Important information
Published: November 2021
Reviewed: June 2026
1. Introduction
The Principles for Financial Benchmarks (“Principles”) were issued by the International Organization of Securities Commissions (“IOSCO”) on 17 July 2019. The purpose of the Principles is to set a framework for use of financial benchmarks in financial markets by addressing, inter alia, transparency of the benchmark submission process, content and transparency of methodology, governance and accountability.
IOSCO has recommended that administrators of benchmarks publicly disclose the extent of their compliance with the IOSCO Principles on an annual basis. This Compliance Statement is made by the Commodities and Global Markets Group of Macquarie Bank Limited (London Branch) (“Macquarie”) in adherence to this recommendation.
Unless otherwise indicated, capitalised terms used in this Compliance Statement are within the meaning of the Principles.
2. Scope of Compliance Statement
This Compliance Statement is made in respect of Macquarie’s role as Administrator of a number of proprietary strategies that fall within the meaning of Benchmarks (together, the “Macquarie Strategies” and, on an individual basis, a “Macquarie Strategy”).
Macquarie develops, calculates, publishes and offers financial products referencing Macquarie Strategies. The Macquarie Strategies are rules-based investment strategies that may include constituents from various asset classes (including commodities, foreign exchange, rates and equities). Macquarie Strategies may be bespoke and restricted for use by a single investor or public and made available to range of investors.
The Macquarie Strategies exclude, and this Compliance Statement therefore does not apply to, illustrative strategies which are not linked to financial products and which are not used as a performance measure for any financial product.
3. Macquarie QIS Policy
Macquarie designs and creates a range of quantitative investment strategies, for use in its activities including the issuance of financial products linked to such Benchmarks.
Macquarie has established a governance and oversight framework in respect of the Macquarie Strategies which is set out in its Quantitative Investment Strategies (“QIS”) Policy, QIS Control Framework and QIS Oversight Committee Charter (together, the “Policy”). The Policy is intended to address, inter alia, the Administrator requirements set out within the Principles.
Macquarie has established a QIS Oversight Committee (the “Committee”) to oversee and support the implementation of the Policy. The Committee’s responsibilities include:
4. Compliance Statement
Subject to the above and as of the date of this Compliance Statement, Macquarie hereby confirms its observance of, and adherence to, the Principles in a manner which is proportionate to the size, risk profile, composition and purpose of each Macquarie Strategy.
Macquarie is committed to operating its QIS business in accordance with the Principles and considers that it complies with the Principles in all material respects, proportionate to the size and risks posed by each Macquarie Strategy and the QIS setting process (as permitted by IOSCO).
Macquarie has established policies and procedures that seek to apply appropriate governance procedures to the creation, maintenance and provision of the Macquarie Strategies. In addition, Macquarie and its employees are subject to policies and procedures designed to identify, manage and address any conflicts of interest. These policies and procedures seek to maintain the integrity of the process by which Macquarie creates and maintains the Macquarie Strategies.
5. Further Information
If you require further information regarding the Macquarie Strategies, please contact Macquarie at cip@macquarie.com.
