This code of conduct details the expectations for contributors to EDHECinfra’s indices.
The code of conduct should be read in conjunction with Article 15 of the EU Benchmarks Regulation (BMR) for contributed benchmarks.
The BMR requires benchmarks derived from contributed information to develop a code of conduct that specifies the contributor’s responsibilities with respect to the input data.
The code details the governance, data submission, record keeping, and data revision / error checking requirements that a contributor must follow to be included in EDHECinfra’s indices.
Data Submission and Record Keeping
The required data is described in EDHECinfra’s data standard. This details the information that is required to be provided by the contributor, the format it must take, and the periodicity of the contribution.
The contribution must be provided to a representative of EDHECinfra through the secure data portal in the format that EDHECinfra has agreed prior to the submission.
The contributor will conduct the necessary reviews and validate the submission internally before providing the submission to EDHECinfra. Furthermore, in providing the submission it acknowledges that the information provided is complete, accurate, and consistent with the EDHECinfra’s specifications in the data standard.
The data contributor is expected to maintain records.
Following the submission the contributor is required to maintain records relating to the submission for a period of five years, subject to applicable record-keeping requirements.
If EDHECinfra requests, the contributor will provide the documents used to provide a submission. These can include but are not limited to annual reports, financial models, valuation reports, and transaction contracts.
The contributor is required to delegate the task of preparing the submission to an employee with sufficient experience and authority to prepare and submit the data on behalf of the contributor and receive reports on data quality subsequent to submission.
The contributor is expected to develop policies and procedures that ensure that the organisation complies with this code of conduct and ensures that any submission has appropriate approvals to ensure data integrity.
All parties that provide input to the submission must be identified with each submission.
Data Revision or Suspicious Submissions
Submitters are expected to conduct internal reviews before making a submission to EDHECinfra. These reviews are expected to identify any errors or anomalous reports and would lead to them being rejected.
All submissions are expected to provide supporting evidence if EDHECinfra requests when reviewing the integrity of the data.
Submitters are expected to have in place a robust compliance regime that allows for the reporting of any suspicious behaviour or submissions.
Any suspicious behaviour or submission must be reported to EDHECinfra in a timely manner upon discovery.
Conflicts of Interest
As part of a robust compliance regime, the contributor is expected to maintain effective controls to identify and manage any apparent or perceived conflicts of interest in the data-submission process. These controls must include a policy that allows for employees of the contributor to raise concerns about apparent or perceived conflicts of interest without fear of retribution.