes and controls required to comply with the IOSCO Principles. 

MOEX’s indices are calculated based on Benchmark Methodologies. MOEX’s Benchmark

Methodologies are designed in a way to produce Benchmarks that are representative of economic 

realities of the interest they seek to measure, and eliminate factors that might result in the distortion 

of the value of Benchmarks. 

MOEX’s Benchmark Methodologies are aimed to make the Benchmarks determination transparent 

to Stakeholders and contain detailed descriptions and explanations of how the Benchmarks are 

determined. All Benchmark Methodologies are publicly available on MOEX’s web-site. 

MOEX introduced a clearly defined process for the development and approval of Benchmark 

Methodologies. Benchmark Methodologies are developed based on the consultation with MOEX’s 

Committees and approved by the Executive Board of MOEX and the Management Board of MICEX

SE.

Benchmark Methodologies are reviewed by the Executive Board of MOEX and the Management 

Board of MICEX SE at least annually to assess the necessity of changes to reflect the current market 

conditions. Constituents Lists for Benchmarks are reviewed on a quarterly basis or in case of 

corporate events. Respective MOEX’s Committee participates in the process of Benchmarks’ review. 

All the changes to Benchmark Methodologies and Constituents Lists are publicly available on 

MOEX’s web-site.

MOEX’s internal processes are aimed at ensuring quality and integrity of Benchmarks. 

MOEX developed information systems and processes for the automated calculation of Benchmarks 

based on Benchmark Methodologies. 

MOEX has established governance structure and control framework to address the requirements of 

the IOSCO Principles (Section 2 and 5). 
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MOEX maintains a comprehensive set of risk policies, processes, and procedures designed to 

ensure the business is consistently managed within an agreed framework. 

MOEX’s policies include the Conflicts of Interests Policy designed to ensure that the Benchmarks 

determinations are not influenced by the existing or potential conflict of interest. 

MOEX established and documented the complaints procedure which gives the opportunities to all 

interested parties to address questions and suggestions to MOEX via MOEX’s web-site.

5. Governance over the Benchmarking Process and Control Framework

The governance framework of MOEX is represented by the following bodies:

 The Supervisory Board of MOEX;

 The Board of Directors of MICEX SE;

 The Executive Board of MOEX;

 The Management Board of MICEX SE;

 Independent Committees of Stakeholders.

The main Divisions/Departments involved in the benchmarking process are:

 The Index Management Division of MOEX;

 The IT Department of MOEX;

 The Compliance (Internal Control) Department of MOEX;

 The Operational Risks Department of MOEX.

The Index Management Division of MOEX is responsible for the execution of administrative functions

of the Benchmark determination process and accountable to the Executive Board of MOEX. The 

Executive Board of MOEX and the Management Board of MICEX SE review and approve policies 

and procedures related to the benchmarking process and they are also responsible for the review of 

internal control reports and operational risk reports. 

The Index Management Division’s role in the Benchmarking processes include: periodic update of 

parameters and constituents lists (both hereinafter referred as “Constituents Lists”) of the 

Benchmarks in case it is necessary, review and update of the existing Benchmark Methodologies, 

consultation with the respective Committee. The Executive Board of MOEX and the Management 

Board of MICEX SE perform the final review and approve updates of parameters and constituents 

lists of the Benchmarks as well as Benchmark Methodologies. 

MOEX’s Committees consist of representatives of external Stakeholders and are responsible for the 

independent oversight function, including periodic review of Benchmark Methodologies, parameters 

and constituents lists of the Benchmarks in case it is applicable acting as a Stakeholder consultation 

function. Each Committee operates within the scope of its functionality and expertise: FX Market 

Committee deals with the issues concerning FX Fixings and SWAP Indicators, REPO Committee is 

responsible for repo Indicators, Collective Investment Market Committee reviews issues concerning 

Pension Indices and Index Committee is responsible for Equity and Bond indices.

The Index Management Division of MOEX is also responsible for the development of new indices. 

Upon approval of the Methodologies, the Index Management Division develops the statement of 
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work for the IT Department for the calculation of indices. The IT department develops the calculation

algorithm and performs its testing in the test environment. Then the calculation algorithm is 

transferred to the working environment and the calculation of indices is performed automatically. The 

publication of indices on the web-site is automatically linked to the system which calculates indices.

The Compliance (Internal Control) Department and the Operational Risk Department are responsible 

for control over the benchmarking process, including conflicts of interest issues, whistleblowing 

process, compliance review, business continuity issues, dealing with error reports and information 

security, where Executive Board of MOEX is responsible for review of such reports and Supervisory 

Board of MOEX is responsible for approval of changes in compliance (internal control) and risk 

management procedures and policies.
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6. Executives’ Statement

We are responsible for the identification of the control objectives and the design of MOEX’s control 

procedures to effectively address the provisions of the IOSCO Principles. We are also responsible 

for the fair description of the control procedures in the Statement of Compliance.

We assert that MOEX has suitably designed control procedures to comply with the IOSCO Principles 

for the Benchmarks listed in Section 3.

We have prepared the detailed description of the relevant control procedures together with the 

related control objectives aimed at compliance with the IOSCO Principles as at 29 May 2015 in 

Section 8 and confirm that:

a) the accompanying descriptions in Section 8 fairly present the Company’s control procedures

which were in place; and

b) the control procedures are suitably designed such that the specified control objectives aimed 

at complying with the IOSCO Principles will have been achieved if the control procedures were

complied with satisfactorily.

Signed on behalf of Public Joint-Stock Company «Moscow Exchange MICEX-RTS»
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8. IOSCO Principles and Responses

IOSCO Principle MOEX’s response Work performed by EY

1. Overall responsibility of Administrator

The Administrator should retain primary responsibility 

for all aspects of the Benchmark determination 

process. For example, this includes:

The Index Management Division of MOEX is 

responsible for the key administrative aspects of the 

Benchmark determination process and it is

supervised by the Executive Board of MOEX and the 

Management Board of MICEX SE. The Index 

Management Division is supplemented by 

Committees of Stakeholders which are the part of the 

governance structure as described in Section 2 and 

Section 5 of this Statement.

We obtained and reviewed:

 MOEX’s organogram and hierarchy structure;

 the Index Management Policy describing the 

roles and responsibilities of all the functions 

involved in the benchmarking process;

 the Charters of MOEX and of MICEX SE;

 the Terms of Reference for the Index Committee, 

FX Market Committee, REPO Committee, 

Collective Investment Market Committee, 

Executive Board of MOEX and Management 

Board of MICEX SE.

We inspected for evidence that the above 

mentioned MOEX’s bodies are accountable for the 

Benchmark determination process.
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IOSCO Principle MOEX’s response Work performed by EY

a) Development: The definition of the Benchmark 

and Benchmark Methodology.

The Index Management Division is responsible for 

the development of Benchmarks as well as

Benchmark Methodologies.

Benchmark development process is supervised by 

the relevant Committee (Index Committee, FX 

Market Committee, REPO Committee and Collective 

Investment Market Committee), depending on the 

type of the Benchmark. Benchmark Methodologies 

are also reviewed for compliance with legislation and 

internal documents by the Compliance (Internal 

Control) Department. Afterwards they are reviewed 

and approved by the Executive Board and the 

Management Board.

All Benchmark Methodologies are officially disclosed

on MOEX’s web-site. 

The Bond, Equity and Pension Benchmarks are 

calculated based on the Constituent List, which is 

periodically reviewed (once per quarter) with the 

participation of the relevant Committee. The 

contents and structure of all Methodologies are also 

reviewed periodically by the Executive Board and the 

Management Board subject to consultation with 

relevant Committees.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that the roles are stated as described in 

MOEX’s response.

We obtained the Terms of Reference for Index 

Committee, FX Market Committee, 

REPO Committee, and Collective Investment 

Market Committee and inspected for evidence that 

they are responsible for periodic review, 

consultation and approval of Benchmark’s 

Methodologies and Constituent Lists.

We obtained a selection of meeting minutes of the 

Index Committee, FX Market Committee, 

REPO Committee and Collective Investment 

Market Committee and inspected for evidence that 

the Benchmark Methodologies together with the 

Constituent List for each MOEX’s index are 

reviewed on a periodic basis.

We obtained a selection of meeting minutes of the 

Executive Board and the Management Board and 

inspected for evidence that changes to the 

Benchmark Methodologies have been approved by 

them.

For each MOEX’s Index, we obtained Benchmark 

Methodologies and inspected for evidence that:

 they include the Benchmark definition and 

Benchmark determination procedure;

 they are publicly available on MOEX’s official 

web-site (http://moex.com/en/).
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IOSCO Principle MOEX’s response Work performed by EY

b) Determination and Dissemination: Accurate and 

timely compilation and publication and distribution 

of the Benchmark.

The Benchmark determination and dissemination 

process is automated at MOEX. The process of 

Benchmarks publishing follows the process of their 

calculation. The IT Department is responsible for the 

timely compilation and publication of Benchmarks. 

The Index Management Division is responsible for 

developing the statement of work for the Benchmark 

calculation. Based on this statement of work the IT 

Department develops technical specifications, upon 

which the calculation algorithm is developed. 

Afterwards the calculation algorithm is tested and 

reviewed for accuracy and compliance with the 

statement of work by the IT Department, the 

Compliance (Internal Control) Department and the 

Index Management Division. Then the calculation 

algorithm is transmitted from the test environment to 

the working environment. The working environment 

is designed in a way that the changes to the 

algorithm are not possible. The calculation of 

benchmarks is then performed automatically based 

on the calculation algorithm. The calculated 

benchmarks then flow from the calculating system 

and are automatically published on MOEX’s web-site

and Benchmarks are transferred to the data 

repository to provide data vendors with the real-time 

Benchmarks data. The process is reviewed both by 

the Operational Risk Department and the Index 

Management Division on a daily basis.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that the roles of the IT Department, the 

Index Management Division, the Compliance 

(Internal Control) Department and the Operational 

Risk Department are stated as described in MOEX’s 

response.

We obtained an example of statement of work for 

the IT Department and all the relevant 

correspondence and inspected for evidence that:

 the IT Departments develops algorithm for 

automatic determination and dissemination 

process in accordance with the statement of 

work;

 internal correspondence includes finalization, 

review, testing and final approval stages for the 

algorithm developed.

Based on the above we ensured that the process is 

designed in a way that the changes to the 

calculation algorithm are possible only after the 

approval of the new statement of work for the 

algorithm development.
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c) Operation: Ensuring appropriate transparency 

over significant decisions affecting the compilation 

of the Benchmark and any related determination 

process, including contingency measures in the 

event of absence of or insufficient inputs, market 

stress or disruption, failure of critical 

infrastructure, or other relevant factors.

Significant decisions affecting the determination of 

the Benchmark are relayed via press-releases on the 

official MOEX’s web-site (for example changes to 

Constituent List and changes to Methodologies in 

order to reflect current market conditions).

