Jun 29, 2025

Statement of Compliance with IOSCO Principles for Financial Benchmarks

Introduction

This Statement of Compliance outlines Arch Indices' adherence to the "Principles for Financial Benchmarks" (the "IOSCO Principles") as published by the International Organization of Securities Commissions (IOSCO) on July 17, 2013. The IOSCO Principles provide an overarching framework of recommended practices for financial benchmarks. As an administrator of financial indices, Arch Indices affirms the importance of accuracy and integrity in these benchmarks.

Scope

Arch Indices acts as an "Administrator" of financial indices that fall within the scope of the IOSCO Principles (each, an "Index," and together, the "Indices"). These Indices are typically developed for specific users, including private bespoke or custom indexes that are generally not made available publicly, and may also include a limited number of indices made available to the public or licensed to third parties on a restricted basis. This Statement of Compliance covers all Indices administered by Arch Indices.

Proportionality and Extent of Compliance

Arch Indices has implemented the IOSCO Principles in a manner that is proportionate to the size of, and the risks posed by, each Index and the Index-setting process. In assessing compliance, Arch Indices considers factors including the proposed use of the Indices, index components, the actual or expected number of users, the actual or expected volume of products linked to the Indices, the level of discretion retained, and potential conflicts of interest. The standards applied to each Index may differ based on this assessment.

Control Framework and Governance

Arch Indices has established and maintains policies and procedures governing the creation and administration of its Indices. These include a specific control framework designed to ensure the accuracy and integrity of the Indices, as well as arrangements to identify and mitigate potential conflicts of interest.

An Index Committee provides governance and internal oversight over all aspects of Index administration activities, ensures accountability of those involved in the Index administration process, and reviews complaints data and results of internal audits. Arch Indices has established robust processes and procedures for development, calculation, publication, maintenance, and licensing of indices, including data sources, use of pricing data, calculation methodology, index determination, validation, and use of expert judgement when relevant.

Further details concerning Arch Indices' control and oversight framework for the determination and distribution of Indices, as well as procedures for material changes in methodologies and/or cessation, are available upon request.

Disclaimer

This document constitutes the applicable statement of compliance pursuant to the IOSCO Principles and is provided by Arch Indices for the sole purpose of describing the extent of its compliance with such IOSCO Principles. Arch Indices has provided this document publicly voluntarily. It should not be relied upon for any other purpose and does not constitute legal, financial, or investment advice. No third party shall have any right to enforce anything set out in this document, either directly or indirectly.