Governance

S&P DJI has an extensive history of delivering robust and transparent benchmarks to the financial industry and always endeavors to deliver high quality indices in conformity with our core values and in compliance with all applicable laws and regulations as well as industry standards and guidelines. S&P Global's Code of Business Ethics coupled with S&P DJI policies and procedures set the standard for an effective governance program.

Governance Framework

S&P DJI's governance and control framework is designed to protect the integrity and quality of our benchmarks, and comply with applicable regulatory standards and accepted industry practices.

This framework includes independence in the development, maintenance, and distribution of benchmarks, as well as clear separation of distinct functions and duties across the organization.

This ensures effective conflicts of interest mitigation and management, an oversight function that effectively monitors, maintains and enforces S&P DJI policies and procedures, and a robust quality review program.

We ensure proper execution of this framework through our independent Index Committee governance function, ongoing oversight from Legal, Compliance and Risk functions, and a third-line assurance program.

Our rigorous and comprehensive policies and procedures reflect our longstanding commitment to avoid conflicts of interest, govern our indices transparently, and adopt best practices.

Internal Oversight & Industry Alignment

  • Index Industry Association

    S&P DJI is a founding member of the Index Industry Association (IIA), and as such, aligns its activities, policies and structure with the IIA’s Best Practices.
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  • Internal Oversight

    The S&P DJI Internal Oversight Committee comprises representatives from the Compliance, Legal, and Risk oversight functions. The Committee’s mission is to oversee S&P DJI’s compliance with its Benchmark governance, quality, and operational standards. Among other responsibilities, the Committee reviews S&P DJI’s adherence with its policies, monitors applicable regulatory developments, and serves as an escalation body for the Index Governance function.

Policies

Benchmark Complaints Policy

S&P Dow Jones Indices 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 have issued the Benchmark Complaints Policy which sets out the procedures for submission and handling of benchmark complaints and retaining relevant records.

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.

Third Party Governance

As data integrity is critical to our index production processes, S&P DJI holds all vendors providing data services to high quality and control standards. The Data Submitter Code of Conduct outlines expectations for vendors providing non-regulated input data to value or price the underlying constituents of an index in the calculation process.

Index Governance

Index Committee and Governance Function

S&P DJI’s Index Committees serve as the index governance body and oversee the design, maintenance, and publication of S&P DJI’s indices. Index Committees seek to ensure indices are maintained in accordance with their respective methodology by reviewing all methodologies to ensure they continue to achieve their stated objectives, and overseeing any changes to an index and/or methodology. All Index Committee members must meet specified core competency, tenure, and experience requirements.

Stakeholder Engagement

To ensure full transparency around our indices and their possible evolution, S&P DJI invites stakeholders to provide feedback on potential material changes to an index methodology through a consultation request process. We post notification of consultation requests and results on our website.

Cessation Policy

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Contacts

Legal Department

Compliance Department

Client Services

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