The Index Management Policy contains provisions 

concerning Benchmark determination procedure in 

case of absence or insufficient inputs and technical 

deficiency. In this case MOEX is responsible for 

undertaking measures to ensure the accuracy of the 

Benchmark.

MOEX has a Business Continuity Plan in place to 

cover disruptions both to technical and office 

infrastructure, thus ensuring the continuity of the 

business. All MOEX’s employees attend annual 

trainings concerning internal policies aimed at 

business continuity and prevention of infrastructure 

disruptions.

We reviewed a selection of MOEX’s press-releases 

and inspected for evidence that:

 they include statements concerning changes to 

Benchmark Methodologies and the Constituent 

Lists and effective date of changes coming in 

force;

 they include MOEX’s explanations concerning 

these changes;

 they are publicly available on MOEX’s web-site 

(http://www.moex.com/en/news/?ncat=206).

We obtained the Index Management Policy and 

inspected for evidence that it includes provisions 

concerning Benchmark determination procedure in 

evidence of absence or insufficient inputs and 

technical deficiency.

We obtained the Business Continuity Plan and 

inspected for evidence that:

 it is in place to cover disruptions to infrastructure;

 it contains provision concerning activities 

required to allow MOEX to continue to operate if 

there is an issue of technical deficiency.

We obtained mandatory training schedule for 

MOEX’s employees and inspected for evidence that 

all employees attend annual training concerning 

internal policies on business continuity and 

prevention of infrastructure disruptions.
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IOSCO Principle MOEX’s response Work performed by EY

d) Governance: Establishing credible and 

transparent governance, oversight and 

accountability procedures for the Benchmark 

determination process, including an identifiable 

oversight function accountable for the 

development, issuance and operation of the 

Benchmark. 

The Index Management Division of MOEX is 

responsible for the administrative functions of the 

Benchmark determination process and accountable 

to the Executive Board of MOEX. The Executive 

Board of MOEX and the Management Board of 

MICEX SE review and approve policies and 

procedures related to the benchmarking process and

Benchmark Methodologies and oversight the 

functions involved in the benchmarking process (all 

departments involved are accountable to the 

Executive Board of MOEX) as well as responsible for 

the review of internal control reports and operational 

risk reports.

MOEX’s Committees consist of representatives of 

external Stakeholders and are responsible for the 

independent oversight function, including periodic 

review of Benchmark Methodologies, parameters 

and constituents lists of the Benchmarks in case it is 

applicable acting as a Stakeholder consultation 

function. Each Committee operates within the scope 

of its functionality and expertise: FX Market 

Committee deals with the issues concerning 

FX Fixings and SWAP Indicators, REPO Committee 

is responsible for repo Indicators, Collective 

Investment Market Committee reviews issues 

concerning Pension Indices and Index Committee is 

responsible for Equity and Bond indices.

The Compliance (Internal Control) Department and 

the Operational Risk Department are responsible for 

performing control function over the benchmarking

process, including conflicts of interest issues, 

whistleblowing process, compliance review, 

business continuity issues, dealing with error reports 

and information security.

We obtained and reviewed:

 MOEX’s organogram and hierarchy structure;

 the Index Management Policy describing the 

roles and responsibilities of all the functions 

involved in the benchmarking process;

 the Charters of MOEX and of MICEX SE;

 the Terms of Reference for Index Committee, 

FX Market Committee, REPO Committee, 

Collective Investment Market Committee, the 

Executive Board of MOEX and the Management 

Board of MICEX SE;

 A selection of meeting minutes of the Executive 

Board and the Management Board.

We inspected for evidence that the above 

mentioned MOEX’s bodies are accountable for the 

respective Benchmark governance and oversight 

process as described by MOEX.
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IOSCO Principle MOEX’s response Work performed by EY

2. Oversight of third parties

Where activities relating to the Benchmark 

determination process are undertaken by third 

parties − for example collection of inputs, publication 

or where a third party acts as Calculation Agent − the 

Administrator should maintain appropriate 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 obligations of 

third parties who participate in the Benchmark 

determination process, as well as the standards the 

Administrator expects these third parties to comply 

with.

b) Monitor third parties’ compliance with the 

standards set out by the Administrator.

c) Make Available to Stakeholders and any relevant 

Regulatory Authority the identity and roles of third 

parties who participate in the Benchmark 

determination process.

d) Take reasonable steps, including contingency 

plans, to avoid undue operational risk related to 

the participation of third parties in the Benchmark 

determination process. 

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. 

This principle is not applicable for MOEX since it 

operates Benchmark determination process without 

the involvement of third parties. Benchmarks are 

based on market data generated on MOEX trading 

venues, automatically calculated and published by 

MOEX. 

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that Benchmark determination process is 

performed without the involvement of third parties.

3. Conflicts of Interests for Administrators
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IOSCO Principle MOEX’s response Work performed by EY

To protect the integrity and independence of 

Benchmark determinations, Administrators should 

document, implement and enforce policies and 

procedures for the identification, disclosure, 

management, mitigation or avoidance of conflicts of 

interest. Administrators should review and update 

their policies and procedures as appropriate. 

MOEX’ employees are restricted from participating in 

trading activities so no significant conflict of interests 

may arise.

MOEX’s business connections do not give rise to the 

conflict of interest in relation to Benchmarks since 

MOEX is a regulated exchange and it does not have 

business relationships which can compromise the 

performance of its functions as an Administrator.

MOEX implemented a conflicts of interest framework 

which consists of internal documents regarding 

conflicts of interests and confidentiality of information 

and related internal controls over identification and 

prevention of conflicts of interests. The policies and 

procedures are described in the following 

documents:

 MOEX Conflicts of Interests Policy.

 MOEX List of Insider Information.

 MOEX Information Security Policy.

 MOEX Insider Information Access Policy.

 MOEX Insider Information Illegitimate Usage 

Prevention Policy.

Details related to these documents are presented in 

point E of Principle 3

The Conflicts of Interests Policy is subject to periodic

review by the Supervisory Board and other 

documents are subject to review by the Executive 

Board and the Management Board.

The Compliance (Internal Control) Department is 

We obtained MOEX’s Conflicts of Interests Policy 

and inspected for evidence that it is reviewed and 

approved by the Supervisory Board of MOEX.

We obtained meeting minutes of the Supervisory 

Board and inspected for evidence that MOEX’s 

Conflicts of Interests Policy is reviewed and 

approved.

We obtained MOEX List of Insider Information, 

MOEX Information Security Policy, MOEX Insider 

Information Access Policy, MOEX Insider 

Information Illegitimate Usage Prevention Policy

and inspected for evidence that these documents 

are reviewed and approved by the Executive Board 

and the Management Board.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that the Compliance Department is 

responsible for implementation of controls over 

conflicts of interest and its periodic review; the 

Operational Risk Department is responsible for dayto-day identification, prevention and management of 

conflicts of interest.

We obtained the Terms of Reference of MOEX’s 

Committees (the Index Committee, FX Market 

Committee, REPO Committee and Collective 
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IOSCO Principle MOEX’s response Work performed by EY

responsible for the implementation of controls over 

conflicts of interest and review of compliance with the 

Conflicts of Interests Policy. The Operational Risk 

Department is responsible for day-to-day 

identification, prevention and management of 

conflicts of interest which can result in operational 

risks.

Members of the MOEX’s Committees are obliged to 

follow all MOEX internal policies and documents, 

including the Conflicts of Interests Policy.

The Conflicts of Interests Policy requires employees 

to declare the potential or actual conflict of interest 

when it arises and any subsequent changes in 

relation to it. Employees are required to report on 

potential and actual conflicts of interest to their 

Heads and to the Compliance (Internal Control) 

Department.

Investment Market Committee) and inspected for 

evidence that all Committee members are obliged to 

follow all MOEX internal policies and documents, 

including the Conflicts of Interests Policy.

We obtained a selection of acceptance letters and 

appointment agreements of MOEX’s Committees’

members and inspected for evidence that they are 

signed by respective Committees’ members.

We obtained examples of MOEX’s employee’s 

declarations concerning potential and actual 

conflicts of interest and inspected for evidence that:

 they are in accordance with the Conflicts of 

Interests Policy;

 they are appropriately signed by employees.

Administrators should disclose any material conflicts 

of interest to their users and any relevant Regulatory 

Authority, if any.

The Index Management Policy requires the 

disclosure of high risk potential conflict of interest to 

Benchmark users and relevant Regulatory 

Authorities. So far no high risk potential conflict of 

interests has arisen.

We obtained the Index Management Policy and 

inspected for evidence that it contains requirements 

on the disclosure of high risk potential conflict of 

interest.
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IOSCO Principle MOEX’s response Work performed by EY

The framework should be appropriately tailored to the 

level of existing or potential conflicts of interest 

identified and the risks that the Benchmark poses and 

should seek to ensure: 

a) Existing or potential conflicts of interest do not 

inappropriately influence Benchmark 

determinations.

MOEX Conflicts of Interests Policy covers the 

following issues:

 key terms and definitions essential for 

understanding the nature of conflicts of interest;

 the list of most common conflicts of interests, 

which enables employees to identify such 

conflicts;

 the procedure (including declaration of potential 

conflict of interest) of informing the administration 

concerning conflicts of interest identified (both 

potential and actual).

 the restrictions for MOEX’s employees to the 

activities which may result in the potential 

conflicts of interest: trading in securities; nondisclosure of confidential information; part-time 

employment with the clients.

MOEX employees participate in annual trainings 

regarding conflict of interest and are aware of the 

circumstances that may lead to the conflict of 

interest. In accordance with the Conflicts of Interests 

Policy they should report on the origination of a 

potential or actual conflict of interest within three 

working days.

We obtained the Conflicts of Interests Policy and 

inspected for evidence that it is covers the issues as 

described in MOEX’s response.

We obtained e-mail confirmation from the HR 

Department that the periodicity of the mandatory 

training on conflict of interests is one year. We also 

obtained the confirmation from electronic system 

confirming the attendance of trainings related to 

conflicts of interest by the employees of the Index 

Management Division.

We obtained examples of MOEX’s employee’s 

declarations concerning potential and actual 

conflicts of interest and inspected for evidence that:

 they are in accordance with the Conflicts of 

Interests Policy;

 they are appropriately signed by employees.

b) Personal interests and connections or business 

connections do not compromise the 

Administrator’s performance of its functions.

The Conflicts of Interests Policy requires employees 

to declare the potential or actual conflict of interest 

when it arises and any subsequent changes in 

relation to it. Employees are required to report on 

potential and actual conflicts of interest to their 

Heads and to the Compliance (Internal Control) 

Department.

The Conflicts of Interests Policy contains provisions 

concerning restrictions on MOEX’s employees 

participating in trading in securities, derivatives and 

We obtained the Conflicts of Interests Policy and 

inspected for evidence that:

 it requires employees to report immediately on 

conflicts of interest to their Heads and to the 

Compliance Department;

 it contains restrictions on all trading activity for 

MOEX’s employees.

