Owner: Chief Risk and Compliance Officer, S&P DJI

S&P Dow Jones Indices, a division of S&P Global, strives to provide information of the highest standards and to conduct its business with integrity.  To facilitate achieving those standards, S&P Dow Jones Indices and its subsidiaries that provide index-related products and services, including  IHS Markit Benchmark Administration Limited and S&P DJI Netherlands B.V. (S&P DJI) have issued this Benchmark Complaints policy which sets out the procedures for submission and handling of benchmark complaints and retaining relevant records.&nbs;

Please note that confidential and anonymous concerns may also be reported by S&P Global employees or external stakeholders can be submitted on-line or by calling the toll-free number provided through the EthicsPoint Helpline.

A benchmark complaint may relate to any aspect of the products and services provided by S&P DJI, including benchmark determinations, such as

• the application of a methodology to a specific benchmark determination,
• whether the benchmark determination is representative of the underlying interest it seeks to measure or
• a proposed change to the methodology of a benchmark.

S&P DJI will investigate benchmark complaints in a fair and timely manner and the inquiry will be conducted by parties independent of those involved in the subject matter of the complaint.

In the ordinary course of business, benchmark stakeholders may from time-to-time contact S&P DJI to seek clarification about a benchmark determination including its underlying constituents; obtain a better understanding of a particular benchmark methodology or question a particular benchmark determination process. We recommend that any stakeholder who is not satisfied with a benchmark determination matter, firstly raise their concern with their existing contacts within S&P DJI’s Client Coverage or Product Management Groups or contact S&P DJI’s Client Services Group^[1], before they decide they wish to file a formal complaint.

A stakeholder who wishes to enter the formal benchmark complaints process must record the complaint in writing,using the online form for ‘Benchmark Complaints’, and provide

• Full name
• company name (if applicable)
• description of the benchmark complaint including the name of the index, the date of the issue; and
• a detailed description of the issue and its impact.

The online form can be found on the ‘General Inquiries’ page of S&P DJI’s website .  Under the ‘Request type’ drop-down menu, please select the ‘Benchmark Complaint’ option.

^[1]Contact details for the Client Services Group, email, and telephone numbers, can be found on the S&P DJI website at https://www.spglobal.com/spdji/en/contact-us/.

S&P DJI will seek to acknowledge receipt of a benchmark complaint within three (3) business days and, if necessary, confer with the complainant to ensure all information is available and the nature of the matter is fully understood. 

S&P DJI will assign the issue to the department best placed to address it and will seek to resolve in a timely manner.

S&P DJI will provide updates on the status and likely timescales for resolution. The period to resolve a benchmark complaint will vary according to the nature of the issue and its complexity. The complainant will be advised (via email) of the resolution of the issue as soon as reasonably practical.

Where the complainant is not satisfied with the resolution, S&P DJI will escalate the issue to relevant Senior Management and the relevant management body as appropriate.

If, as a result of a benchmark complaint, a material change to an index is determined to be warranted, such as a recalculation of index values or reissue of data, a client notice will be issued to all affected users before the complainant is notified.

S&P DJI will retain all information relating to a benchmark complaint, for a minimum period of five (5) years.

This Policy is reviewed on an annual basis to assess whether it remains fit for purpose. Any questions or concerns with this Policy should be raised to the Compliance Team, at spdji_compliance@spglobal.com.