IBA has developed and implemented a control framework for the design, calculation, maintenance and distribution of the benchmarks it administers. The control framework is formally documented and the IBA Board is responsible for regularly reviewing the control framework and its effectiveness.
The control framework is an overarching document that along with methodologies, policies and procedures, oversight and accountability mechanisms, and business processes covers the requirements of the IOSCO Principles. A summary of the main features are set out below:
The control framework describes processes and control activities relating to:
a. how conflicts of interest are managed and resolved in the business (with reference to IOSCO Principle 3).
b. (i), (ii), (iii), (iv) the integrity and quality of the design, calculation, maintenance and distribution of benchmarks (referring to IOSCO Principles 6 to 19); the automated calculation and distribution of the benchmark; and IT General Controls (“ITGCs”) supporting benchmark calculation, maintenance and distribution processes, including system-enforced password authorisation from two operators.
The ITGCs also include: User access management; systems change control; and Backup procedures.
IBA has a formally documented risk framework, approved by IBA's Board.
c. There is a formal whistle-blower policy in place. An annual Whistleblowing report is made to the IBA Board.
d. All employees are subject to external screening prior to appointment and then required to complete a probationary period of employment which includes training on benchmark production. All employees are subject to annual performance appraisals.