We obtained examples of MOEX’s employee’s 

declarations concerning potential and actual 
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IOSCO Principle MOEX’s response Work performed by EY

other exchange instruments. conflicts of interest and inspected for evidence that:

 they are in accordance with the Conflicts of 

Interests Policy;

 they are appropriately signed by employees.

c) Segregation of reporting lines within the 

Administrator, where appropriate, to clearly define 

responsibilities and prevent unnecessary or 

undisclosed conflicts of interest or the perception 

of such conflicts.

As part of the control framework, MOEX has 

identified and documented roles and responsibilities 

of the key departments involved in the Benchmark 

determination process as described earlier in the 

response to Principle 1. The control framework is 

structured in a way to prevent potential conflict of 

interest. 

The Compliance (Internal Control) Department is 

responsible for the implementation of controls over 

conflicts of interest and review of compliance with the 

Conflicts of interests Policy. The Operational Risk 

Department is responsible for day-to-day 

identification, prevention and management of 

conflicts of interest which can result in operational 

risks. 

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that the roles of the Compliance (Internal 

Control) Department and the Operational Risk 

Department are described in this document in 

accordance with MOEX’s response.

d) Adequate supervision and sign-off by authorised 

or qualified employees prior to releasing 

Benchmark determinations.

Benchmark determination and dissemination 

process is automated in MOEX. The calculation of 

Benchmarks is performed in a predetermined way 

based on the developed calculation algorithm and 

the process is structured in a way to prevent

unauthorized access to the calculation of 

Benchmarks.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that the process is described in accordance 

with MOEX’s response.

We obtained an example of statement of work for 

the IT Department and all the relevant 

correspondence and inspected for evidence that:

 the IT Departments develops algorithm for 

automatic determination and dissemination 

process in accordance with the statement of 

work;

 internal correspondence includes finalization, 

review, testing and final approval stages for the 
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IOSCO Principle MOEX’s response Work performed by EY

algorithm developed.

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.

MOEX’s internal documents in relation to the 

confidentiality of information include:

 the Information Security Policy − major document 

stipulating general provisions concerning user 

access, confidentiality of the data, controls over 

data usage, illegitimate usage prevention; 

 the List of insider information − document stating 

the list of confidential information;

 the Insider Information Access Policy − document 

regulating the procedure of MOEX’s employees 

access to confidential information;

 the Insider Information Illegitimate Usage 

Prevention Policy − document stating procedures 

and controls aimed at prevention of illegitimate 

usage of confidential information.

In accordance with the Information Security Policy 

the employees should sign the declarations 

regarding non-disclosure of the confidential 

information.

We obtained from MOEX: 

 the Information Security Policy;

 the List of insider information;

 the Insider Information Access Policy;

 the Insider Information Illegitimate Usage 

Prevention Policy.

and inspected for evidence that these policies cover

the rules and procedures for user access, protection 

of information confidentiality, controls over data 

usage and illegitimate usage prevention.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that the Compliance Department and the 

Operational Risk Department are responsible for 

prevention of insider and confidential information 

illegitimate usage and market manipulation. 

We obtained a selection of declarations regarding 

the confidentiality and ensured that they are signed 

by the employees.

f) Effective procedures to control the exchange of 

information between staff engaged in activities 

involving a risk of conflicts of interest or between 

staff and third parties, where that information may 

reasonably affect any Benchmark determinations.

All individuals are subject to the internal documents 

including the Conflicts of Interests Policy in relation 

to the confidentiality of information which are listed 

above. In accordance with these documents 

individuals have an access to confidential 

information only within their terms of reference.

In accordance with the Information Security Policy 

the employees should sign the declarations 

regarding non-disclosure of the confidential 

information.

We obtained examples of MOEX’s employee’s 

declarations concerning potential and actual 

conflicts of interest and inspected for evidence that:

 they are in accordance with MOEX’s Conflicts of 

interests Policy;

 they are appropriately signed by employees.

We obtained a selection of acceptance letters and 

appointment agreements of MOEX’s Committees’

members and inspected for evidence that they are 

signed by respective Committees’ members.

We obtained a selection of declarations regarding 
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IOSCO Principle MOEX’s response Work performed by EY

the confidentiality and ensured that they are signed 

by the employees.
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IOSCO Principle MOEX’s response Work performed by EY

g) Adequate remuneration policies that ensure all 

staff who participate in the Benchmark 

determination are not directly or indirectly 

rewarded or incentivised by the levels of the 

Benchmark.

MOEX’s employees who participate in the 

Benchmark determination are not rewarded based 

upon the level of any Benchmarks. 

We received oral representation from the 

HR Department that the employees of Index 

Management Division are not rewarded based on 

the level of Benchmarks (the individual KPIs of the 

Head of the Index Management division for 2014 

were listed). 

We obtained the Terms of Reference for MOEX’s 

Committees’ (Index Committee, FX Market 

Committee, REPO Committee and Collective 

Investment Market Committee) and inspected for 

evidence that:

 Committees are formed of non-MOEX 

employees;

 members of Committees are not directly or 

indirectly rewarded or incentivized based on the 

levels of Benchmarks.
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IOSCO Principle MOEX’s response Work performed by EY

An Administrator’s conflict of interest framework 

should seek to mitigate existing or potential conflicts 

created by its ownership structure or control, or due 

to other interests the Administrator’s staff or wider 

group may have in relation to Benchmark 

determinations. To this end, the framework should: 

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 business of the Administrator or any of its 

affiliates.

b) Provide that an Administrator discloses conflicts of 

interest arising from the ownership structure or the 

control of the Administrator to its Stakeholders and 

any relevant Regulatory Authority in a timely 

manner.

The Central Bank of Russia (CBR) and OJSC 

Sberbank, owning 12% and 10% of MOEX

respectively, do not control and influence the 

Benchmarks since the majority of shares are in freefloat. The representatives of OJSC Sberbank and 

CBR participate in the Supervisory Board of MOEX

and in the Committees of Stakeholders, but the 

structure of the Board and the Committees is such 

that they cannot alone influence the decisions (there 

are other members in the Committees and the 

decisions are taken based on the majority of votes)

− no conflict of interest arises. 

MOEX does not have conflict of interest due to the 

fact that MOEX’s securities are included in equity 

indices. This fact is associated with the large volume 

of trades, and as a result, MOEX’s shares are 

constituents of the respective Benchmarks since the 

Constituents Lists are determined based on the 

volume of trades in securities. Also the decision for 

including MOEX’s shares in the indices is approved 

by the Index Committee.

We reviewed the shareholding structure disclosed 

on MOEX’s web-site and inspected for evidence 

that there are no majority shareholders.

We reviewed the structure and Terms of Reference

for the Supervisory Board of MOEX and the 

Committees of Stakeholders and ensured that the 

structure of the Board and the Committees and the 

decision-making procedure is the same as in 

MOEX’s response.

We reviewed the trade turnover of MOEX shares 

and inspected for evidence that:

 the majority of MOEX’s shares are in free-float;

 the turnover is sufficient enough to satisfy 

constituents criteria.

For more details concerning conflict of interest, 

please, refer to our responses stated above in 

Principle 3.

4. Control Framework for Administrators

An Administrator should implement an appropriate 

control framework for the process of determining and 

distributing the Benchmark. The control framework 

should be appropriately tailored to the materiality of 

the potential or existing conflicts of interest identified, 

the extent of the use of discretion in the Benchmark 

setting process and to the nature 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. 

As part of the internal policies and procedures on the 

Benchmarking process MOEX has implemented its 

control framework related to Benchmark 

determination. The process in described earlier in 

this section in the response to Principle 1. The 

summary of the main features is published on 

MOEX’s web-site.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that the control framework is described in 

this document. Please also see our response to 

Principle 1.

We ensured that the summary of the control 

framework is published on MOEX’s web-site.

This control framework should be reviewed Control framework is reviewed periodically and We obtained the Index Management Policy 
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IOSCO Principle MOEX’s response Work performed by EY

periodically and updated as appropriate. The 

framework should address the following areas: 

signed by the Executive Board and the Management 

Board.

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

the control framework and ensured that this 

document is signed by the Executive Board and the 

Management Board and that the procedure of the 

periodic review is stated in this policy.

a) Conflicts of interest in line with Principle 3 on 

conflicts of interests.

The control framework is structured in a way to 

prevent potential conflict of interest as described in 

the response to Principle 3.

Please see our procedures for Principle 3.
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b) Integrity and quality of Benchmark determination: 

i. Arrangements to ensure that the quality and 

integrity of Benchmarks is maintained, in line with 

principles 6 to 15 on the quality of the Benchmark 

and Methodology.

ii. Arrangements to promote the integrity of 

Benchmark inputs, including adequate due 

diligence on input sources.

i. The Executive Board of MOEX and the 

Management Board of MICEX SE act as an 

oversight function, performing the review and 

approval of the Benchmark Methodologies and 

oversight over the functions involved in the 

benchmarking process (all functions involved, 

except for Independent Committees of 

Stakeholders, are accountable to the Executive 

Board of MOEX).

MOEX’s Committees consist of representatives of 

external Stakeholders and are responsible for the 

independent oversight function, including periodic 

review of Benchmark Methodologies, parameters 

and constituents lists of the Benchmarks in case it is 

applicable acting as a Stakeholder consultation 

function. Each Committee operates within the scope 

of its functionality and expertise: FX Market 

Committee deals with the issues concerning 

FX Fixings and SWAP Indicators, REPO Committee 

is responsible for repo Indicators, Collective 

Investment Market Committee reviews issues 

concerning Pension Indices and Index Committee is 

responsible for Equity and Bond indices.

The Compliance (Internal Control) Department and 

the Operational Risk Department are responsible for 

performing control function over the Benchmark 

process, including conflicts of interest issues, 

whistleblowing process, compliance review, 

business continuity issues, error reports and 

information security.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that the process is stated as described in 

MOEX’s response.

Please see our procedures for Principles 6-16.
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iii. Arrangements to ensure accountability and 

complaints mechanisms are effective, in line with 

principles 16 to 19.

iv. Providing robust infrastructure, policies and 

procedures for the management of risk, including 

operational risk.

ii. The process of Benchmark determination is 

automated with data flowing automatically from 

the trading system.

Trading data is reviewed by the Index Management 

Division on a selective periodic basis and in case 

significant volatility of the index is identified or alert 

reports from the Operational Risk Department are 

received. 

