Benchmark Complaints Handling

During the normal course of business, GX would expect to have ongoing dialogue with market participants and other users of our benchmarks. This dialogue may concern discussions around methodology, the application of methodology, why input data has been included or excluded on a specific day or other such matters. Such dialogue would, in the first instance, not be registered as a formal complaint and instead, GX will seek to answer any such questions to the satisfaction of the individual or company making the enquiry.

Should a subscriber remain dissatisfied with the outcome of such an enquiry, as it pertains to the calculation of a benchmark, they are entitled to submit a formal complaint.

Subscribers to any GX benchmarks may submit complaints on whether a specific calculation is representative of market value, proposed calculation changes, applications of methodology in relation to a specific calculation and other decisions in relation to the calculation processes. In order for a formal complaint to be recognised, it must be made in writing to the Head of Compliance, General Index Ltd. 30 Orange St, London WC2H 7HF, or electronically to .

GX will acknowledge receipt of a complaint within 24 hours of it being received, and will provide an initial response within 7 days. That initial response may include a request for further information to support the complaint being made, after which the complaint is reviewed in detail by the General Index Compliance Committee. General Index is committed to investigating all such complaints in a fair and timely manner, independently of any individual who may be subject to the complaint. No individual who is the subject of a complaint is involved in any stage of the complaints process. The Head of Compliance will then determine the validity of the complaint and determine whether or not the complaint be escalated to the Independent Complaints Assessor (ICA) – a role that sits outside the management structures of General Index, and that reports directly to the board.

Where such escalation is determined not to be required, the Head of Compliance will formally notify the complainant of the outcome of the investigation. General Index will seek to review and respond to any complainants within 28 days, advising the complainant on either the outcome, or the decision to escalate the complaint to the ICA.

If a complainant considers that GX has not adhered to its complaints handling policy, they are entitled, within six months of the original complaint determination, to request a review of whether the complaints process was adhered to – such request being made to the Head of Compliance. The Head of Compliance will then refer the matter to the ICA for review, the outcome of which will be communicated to the complainant at the conclusion. In such circumstances, the complainant will bear the costs of the review if the review concludes that the complaints process was followed correctly.

All complaints records are kept for a minimum of seven years.

If a formal or informal complaint results in a change in price, the details of that change in price is communicated to the market as soon as possible in line with the Corrections policy.