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Societe Generale has been registered as benchmark administrator with the AMF under the European Benchmark Regulation (BMR) on 12 April 2019.
The Benchmark statements of all SGI indices (excluding Factor Indices) falling in the scope of the European Benchmark Regulation (the “benchmarks”) are published on the dedicated webpage of such benchmark.
The Benchmark statement of the benchmark family of Factor Indices that are underlying of Factor Certificates is below. For more information regarding such Factor Certificates, please go to https://www.warrants.com/. The Factor Indices description can be found in the Final Terms of each related Factor Certificate.
The activity of administering proprietary indices of Societe Generale SA, under the brand “SGI”, is integrated in the financial markets department of Societe Generale, “MARK”. The “SGI” proprietary indices are created primarily to be the underlying reference of products traded by MARK, which requires a regular interaction between the “SGI” index team and the other engineering teams within MARK.
Furthermore, the “SGI” index team shall interact with the sales teams and the trading teams of the dealing room, particularly in the context of when new products are launched with an “SGI” index as an underlying reference.
The integration of the “SGI” teams within MARK leads to a risk of conflicts of interest.
Those risks are notably but without limitation:
Furthermore, the trading teams of the dealing room which hedge the risks generated by the issuance of financial products by MARK, by taking positions on underlying financial instruments to replicate the indices composition, could be likely to have an interest in influencing the values of the indices components in the financial markets in an inappropriate manner.
In order to prevent these various risks, Societe Generale has implemented an oversight function, procedures and controls governing the administration of “SGI” indices, compliant with the European Regulation 2016/2011 of 8 June 2016 concerning the indices used as benchmarks.
The following measures are implemented to address these conflicts of interest risks:
A dedicated department within the Societe Generale Compliance department carries out controls on the transactions conducted by the MARK trading teams, in accordance with Societe Generale’s regulatory obligations in order to detect risks of market abuse that could be generated by these operations.
Stakeholders may register complaints in respect of any SGI Index with the Index Sponsor mark-clientclaims.world@sgcib.com
Complaints may relate to, among other things: (a) whether determinations made in respect of an SGI Index and the Index Components are representative of market value; (b) modifications to the Index Rules and SGI Global Methodology; (c) the manner of application of the Index Rules and/or SGI Global Methodology in respect of a particular determination under an SGI Index; and (d) any other decisions or matters in relation to the maintenance and calculation of an SGI Index.
In respect of each complaint received by the Index Sponsor, the complaints procedure shall be managed by Société Générale personnel independent of those who may have been involved in the subject matter of such complaint.