Constituents Lists for Benchmarks are reviewed and 

recommended for the approval by the respective

MOEX’s Committee (Index Committee, FX Market 

Committee, REPO Committee, Collective 

Investment Market Committee), which meet on 

periodic basis. Constituent Lists are then updated 

manually in the system by the Index Management 

Division employees. Afterwards the market data on 

constituents is used by the system for the automatic 

indices calculation procedure.

iii. The Index Management Division is responsible 

for the complaints procedure. The details are in 

the response to Principle 16.

iv. The Operational Risk Department is responsible 

for the management of operational risk. The 

Operational Risk Department is responsible for 

identification, alerting and management of errors, 

technical disruptions and other problems in 

Benchmark determination process on a day-today basis. This Department covers 4 major areas 
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IOSCO Principle MOEX’s response Work performed by EY

of risks: IT risks, Business risks, External risks 

and Human Factor. The most significant control 

is performed over IT risks in Benchmarking

process: the Operational Risk Department 

performs tests over the software at all its stages 

of functioning (development, introduction and 

afterwards daily monitoring). Please also refer to 

the response to the Principle 1.
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IOSCO Principle MOEX’s response Work performed by EY

c) Whistleblowing mechanism: Administrators should 

establish an effective whistleblowing mechanism 

to facilitate early awareness of any potential 

misconduct or irregularities that may arise. This 

mechanism should allow for external reporting of 

such cases where appropriate.

The Compliance (Internal Control) Department is 

responsible for whistleblowing procedures. 

Whistleblowing mechanism is described in the Code 

of Ethics.

MOEX’s Code of Ethics provides a summary of 

major misconduct issues (e.g. non-compliance with 

internal procedures, corruption, unethical behavior) 

and what MOEX employees should do in such cases 

(including reporting internally − whistleblowing). 

MOEX also has a mandatory training program for 

employees, which covers issues concerning 

whistleblowing procedures and reporting, 

importance of early awareness of any potential 

misconduct or irregularities.

We obtained MOEX’s Code of Ethics and inspected 

for evidence that it contains a summary of major 

issues of misconduct and the requirement for 

MOEX’s employees to report on such issues.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that this document states the roles of the 

Compliance department for whistleblowing 

mechanism.

We obtained an obligatory training schedule and 

electronic confirmation that MOEX’s employees 

attend trainings on a periodic basis.

d) Expertise: 

i. Ensuring Benchmark determinations are made by 

personnel who possess the relevant levels of 

expertise, with a process for periodic review of 

their competence; and 

ii. Staff training, including ethics and conflicts of 

interest training, and continuity and succession 

planning for personnel.

The HR Department ensures that employees 

involved in Benchmark determination process have 

relevant level of expertise and knowledge based on 

the job description received from relevant business 

lines. Each employee has its individuals 

performance goals stated for each year which are 

subject to appraisal and discussion with the Head of 

division. MOEX’s Committees (Index Committee, FX 

Market Committee, REPO Committee and Collective

Investment Market Committee) are formed from 

market professionals with exceptional knowledge, 

reputation and expertise.

All personnel are obliged to attend FFMS 2.0 

examination (Federal Financial Markets Service 

professional certificate). Each employee may attend 

MOEX Business University (program of staff 

development) and has its personal training schedule.

We obtained the Terms of Reference of MOEX’s 

Committees (Index Committee, FX Market 

Committee, REPO Committee and Collective 

Investment Market Committee) and inspected for 

evidence that these documents state strict criteria 

for Committee applicants, ensuring their level of 

knowledge and expertise. We also reviewed the 

Committees’ Membership List, which is publicly 

available on MOEX’s web-site and ensured that 

Committees are formed by market professionals 

with relevant experience.

We obtained oral representation from the HR 

department and verified that there is a formal 

performance appraisal for the employees and this 

process takes into account the progress in relation 

to trainings.

We obtained training schedule for MOEX’s 

personnel and ensured that it is in place, covers 

such issues as ethics and conflicts of interest and it 
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IOSCO Principle MOEX’s response Work performed by EY

is aimed at professional development and growth of 

employees.

Where a Benchmark is based on Submissions: 

Administrators should promote the integrity of inputs 

by:

a) Ensuring as far as possible that the Submitters 

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 and specifying that inputs or Submissions 

should be made for every Benchmark 

determination.

d) Establishing and employing measures to effectively 

monitor and scrutinise inputs or Submissions. This 

should include pre-compilation or pre-publication 

monitoring to identify and avoid errors in inputs or 

Submissions, as well as ex-post analysis of trends 

and outliers. 

MOEX’s Benchmarks are not based on 

Submissions so this part is not applicable to MOEX.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that Benchmark determination is not based 

on Submissions.
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IOSCO Principle MOEX’s response Work performed by EY

5. Internal Oversight

Administrators should establish an oversight function 

to review and provide challenge on all aspects of the 

Benchmark determination process. This should 

include consideration of the features and intended, 

expected or known usage of the Benchmark and the 

materiality of existing or potential conflicts of interest 

identified. 

The oversight function should be carried out either by 

a separate committee, or other appropriate 

governance arrangements. The oversight function 

and its composition should be appropriate to provide 

effective scrutiny of the Administrator. Such oversight 

function could consider groups of Benchmarks by 

type or asset class, provided that it otherwise 

complies with this Principle.

The Index Management Division of MOEX is 

responsible for the administrative functions of the 

Benchmark determination process and accountable 

to the Executive Board of MOEX. The Executive 

Board of MOEX and the Management Board of 

MICEX SE oversight and approve policies and 

procedures related to the benchmarking process as 

well as responsible for the review of internal control 

reports and operational risk reports.

Supervisory Board of MOEX and Board of Directors 

of MICEX SE are responsible for appointment of 

members of Independent Committees of 

Stakeholders for the key market segments: FX 

Market Committee, REPO Committee, Collective 

Investment Market Committee, Index Committee.

MOEX’s Committees consist of representatives of 

external Stakeholders and are responsible for the 

independent oversight function, including periodic

review of Benchmark Methodologies, parameters 

and constituents lists of the Benchmarks in case it is 

applicable acting as a Stakeholder consultation 

function. Each Committee operates within the scope 

of its functionality and expertise: FX Market 

Committee deals with the issues concerning 

FX Fixings and SWAP Indicators, REPO Committee 

is responsible for repo Indicators, Collective 

Investment Market Committee reviews issues

concerning Pension Indices and Index Committee is 

responsible for Equity and Bond indices.

We obtained and reviewed:

 The Index Management Policy describing the 

roles and responsibilities of all the functions 

involved in the benchmarking process;

 the Charters of MOEX and of MICEX SE;

 the Terms of Reference for Index Committee, 

FX Market Committee, REPO Committee, 

Collective Investment Market Committee, the 

Executive Board of MOEX and the Management 

Board of MICEX SE, the Supervisory Board of 

MOEX and the Board of Directors of MICEX SE;

 A selection of meeting minutes of the Executive 

and the Management Board, the Supervisory 

Board and the Board of Directors.

We inspected for evidence that roles and 

responsibilities of the above mentioned bodies are 

the same as described in MOEX’s response.
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IOSCO Principle MOEX’s response Work performed by EY

An Administrator should develop and maintain robust 

procedures regarding its oversight function, which 

should be documented and available to relevant 

Regulatory Authorities, if any. The main features of 

the procedures should be Made Available to 

Stakeholders. These procedures should include: 

a) The Terms of Reference of the oversight function.

b) Criteria to select members of the oversight 

function.

c) The summary details of membership of any 

committee or arrangement charged with the 

oversight function, along with any declarations of 

conflicts of interest and processes for election, 

nomination or removal and replacement of 

committee members.

Terms of References for the Executive Board and 

the Management Board and Committees are publicly 

available on MOEX’s web-site.

Criteria to select members and the processes for 

election, nomination or removal and replacement of 

members are stated in the Terms of References.

In accordance with the Conflicts of Interests Policy

the members of the Executive and Management 

Board are subject to this policy and should provide 

declarations when necessary.

In accordance with the Terms of References for the 

Committees of Stakeholders they are subject to 

internal policies and procedures of MOEX and also 

should provide declarations when necessary.

We examined the Terms of Reference for Index 

Committee, FX Market Committee, REPO 

Committee, Collective Investment Market 

Committee and the Executive and Management 

Board and inspected for evidence that:

a) they are publicly available on MOEX’s web-site;

b) they state clear criteria for membership and an 

application procedure;

c) they contain provisions concerning election, 

nomination or removal and replacement of 

members. For conflict of interest procedures, 

please, see Principle 3, stated above.

The responsibilities of the oversight function include: 

a) 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 

(as appropriate).

iii. Overseeing any changes to the Benchmark 

Methodology, including assessing whether the 

Methodology continues to appropriately measure 

the underlying Interest, reviewing proposed and 

implemented changes to the Methodology, and 

authorising or requesting the Administrator to 

undertake a consultation with Stakeholders where 

known or its Subscribers on such changes as per 

Principle 12.

iv. Reviewing and approving procedures for 

termination of the Benchmark, including guidelines 

The Executive Board and the Management Board 

and Committees of Stakeholders are responsible for 

the oversight of Benchmark design:

The Executive Board of MOEX and the Management 

Board of MICEX SE perform periodic review and 

approval of the Benchmark Methodologies, 

assessing the appropriateness of the Methodologies 

and the necessity of termination of the Benchmarks.

MOEX’s Committees (Index Committee, FX Market 

Committee, REPO Committee and Collective 

Investment Market Committee) perform independent 

periodical review of Benchmark Methodologies 

acting as a Stakeholder consultation function. 

All the functions involved in the Benchmarking 

process report to the Executive Board of MOEX so 

the Board is aware of issues and risks related to 

Benchmarks’ determination.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

Benchmark Methodologies and inspected for 

evidence that:

i. MOEX’s Committees and the Executive and 

the Management Boards are responsible for 

periodical review of the Benchmarks definition 

and their Methodologies, including Constituent 

Lists.

ii.-iii. Committees and the Executive and the 

Management Boards are responsible for 

periodic assessment of Benchmark being upto-date with market conditions;

iv. Committees and the Executive and the 

Management Boards are responsible for the 

Benchmark decommissioning procedure. 

We obtained meeting minutes of the Executive 

Board and the Management Board and inspected 
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IOSCO Principle MOEX’s response Work performed by EY

that set out how the Administrator should consult 

with Stakeholders about such cessation. 

for evidence that changes to the Benchmark 

Methodologies have been approved by them.

We obtained meeting minutes of the Supervisory 

Board of MOEX and inspected for evidence that the 

reports of the Compliance Department are reviewed 

by the Board.

We obtained meeting minutes of the Executive 

Board of MOEX and inspected for evidence that the 

reports of the Operational Risk Department are 

reviewed by the Board.

b) Oversight of the integrity of Benchmark 

determination and control framework: 

i. Overseeing the management and operation of the 

Benchmark, including activities related to 

Benchmark determination undertaken by a third 

party.

ii. Considering the results of internal and external 

audits, and following up on the implementation of 

remedial actions highlighted in the results of these 

audits.

iii. Overseeing any exercise of Expert Judgment by 

the Administrator and ensuring Published 

Methodologies have been followed.

The Executive Board of MOEX reviews periodic 

reports provided by Operational Risk Department

and reports provided by Compliance (Internal 

Control) Department. The reports include issues 

related to the benchmarking process.

All the functions involved in the Benchmarking 

process (including the Compliance Department) 

report to the Executive Board of MOEX.

The Executive Board of MOEX reviews the reports 

of the functions involved in Benchmarks 

determination and approves the Methodologies.

We obtained meeting minutes of the Executive 

Board of MOEX and of the Management Board of 

MICEX SE and inspected for evidence that the 

reports of the Operational Risk Department and 

Compliance Department are reviewed by the

Executive Board of MOEX and Management Board 

of MICEX SE.

We obtained:

 the Terms of Reference for the Executive Board 

of MOEX and the Management Board of MICEX 

SE;

 Meeting minutes of the Executive Board and the 

Management Board.

and inspected for evidence that MOEX’s Executive 

and Management Boards review the Constituents 

Lists and free-float which relates to the area of 

Expert Judgment exercise.
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IOSCO Principle MOEX’s response Work performed by EY

Where conflicts of interests may arise in the 

Administrator due to its ownership structures or 

controlling interests, or due to other activities 

conducted by any entity owning or controlling the 

Administrator or by the Administrator or any of its 

affiliates: the Administrator should establish an 

independent oversight function which includes a 

balanced representation of a range of Stakeholders 

where known, Subscribers and Submitters, which is 

chosen to counterbalance the relevant conflict of 

interest. 

Committees of Stakeholders act as an independent 

Stakeholder consultation function and report to the 

Executive Board and the Management Board.

Please, refer to our responses stated above in 

Principle 3.

Where a Benchmark is based on Submissions: the 

oversight function should provide suitable oversight 

and challenge of the Submissions by: 

a) Overseeing and challenging the scrutiny 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 in challenging 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.

d) 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 becomes 

aware to the relevant Regulatory Authorities, if 

any.

MOEX’s Benchmarks are not based on Submissions 

so this part is not applicable to MOEX

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that Benchmark determination is not based 

on Submissions.

6. Benchmark Design

The design of the Benchmark should seek to achieve, The Benchmark design and what the Benchmark is For each MOEX’s Index, we obtained Benchmark 
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IOSCO Principle MOEX’s response Work performed by EY

and result in an accurate and reliable representation 

of the economic realities of the Interest it seeks to 

measure, and eliminate factors that might result in a 

distortion of the price, rate, index or value of the 

Benchmark. 

intended to measure are detailed in respective 

Benchmark Methodologies. The principles of 

Benchmarks determination are aimed to eliminate 

factors that may distort Benchmarks and described 

in these methodologies.

For Equity, Bond and Pension Indices there is a 

criteria for the determination of the Constituent’s 

Lists.

For REPO indicators and SWAP rates indicators the 

criteria for including deals and securities and deals 

with currencies respectively in the calculation is 

stated in the methodology.

For FX Fixings the base for calculation is stated in 

the methodology.

Methodologies and inspected for evidence that the 

design and the purpose of Benchmarks are 

described in the respective methodologies.

We ensured that the criteria for Constituent Lists’

determination are included in Equity, Bond and 

Pension Indices Methodologies.

We ensured that REPO indicators and SWAP rates

indicators methodologies describe criteria for deals

and securities to be included in the Methodologies.

We ensured the base for FX Fixings is described in 

the methodologies.
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IOSCO Principle MOEX’s response Work performed by EY

Benchmark design should take into account the 

following generic non-exclusive features, and other 

factors should be considered, as appropriate to the 

particular Interest: 

a) Adequacy of the sample used to represent the 

Interest.

b) Size and liquidity of the relevant market (for 

example whether there is sufficient trading to 

provide observable, transparent pricing).

c) Relative size of the underlying market in relation to 

the volume of trading in the market that references 

the Benchmark.

d) The distribution of trading among Market 

Participants (market concentration).

e) Market dynamics (e.g., to ensure that the 

Benchmark reflects changes to the assets 

underpinning a Benchmark).

Benchmarks are based on the data obtained from 

MOEX trading venues. In accordance with 

Benchmark Methodologies the following is taken into 

account in Benchmarks calculations:

Equity Indices: the determination of the Constituent 

List is based on the variety of eligibility criteria in 

order to eliminate illiquid or non-representative 

stocks. 

Bond Indices: the determination of the Constituent 

List is based on the criteria such as issue size, 

liquidity and issuer’s rating.

Pension Indices: Constituent List is determined 

based on issue size, trading volume (liquidity), 

maturity, issuer’s rating and others depending on the 

type of the Pension Index (equity or bond).

REPO Indices and SWAP rates indicators: The 

criteria for the selection of deals and securities and 

deals with currencies respectively used in the 

calculation are determined in a way to take into 

account the expectations of market participants.

FX Indices: calculated based on ask, bid and 

matched deals levels obtained from MOEX FX 

Market.

The Index Management Policy contains provisions 

concerning procedures that should be performed in 

order to calculate reliable Benchmarks in case of 

absence or insufficient inputs. Such procedures 

include using of last trade data or previous day 

prices, changes to Constituents Lists and 

parameters for calculation.

We obtained Benchmark Methodologies and 

ensured that they describe the Benchmarks 

determination as in MOEX’s response.

We obtained a selection of meeting minutes of Index 

Committee and Collective Investment Market 

Committee and inspected for evidence that the 

Constituents Lists are reviewed on a periodic basis 

in order to measure appropriately the underlying 

interest.

We obtained the Index Management Policy and 

ensured that it contains procedure for dealing with 

insufficient inputs and the absence of inputs as 

described in MOEX’s response.

7. Data sufficiency

The data used to construct a Benchmark The data is obtained directly from MOEX’s trading We obtained Benchmark Methodologies and 
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determination should be sufficient to accurately and 

reliably represent the Interest measured by the 

Benchmark and should: 

a) Be based on prices, rates, indices or values that 

have been formed by the competitive forces of 

supply and demand in order to provide confidence 

that the price discovery system is reliable.

b) Be anchored by observable transactions entered 

into at arm’s length between buyers and sellers in 

the market for the Interest the Benchmark 

measures in order for it to function as a credible 

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 Bona Fide, 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 to rely on different 

forms of data tied to observable 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 prior transactions. This is 

venues − the Regulated Market of the Russian 

Federation. No Submissions are used in determining 

Benchmarks. 

FX Fixings: MOEX computes currency rates based 

on the following data on FX trading: orders directed 

to all trading participants (indirect orders) and trades 

executed based on the indirect orders. FX Fixings 

are determined based on the average values of 

trades and orders prices.

Equity, Bonds, Pension indices: Calculated based on

the information on trades in equities, bonds and 

Russian depository receipts representing stocks, as 

well as other securities that may be used to calculate 

the indices in accordance with requirements stated 

in the regulatory acts for financial markets.

REPO Indicators: The indices are calculated based 

on the repo deals with securities which are traded on 

MOEX trading venues.

SWAP rates Indicators: The indices are calculated 

based on the swap deals with currencies which are 

traded on MOEX trading venues.

ensured that the base for Benchmarks calculations 

and data used for these calculations is stated as in 

MOEX’s response.

We obtained the Index Management Policy and 

ensured that it states that the methodologies should 

be reviewed not less than once a year to assess 

whether they still represent accurately the 

underlying interest. 
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IOSCO Principle MOEX’s response Work performed by EY

further clarified in Principle 8.

Provided that subparagraphs (a) and (b) above are 

met, Principle 7 does not preclude Benchmark 

Administrators from using executable bids or offers as 

a means to construct Benchmarks where anchored in 

an observable market consisting of Bona Fide, ArmsLength transactions.23 

This Principle also recognizes that various indices 

may be designed to measure or reflect the 

performance of a rule-based investment strategy, the 

volatility 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 for such 

indices that are not designed to represent 

transactions and where the nature of the index is 

such that non-transactional data is used to reflect 

what the index is designed to measure. For example, 

certain volatility indices, which are designed to 

measure the expected volatility of an index of 

securities transactions, rely on non-transactional 

data, but the data is derived from and thus “anchored” 

in an actual functioning securities or options market.

8. Hierarchy of data inputs

An Administrator should establish and Publish or 

Make Available clear guidelines regarding the 

hierarchy of data inputs and exercise of Expert 

Judgment used for the determination of Benchmarks. 

In general, the hierarchy of data inputs should 

include: 

For each Benchmark the description of data inputs is 

stated in respective Benchmark Methodologies, 

which are publicly available on MOEX’s web-site.

For detailed description for each family of 

Benchmarks please see our response to Principle 6.

MOEX’s Benchmarks are based on data sourced 

from MOEX’s trading platform as described above. 

We obtained Benchmark Methodologies and 

ensured that:

 they describe inputs for each Benchmark;

 they are publicly available on MOEX’s web-site;

 the criteria for Constituents Lists determination 

is stated in respective methodologies.
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IOSCO Principle MOEX’s response Work performed by EY

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 the underlying interest.

c) Reported or observed concluded Arm’s-length 

Transactions in related markets.

d) Firm (executable) bids and offers.

e) 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 to restrict an Administrator’s flexibility to use 

inputs consistent with the Administrator’s approach to 

ensuring the quality, integrity, continuity and reliability 

of its Benchmark determinations, as set out in the 

Administrator’s Methodology. The Administrator 

should retain flexibility to use the inputs it believes are 

appropriate under its Methodology to ensure the 

quality and integrity of its Benchmark. For example, 

certain Administrators may decide to rely upon Expert 

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 

an outlier transaction. Under these circumstances, 

non-transactional data such as bids and offers and 

extrapolations from prior transactions might 

No Submissions are used in determining 

Benchmarks. 

Expert Judgment is used in determination of the 

Constituent Lists and free-float factor (for the equity, 

bond and pension indices). 

The criteria for Constituent Lists determination is 

stated in respective Benchmark Methodologies. 

MOEX’s Index Committee reviews and approves 

Constituent Lists quarterly and also in case of 

specific corporate events stated in Methodologies. 

Index Committee may recommend inclusion and 

exclusion of constituents based on criteria specified 

in Methodologies. 

Free-float is determined in accordance with FreeFloat Methodology which is publicly available on 

MOEX’s web-site. Expert Judgment over free-float is 

exercised through Index Committee 

recommendations on decreasing the number of 

floating securities based on criteria stated in the 

Free-Float Methodology. 

We obtained Free-float Methodology and inspected 

for evidence that:

 it is stated that Index Committee may provide 

recommendation to limit the free-float for a stock 

included in an index in order to avoid 

inconsistency between the stock’s weight in the 

index and its liquidity;

 the methodology is publicly available on MOEX’s 

web-site.

We obtained a selection of meeting minutes of Index 

Committee and Collective Investment Market 

Committee and inspected for evidence that the 

Constituents Lists are reviewed on a periodic basis 

in order to measure appropriately the underlying 

interest.
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IOSCO Principle MOEX’s response Work performed by EY

predominate in a given Benchmark determination.

9. Transparency of Benchmark determinations

The Administrator should describe and publish with 

each Benchmark determination, to the extent 

reasonable without delaying an Administrator 

publication deadline: 

a) A concise explanation, sufficient to facilitate a 

Stakeholder’s or Market Authority’s ability to 

understand how the determination was developed, 

including, at a minimum, the size and liquidity of 

the market being assessed (meaning the number 

and volume of transactions submitted), the range 

and average volume and range and average of 

price, and indicative percentages of each type of 

market data that have been considered in a 

Benchmark determination; terms referring to the 

pricing Methodology should be included (i.e., 

transaction-based, spread-based or 

interpolated/extrapolated).

Since MOEX is a regulated market the trading data 

used for Benchmark determination is publicly 

available on MOEX’s web-site. Benchmark 

determination procedure for each index family is 

publicly available on MOEX’s web-site.

a) The procedure for each index family is 

standardized and no additional information is 

published on a daily basis. MOEX’s trading data 

used for Benchmarks calculations is publicly 

available on MOEX’s web-site. In each respective 

methodology the formulas for Benchmarks 

calculation and the basis for Constituents Lists 

determination are described. Any changes to 

methodologies or Constituents lists are published on 

MOEX’s web-site together with detailed explanations 

and statistical data. The list of securities included in 

Constituents Lists is also publicly available on 

MOEX’s web-site.

We ensured that trading data is publicly available 

on MOEX’s web-site.

We obtained Benchmark Methodologies and

ensured that:

 they describe Benchmarks determinations as 

stated in MOEX’s response;

 they are publicly available on MOEX’s web-site.

We ensured that Constituents Lists are published 

on MOEX’s web-site.

We reviewed a selection of MOEX’s pressreleases and inspected for evidence that:

 they include statements concerning changes to 

Benchmark Methodologies and the Constituent 

List and effective date of changes coming into 

force;

 they include MOEX’s explanations concerning 

the changes;

 they are publically available on MOEX’s website 

(http://www.moex.com/en/news/?ncat=206).

b) A concise explanation of the extent to which and 

the basis upon which Expert Judgment if any, was 

used in establishing a Benchmark determination.

b) The extent of the exercise of Expert Judgment is 

described in the response to Principle 8. 

Please see our response to Principle 8.
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10. Periodic review

The Administrator should periodically review 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 the Interest has diminished or is nonfunctioning such that it can no longer function as the 

basis for a credible Benchmark. 

The Executive Board of MOEX and the Management 

Board of MICEX SE together with MOEX’s

Committees perform periodic reviews of the 

Benchmark Methodologies in order to determine 

whether the changes to the design of the 

Methodology are required or whether the Benchmark 

is no longer a credible Benchmark.

MOEX’s Equity, Bond and Pension indices are 

based on the Constituent Lists which are reviewed 

once per quarter by MOEX’s Index Committee and 

Collective Investment Market Committee. These 

reviews are conducted in accordance with 

Benchmark Methodologies, ensuring that 

constituents, which do not satisfy criteria are not 

included in the list.

In addition to periodic scheduled reviews, MOEX’s 

Committees can perform unplanned reviews of the 

constituents. In this case only elimination of nonrepresentative constituents can take place (for 

example, in case of specific corporate events like 

bankruptcy or reorganization).

It works similar for the FX Fixings, REPO indicators 

and SWAP rates indicators and the respective 

Methodology reviewed by the respective MOEX’s 

Independent Committee.

We obtained the Index Management Policy and 

ensured that it is stated in the policy that the 

methodologies are reviewed not less than once a 

year and the decommissioning procedure is 

described.

We obtained Benchmark Methodologies and 

ensured that:

 they contain the procedure of the Constituent 

List quarterly review by MOEX’s Committees;

 they contain provisions concerning unplanned 

review of the constituents by MOEX’s 

Committees.

We reviewed a selection of meeting minutes of the 

Executive Board and the Management Board and

MOEX’s Committees and inspected for evidence 

that they include items concerning changes to 

Benchmark Methodologies and the Constituent 

Lists.

The Administrator should Publish or Make Available a 

summary of such reviews where material revisions 

have been made to a Benchmark, including the 

rationale for the revisions. 

All changes to Benchmark Methodologies and 

Constituent Lists are published on MOEX’s web-site

via press-releases, which are accompanied by 

explanations and rationale for the revision. The 

history of Methodologies changes is also available 

on MOEX’s web-site.

We reviewed a selection of MOEX’s press-releases 

and inspected for evidence that they include items

concerning changes to Benchmark Methodologies 

and the Constituent Lists and rationale for change.
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11. Content of the Methodology

The Administrator should document and Publish or 

Make Available the Methodology used to make 

Benchmark determinations. The Administrator should 

provide the rationale for adopting a particular 

Methodology. The Published Methodology should 

provide sufficient detail to allow Stakeholders to 

understand how the Benchmark is derived and to 

assess its representativeness, its relevance to 

particular Stakeholders, and its appropriateness as a 

reference for financial instruments. 

MOEX documents and publishes Methodologies for 

Benchmark determination on its official web-site. 

When publishing new or revised methodology, 

MOEX provides rationale for adopting these 

changes via press-releases. The Methodologies 

include the description of how the Benchmark is 

calculated and the base for the calculation.

There is a description on MOEX’s web-site for each 

Benchmark in relation to the rationale for 

Methodologies, relevance of Benchmarks for 

Stakeholders’ needs and how it was derived.

We ensured that there is a description on MOEX’s 

web-site for each Benchmark stating the rationale 

for Methodologies, the relevance of Benchmark

and how it was derived.

For each MOEX’s index, we obtained Benchmark 

Methodologies and inspected for evidence that:

 they include the Benchmark determination 

procedure;

 they are publicly available on MOEX’s web-site 

(http://moex.com/en/).

We reviewed a selection of MOEX’s pressreleases and inspected for evidence that:

 they include statements concerning changes to 

Benchmark Methodologies and the Constituent 

List and effective date of changes coming into 

force;

 they include MOEX’s rationale for adopting 

these changes;

 they are publicly available on MOEX’s web-site 

(http://www.moex.com/en/news/?ncat=206).

At a minimum, the Methodology should contain: 

a) Definitions of key terms.

Key terms are described in all Methodologies. The 

examples of key terms are: Constituents Lists, Freefloat coefficient, Divisor, Weighting coefficient.

For each MOEX’s Index, we obtained Benchmark 

Methodologies and inspected for evidence that they 

contain definition of the Benchmark and respective 

key terms as described in MOEX’s response.
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IOSCO Principle MOEX’s response Work performed by EY

b) All criteria and procedures used to develop the 

Benchmark, including input selection, the mix of 

inputs used to derive the Benchmark, the 

guidelines that 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.

For each Benchmark the description of data inputs 

and calculation techniques are stated in respective 

Benchmark Methodologies. Methodologies include 

the calculation of rates, free-float, the Divisor value, 

the weighting coefficient values calculation and other 

basic parameters. Methodologies also state the 

principles of determination of the Constituent Lists, 

their review by the Index Committee and changes to 

be made in case of corporate events.

For each MOEX’s index, we obtained Benchmark 

Methodologies and inspected for evidence that:

 they describe the criteria for the data input;

 they describe the calculation details (including 

the calculation of prices, the free-float, the 

Divisor value, the weighting coefficient values);

 they describe the principles of the Constituent 

List determination and the review process 

(including changes due to corporate events).

c) Procedures and practices designed to promote 

consistency in the exercise of Expert Judgment 

between Benchmark determinations.

The procedures in relation to the exercise of Expert 

Judgment are stated in Methodologies and 

described in response to Principle 8.

Please see response to Principle 8.

d) The procedures which govern Benchmark 

determination in periods of market stress or 

disruption, or periods where data sources may be 

absent (e.g., theoretical estimation models).

The Index Management Policy contains provisions 

concerning procedures that should be performed in 

order to calculate reliable Benchmarks in case of 

absence or insufficient inputs. It is stated that if 

circumstances or events occur that can have an 

adverse impact on the accuracy and fair 

representation of the Russian market by the indices.

MOEX is responsible to undertake actions 

necessary to ensure the accuracy of the Index (using 

last trade data or previous day data, changes to 

Constituents Lists and to parameters used for 

calculation).

We obtained the Index Management Policy and 

ensured that it contains procedure for dealing with 

insufficient inputs and the absence of inputs as 

described in MOEX’s response.

e) The procedures for dealing with error reports, 

including when a revision of a Benchmark would 

be applicable.

The Index Management Policy contains provisions 

concerning procedures related to errors in 

calculations due to a technical disruption. It is stated 

that MOEX should perform the recalculation as soon 

as possible after the technical disruption was 

reported. In case of recalculation of the Index values 

a relevant notice is published on MOEX’s web-site.

We obtained the Index Management Policy and 

ensured that it contains procedure for dealing with 

error reports as described in MOEX’s response.
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IOSCO Principle MOEX’s response Work performed by EY

f) Information regarding the frequency for internal 

reviews and approvals of the Methodology. Where 

applicable, the Published Methodologies should

also include information regarding the procedures 

and frequency for external review of the 

Methodology.

The Index Management Policy states that 

Methodologies are reviewed not less than once a 

year by the respective Committees which are formed 

by external representatives in order to take into 

account the current Russian market conditions and 

to meet the requirements of Stakeholders. 

In Equity, Bond and Pension indices Methodologies 

it is stated that the Constituent List is reviewed once 

per quarter by the Index Committee and Collective 

Investment Market Committee. 

Constituent Lists can be reviewed when needed in 

case there are specific evidences as stated in 

Methodologies (for example, specific issuer’s 

corporate events take place or the stocks are 

excluded from the list of securities admitted to 

trading on MOEX). 

For each Equity, Bond and Pension Indices, we 

obtained Benchmark Methodologies and inspected 

for evidence that the internal review of constituents 

procedure is clearly stated, including periodic and 

unplanned reviews (in case of specific events). 

We obtained the Index Management Policy and 

ensured that it is stated in the policy that the 

Methodologies are reviewed not less than once a 

year.

We obtained a selection of meeting minutes of the

Executive Board of MOEX, Management Board of 

MICEX SE and Index Committee, FX Market 

Committee, REPO Committee and Collective 

Investment Market Committee and inspected for 

evidence that respective Committees conduct 

periodic reviews of Methodologies and Constituent 

Lists.

We reviewed a selection of MOEX’s press-releases 

and inspected for evidence that:

 they include statements concerning changes to 

Benchmark Methodologies and the Constituent 

Lists and effective date of changes coming into

force;

 they include MOEX’s explanations concerning 

the required changes;

 they are publicly available on MOEX’s web-site

at http://www.moex.com/en/news/?ncat=206.

g) The circumstances and procedures under which 

the Administrator will consult with Stakeholders, 

as appropriate.

The Consultation with Stakeholders is performed in 

case of adoption of new Methodologies or changes 

to the existing Methodologies (including changes to 

Constituents Lists).

Consultation with Stakeholders is performed through 

We obtained:

 the Terms of Reference for Index Committee, 

FX Market Committee, REPO Committee and 
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the MOEX’s Committees. These Committees 

represent the major Stakeholders with relevant 

expertise and knowledge, who are not the 

employees of MOEX. The application procedure to 

these Committees is open and publicly available on 

MOEX’s web-site. The decision on inclusion in the 

Committee’s membership is made by the 

Supervisory Board of MOEX and the Board of 

Directors MICEX SE. The Committees can give their 

comments and opinion concerning Benchmark 

Methodologies.

Collective Investment Market Committee;

 a selection of meeting minutes of Index 

Committee, FX Market Committee, REPO

Committee and Collective Investment Market 

Committee;

and inspected for evidence that:

 Committees include only non-MOEX employees 

with industry expertise and knowledge;

 Committees perform Stakeholder consultation 

functions and provide a quorum of Stakeholder

representatives.

h) The identification of potential limitations of a 

Benchmark, including its operation in illiquid or 

fragmented markets and the possible 

concentration of inputs.

The Index Management Policy contains provisions 

concerning potential limitations of Benchmarks. If 

circumstances or events occur that can have an 

adverse impact on the Benchmark and accuracy of 

its indication of the actual state of the Russian 

security and FX market, MOEX must undertake 

actions necessary to ensure accuracy of the Index, 

including removal of securities from the Constituents 

Lists, setting values of parameters used for 

calculation of the indicators specified in the

Methodology.

We obtained the Index Management Policy and 

ensured that it contains procedure for dealing with 

insufficient inputs and the absence of inputs.

Where a Benchmark is based on Submissions, the 

additional Principle also applies: 

The Administrator should clearly establish criteria for 

including and excluding Submitters. The criteria 

should consider any issues arising from the location 

of the Submitter, if in a different 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 to changes in composition, 

including notice periods should be made clear.

This part is not applicable to MOEX since 

Benchmarks are not based on Submissions.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that Benchmark determination is not based 

on Submissions.
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IOSCO Principle MOEX’s response Work performed by EY

12. Changes to the Methodology

An Administrator should Publish or Make Available 

the rationale of any proposed material change in its 

Methodology, and procedures for making such 

changes. These procedures should clearly define 

what constitutes a material change, and the method 

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 are proposed, the 

Administrator should specify exactly what these 

changes entail and when they are intended to apply. 

The Administrator should specify how changes to the 

Methodology will be scrutinised, by the oversight 

function.

As stated in the Index Management Policy changes 

to calculation algorithms, changes to the process of 

Constituents Lists’ update, input data, periods of 

calculation are considered to be material changes.

All changes to Benchmark Methodologies are 

reviewed by MOEX’s Committees and then 

approved by the Executive Board of MOEX and by 

the Management Board of MICEX SE. Approved 

Methodology changes are published on MOEX’s

web-site via official press-releases together with the 

rationale underlying the changes and the timetable 

for their implementation.

All changes to the Benchmark Methodologies 

including quarterly changes to Constituents Lists are 

disclosed on MOEX’s web-site at least two weeks 

prior to the day when changes come into force to 

allow users time to prepare. The notices on the 

unplanned review of Constituent Lists are disclosed 

on MOEX’s web-site not later than one day before 

the day when changes come into force.

The Executive Board and the Management Board

review Benchmark Methodologies not less than once 

a year as stated in the Index Management Policy.

For each Equity, Bond and Pension Indices, we 

obtained Benchmark Methodologies and inspected 

for evidence that the internal review of Constituents

Lists procedure is clearly stated, including periodic 

unplanned reviews (in case of specific events). 

We obtained a selection of meeting minutes of Index 

Committee, FX Market Committee, 

REPO Committee and Collective Investment 

Market Committee and inspected for evidence that 

respective Committees conduct periodic reviews of 

Methodologies and Constituent Lists.

We obtained a selection of meeting minutes of the 

Executive and the Management Board and 

inspected for evidence that Benchmark 

Methodologies are approved by them. 

We reviewed a selection of MOEX’s press-releases 

and inspected for evidence that:

 they include statements concerning changes to 

Benchmark Methodologies and the Constituent 

List and effective date of changes coming in 

force;

 they include MOEX’s explanations concerning 

the required changes and rationale for these 

changes take place;
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IOSCO Principle MOEX’s response Work performed by EY

 they are published on MOEX’s web-site 

(http://www.moex.com/en/news/?ncat=206) at 

least two weeks prior to the day when changes 

come into force or not later than one day before 

in case the review was undertaken out of the 

schedule.

We obtained the Index Management Policy and 

ensured that it is stated in the policy that the 

Methodologies are reviewed not less than once a 

year.

We obtained a selection meeting minutes and 

inspected for evidence that:

 The Executive Board of MOEX and the 

Management Board of MICEX SE are 

responsible for review and approval of 

Benchmark Methodologies;

 Meeting minutes contains evidence of the review 

and approval of Benchmark Methodologies by 

the Executive Board of MOEX and the 

Management Board of MICEX SE.
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IOSCO Principle MOEX’s response Work performed by EY

The Administrator should develop Stakeholder

consultation procedures in relation to changes to the 

Methodology that are deemed material by the 

oversight function, and that are appropriate and 

proportionate to the breadth and depth of the 

Benchmark’s use and the nature of the Stakeholders. 

Procedures should:

a) Provide advance notice and a clear timeframe that 

gives Stakeholders sufficient opportunity to 

analyse and comment on the impact of such 

proposed material changes, having regard to the 

Administrator’s assessment of the overall 

circumstances.

b) Provide for Stakeholders’ summary comments, 

and the Administrator’s summary response to 

those comments, to be made accessible to all 

Stakeholders after any given consultation period, 

except where the commenter has requested 

confidentiality.

MOEX developed Stakeholder consultation 

procedures in relation to changes to the 

Methodology. The MOEX’s Committees perform 

review of respective Methodologies. Committees are 

formed from Stakeholders and their representatives 

with relevant expertise and knowledge, who are not 

engaged in employment relations with MOEX. 

Application to Committee’s membership is open and 

clearly defined on MOEX’s web-site.

a) Committee’s members are given an advance 

notice on prospective changes and timeframe for 

discussions and consultation, together with a 

detailed project of changes, so that they have 

sufficient time to make a review, hold meetings 

and prepare their comments.

b) Summaries of MOEX’s Committees’ discussions 

are available on MOEX’s web-site so allowing 

other interested parties to contribute their views.

We obtained:

 the Terms of Reference for Index Committee, 

FX Market Committee, REPO Committee and 

Collective Investment Market Committee;

 a selection of meeting minutes of Index 

Committee, FX Market Committee, 

REPO Committee and Collective Investment 

Market Committee;

and inspected for evidence that:

 Committees perform Stakeholder consultation 

functions and provide a quorum of Stakeholder

representatives;

 Committees include only non-MOEX employees 

with relevant expertise and knowledge;

 Committees are entitled to give their comments 

concerning each Benchmark Methodology;

 meeting minutes of Committees are publicly 

available on MOEX’s web-site.

13. Transition

Administrators should have clear written policies and 

procedures, to address the need for possible 

cessation of a Benchmark, due to market structure 

change, product definition change, or any other 

condition which makes the Benchmark no longer 

representative of its intended Interest. These policies 

and procedures should be proportionate to the 

estimated breadth and depth of contracts and 

financial instruments that reference a Benchmark and 

the economic and financial stability impact that 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 in determining what policies and 

The Index Management Policy describes the 

procedure for the Benchmark decommissioning and 

cessation. It is stated that cessation and 

decommissioning may be necessary due to market 

structure change, product definition change, or any 

other condition which makes the Benchmark no 

longer representative thus making Stakeholders

aware of the possibility of Benchmarks cessation.

The description of the cessation and 

decommissioning procedures is publicly available on 

MOEX’s web-site.

We obtained the Index Management Policy and 

ensured that the procedure for Benchmark 

decommissioning is stated in this policy.

We ensured that the description of the cessation 

and decommissioning procedure is publicly 

available on MOEX’s web-site.
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IOSCO Principle MOEX’s response Work performed by EY

procedures are appropriate for a particular 

Benchmark. 

These written policies and procedures should be 

Published or Made Available to all Stakeholders.

Administrators should encourage Subscribers and 

other Stakeholders who have financial instruments 

that reference a Benchmark to take steps to make 

sure that: 

a) Contracts or other financial instruments that 

reference a Benchmark, have robust fall-back 

provisions in the event of material changes to, or 

cessation of, the referenced Benchmark.

b) 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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Administrators’ written policies and procedures to 

address the possibility of Benchmark cessation could 

include the following factors, if determined to be 

reasonable and appropriate by the Administrator: 

a) Criteria to guide the selection of a credible, 

alternative Benchmark such as, but not limited to, 

criteria that seek to match to the extent practicable 

the existing Benchmark’s characteristics (e.g., 

credit quality, maturities and liquidity of the 

alternative market), differentials between 

Benchmarks, the extent to which an alternative 

Benchmark meets the asset/liability needs of 

Stakeholders, whether the revised Benchmark is 

investable, the availability of transparent 

transaction data, the impact on Stakeholders and 

impact of existing legislation.

b) The practicality of maintaining parallel 

Benchmarks (e.g., where feasible, maintain the 

existing Benchmark for a defined period of time to 

permit existing contracts and financial instruments 

to mature and publish a new Benchmark) in order 

to accommodate an orderly transition to a new 

Benchmark.

c) 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 tenor of a 

Benchmark that will be discontinued completely, 

the policy defining the period of time in which the 

Benchmark will continue to be produced in order 

to permit existing contracts to migrate to an 

alternative Benchmark if necessary.

e) The process by which the Administrator will 

engage Stakeholders and relevant Market and 

National Authorities, as appropriate, in the process 

for selecting and moving towards an alternative 

The cessation and decommissioning policies and 

procedures described in the Index Management 

Policy include the following:

 the description of the roles and responsibilities;

 the procedure of consulting with Stakeholders;

 the decommissioning period.

MOEX’s Benchmarks are based on the market data 

obtained from its trading venues. Since MOEX does 

not use the Submitters’ data it is not possible to find 

the appropriate alternative for the existing 

Benchmarks. MOEX’s Benchmarks are ceased in 

cases when they are no longer representative for the 

users and new Benchmarks are developed in the 

normal course of business and not as a substitute for 

the ceased Benchmarks. As a result in case of the 

cessation of Benchmarks the selection of alternative 

Benchmarks or running parallel Benchmarks is not 

applicable to MOEX.

We obtained the Index Management Policy and 

ensured that the procedure for benchmark 

decommissioning is stated in this policy as 

described in MOEX’s response.

We obtained a selection of press releases from 

MOEX’s web-site and identified that since May 20, 

2013 capitalization indices MICEX LC and MICEX 

MC have been ceased. The reason for the cessation 

was the merge of CJSC MICEX and OJSC RTS and 

harmonization of the new MOEX’s Indices product 

line so there was no need in them.
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IOSCO Principle MOEX’s response Work performed by EY

Benchmark, including the timeframe for any such 

action commensurate with the tenors of the 

financial instruments referencing the Benchmarks 

and the adequacy of notice that will be provided to 

Stakeholders. 
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IOSCO Principle MOEX’s response Work performed by EY

14. Submitter Code of Conduct

Where a Benchmark is based on Submissions, the 

following additional Principle also applies: 

The Administrator should develop guidelines for 

Submitters (“Submitter Code of Conduct”), which 

should be available to any relevant Regulatory 

Authorities, if any and Published or Made 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 

Submitters to confirm adherence to the Submitter 

Code of Conduct annually and whenever 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.

Benchmarks are not based on Submissions so this 

Principle is not applicable to MOEX.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that Benchmarks determination is not 

based on Submissions.
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The Submitter Code of Conduct should address: 

a) The selection of inputs.

b) Who may submit data and information 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 the 

authorization of such person(s) to report market 

data on behalf of a Submitter.

d) 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.

g)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.

ii. Procedures to detect and evaluate suspicious 

inputs or transactions, including inter-group 

transactions, and to ensure the Bona Fide nature 

of such inputs, where appropriate.

iii. Policies guiding and detailing the use of 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.
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vi. Training, including training with respect 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 by management for 

submitting inputs.

x. Whistle blowing policies (in line with Principle 4).

xi. Conflicts of interest procedures and policies, 

including prohibitions on the Submission of data 

from Front Office Functions unless the 

Administrator is satisfied that there are adequate 

internal oversight and verification procedures for 

Front Office Function Submissions of data to an 

Administrator (including safeguards and 

supervision to address possible conflicts of 

interests as per paragraphs (v) and (ix) above), 

the physical separation of employees and 

reporting lines where appropriate, the 

consideration of how to identify, disclose, manage, 

mitigate and avoid existing or potential incentives 

to manipulate or otherwise influence data inputs 

(whether or not in order to influence the 

Benchmark levels), including, without limitation, 

through appropriate remuneration policies and by 

effectively addressing conflicts of interest which 

may exist between the Submitter’s Submission 

activities (including all staff who perform or 

otherwise participate in Benchmark Submission 

responsibilities), and any other business of the 

Submitter or of any of its affiliates or any of their 

respective clients or customers. 
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IOSCO Principle MOEX’s response Work performed by EY

15. Internal controls over data collection

When an Administrator collects data from any 

external source the Administrator should ensure that 

there are appropriate internal controls over its data 

collection and transmission processes. These 

controls should address the process for selecting the 

source, collecting the data and protecting the integrity 

and confidentiality of the data. Where Administrators 

receive data from employees of the Front Office 

Function, the Administrator should seek corroborating 

data from other sources.

No data from external sources is used in the 

Benchmarks determination. The only exception is 

the Pension indices. 

Constituent List used for the Pension Indices 

calculation is based on net assets of pension funds 

which are under control of private asset 

management companies and non-state pension 

funds. Data on net assets is provided by SRO “NLU” 

(self-regulated organization ‘National league of asset 

management companies’). This data is sourced by 

SRO “NLU” from the Pension Fund of the Russian 

Federation (PF of RF), which is a regulated body of 

the Russian Federation. This data is verified by 

MOEX using the data from the Pension Fund of the 

Russian Federation.

For each MOEX’s index, we obtained Benchmark 

Methodologies and inspected for evidence that no 

data from external sources is used for the

calculation of MOEX’s indices.

We obtained Methodology of the Pension Indices 

Calculation and inspected for evidence that:

 the data used for the determination of the 

Constituent List is obtained from SRO ‘NLU’

(http://www.nlu.ru/renking-retirescha.htm?group_by_portfolio=on) and it 

corresponds with data from the Pension Fund of 

the Russian Federation

(http://2014.pfrf.ru/uk_results_info/2205.html) as 

at 30/09/2014;

 the data provided by SRO ‘NLU’ is not used in 

calculation of the Indices.

16. Complaints process

The Administrator should establish and Publish or 

Make Available a written complaints procedures 

policy, by which Stakeholders may submit complaints 

including concerning whether a specific Benchmark 

determination is representative 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. 

MOEX has a documented complaints procedure in 

the Index Management Policy and its summary is 

publicly available.

We obtained the Index Management Policy and 

ensured that complaints procedure is documented

in this policy.

We ensured that the description of complaints 

procedure is publicly available on MOEX’s web-site.
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IOSCO Principle MOEX’s response Work performed by EY

The complaints procedures policy should: 

a) Permit complaints to be submitted through a userfriendly complaints process such as an electronic 

Submission process.

b) Contain procedures for receiving and investigating 

a complaint made about the Administrator’s 

Benchmark determination process on a timely and 

fair basis by personnel who are independent of 

any personnel who may be or may have been 

involved in the subject of the complaint, advising 

the complainant and other relevant parties of the 

outcome of its investigation within a reasonable 

period and retaining all records concerning 

complaints.

c) Contain a process for escalating complaints, as 

appropriate, to the Administrator’s governance 

body.

d) Require all documents relating to a complaint, 

including those submitted by the complainant as 

well as the Administrator’s own record, to be 

retained for a minimum of five years, subject to 

applicable national legal or regulatory 

requirements. 

Complaints, queries or questions can be sent directly 

to MOEX by e-mail, telephone or using a special 

Client Request Form (user-friendly format) on 

MOEX’s web-site. The Form contents are forwarded 

to index@moex.com and delivered to the Index 

Management Division. All complaints and queries 

are reviewed by MOEX staff within a reasonable 

period of time. MOEX Index Management Division 

provides two level of client support; the 1st level 

support provides general comments and answers on 

incoming requests, while the 2nd level support 

provides detailed comments and references adapted 

to each incoming request. In relation to the storage 

of complaints history, please see Principle 18.

We obtained the Index Management Policy and 

ensured that the complaints process is described as 

stated in MOEX’s response. 

We obtained a selection of complaints and ensured 

that they were responded timely and properly.

We visited MOEX’s web-site and ensured that 

request form exists:

http://moex.com/ru/feedback.aspx
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IOSCO Principle MOEX’s response Work performed by EY

Disputes about a Benchmarking determination, which 

are not formal complaints, should be resolved by the 

Administrator by reference to its standard appropriate

procedures. If a complaint results in a change in a 

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.

All changes to Methodologies and revisions of 

Benchmarks are published via official press-releases

with the reason and explanation for these changes.

We reviewed a selection of MOEX’s press-releases 

and inspected for evidence that:

 they include statements concerning changes to 

Benchmark Methodologies;

 they include MOEX’s explanations concerning 

these changes;

 they are publicly available on MOEX’s web-site

(http://www.moex.com/en/news/?ncat=206)

17. Audits

The Administrator should appoint an independent 

internal or external auditor with appropriate 

experience and capability to periodically review and 

report on the Administrator’s adherence to its stated 

criteria and with the Principles. The frequency of 

audits should be proportionate to the size and 

complexity of the Administrator’s operations. 

Currently Internal Audit department of MOEX does 

not perform any procedures to review and report on 

the compliance with the IOSCO principles. MOEX 

appointed an independent external auditor to report 

on the fair presentation of the Statement of 

Compliance and the suitability of design of the 

control procedures aimed at adherence with the 

IOSCO Principles. The Index Management Policy 

states that audit should be performed annually either 

by internal or external auditors

We obtained the Index Management Policy and 

ensured that the frequency of audits is stated as 

described in MOEX’s response.

Where appropriate to the level of existing 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 and capability to periodically 

review and report on the Administrator’s adherence to 

its stated Methodology. The frequency of audits 

should be proportionate to the size and complexity of 

the Administrator’s Benchmark operations and the 

breadth and depth of Benchmark use by 

Stakeholders.

MOEX appointed EY as an external auditor to report 

on the compliance with the IOSCO Principles due to 

the fact that internal audit currently do not perform 

any procedures in relation to the compliance with the 

IOSCO Principles. In accordance with the Index 

Management Policy the audit (either external or 

internal) should be performed annually.

We obtained the Index Management Policy and 

ensured that the frequency of audits is stated as 

described in MOEX’s response.

18. Audit trail

Written records should be retained by the In accordance with the Index Management Policy of We received the Index Management Policy and 
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Administrator for five years, subject to applicable 

national legal or regulatory requirements on: 

a) All market data, Submissions and any other 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 from standard 

procedures and Methodologies, including those 

made during periods of market stress or 

disruption.

d) The identity of each person involved in producing 

a Benchmark determination.

e) Any queries and responses relating to data inputs. 

If these records are held by a Regulated Market or 

Exchange the Administrator may rely on these 

records for compliance with this Principle, subject to 

appropriate written record sharing agreements.

MOEX the records related to Benchmarks 

calculation are stored for the period not less than five 

years. These records include market data used for 

calculations, Constituents Lists, free-float 

calculations, coefficients calculations, methodology 

changes, complaints from users.

Roles and responsibilities in the benchmarking 

process are defined in the Index Management Policy 

and the identity of persons involved in the 

benchmarking process can be verified. Taking into 

account that the process of Benchmarks’

determination and dissemination is highly automated 

the identity of persons involved can be traced from 

the systems.

ensured that it is stated in the policy that the records 

related to Benchmark determination are stored for 

not less than 5 years. 

We also ensured that the roles and responsibilities 

are clearly stated in this policy.

We ensured that the history of benchmarks values 

and market data, methodologies and changes in 

methodologies, Constituents Lists and changes to 

them, minutes of meetings of Stakeholders 

Committees and roles and responsibilities of these 

Committees are available on the official web-site of 

MOEX.

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 and Methodologies governing the 

Submission 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 and Submission oversight.

Benchmarks are not based on Submissions so this 

Principle is not applicable to MOEX.

We obtained the Index Management Policy 

describing the roles and responsibilities of all the 

functions involved in the benchmarking process and 

ensured that Benchmark determination is not based 

on Submissions.
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d) Relevant communications between submitting 

parties.

e) Any interaction with the Administrator.

f) Any queries received regarding data or 

information provided to the Administrator.

g) Declaration of any conflicts of interests and 

aggregate exposures to Benchmark related 

instruments.

h) Exposures of individual traders/desks to 

Benchmark related instruments in order to 

facilitate audits and investigations.

i) Findings of external/internal audits, when 

available, related to Benchmark Submission 

remedial actions and progress in implementing

them.

19. Co-operation with Regulatory Authorities

Relevant documents, Audit Trails and other 

documents subject to these Principles shall be made 

readily available by the relevant parties to the 

relevant Regulatory Authorities in carrying out their 

regulatory or supervisory duties and handed over 

promptly upon request.

MOEX is a Regulated Market of the Russian 

Federation and is subject to regulation by the Central 

Bank of Russia. Currently there is no requirement 

from regulatory authorities to adhere to the IOSCO 

principles. 

MOEX maintains the Register of documents related 

to compliance with the IOSCO principles in order to 

make them readily available in case of any requests.

We obtained the Register of documents related to 

compliance with the IOSCO Principles and ensured 

that the documents described in above in this 

Section are included in this Register.

We ensured that the history of benchmarks values 

and market data, methodologies and changes in 

methodologies, Constituents Lists and changes to 

them, minutes of meetings of Stakeholders 

Committees and roles and responsibilities of these 

Committees are available on the official web-site of 

MOEX.