Conflicts of Interest Policy
This Policy helps ensure the independence, impartiality and objectivity that is critical to maintaining the trust that the market has in price assessments from Fastmarkets RISI Indices.
Fastmarkets RISI independence
Fastmarkets RISI is an independent company free of ownership or other ties that would give it a financial interest in the movement of prices we report.
To avoid a perceived conflict of interest between price assessment and price forecasting, Fastmarkets RISI’s price reporting staff and products are in the Fastmarkets RISI Indices division, which is separate from the division that contains forecasting (Fastmarkets RISI Analytics). The head of Fastmarkets RISI Indices reports directly to Fastmarkets RISI’s CEO.
Staff of Fastmarkets RISI Indices must report any improper internal requests to influence price assessments to the head of Fastmarkets RISI Indices. An “improper internal request to influence price assessments” is any request or attempt to influence price assessments by anyone within Fastmarkets RISI that would run counter to the spirit of our methodology and the objective of proving accurate price assessments.
Employees who conduct price assessments are prohibited from having a financial interest in the prices on which they report. This means they may not have a financial interest in companies whose values are directly and substantially affected by prices on which they report, except if such interest is held in a passive investment like a mutual fund. Employees also may not participate directly in the markets they cover.
Communication with Financial Stakeholders
Fastmarkets RISI Indices employees must refrain from sharing significant news or price information with any party before publishing it for all customers. To avoid the risk of giving an advance indication of what price we will publish, all contacts with investors, equity analysts, derivatives dealers, and any other financial stakeholders must be avoided completely for the week prior to publication of prices.
Outside Interests and Employment
Fastmarkets RISI Indices employees must not engage in outside activities that:
- Conflict, or appear to conflict, with their duties at Fastmarkets RISI, or interests of Fastmarkets RISI’s customers, contractors, suppliers, vendors, or anyone else doing business with Fastmarkets RISI.
- Compromise, or create the potential to compromise, their objectivity or judgment.
- Adversely affect the quality of Fastmarkets RISI work performed.
Fastmarkets RISI Indices employees are required to avoid using Fastmarkets RISI contacts to advance their private business or personal interests.
Entertainment, Gifts, and Favors
Employees may not accept anything that is or reasonably could be interpreted as improperly influencing or rewarding a business decision, nor can the impression be created that offering gifts is required in order to do business with Fastmarkets RISI.
Fastmarkets RISI price reporting staff must declare any business amenity, regardless of the value, to an appropriate line manager. Fastmarkets RISI staff members may only accept gifts of modest value (up to £50) and are not allowed to offer gifts without the express prior approval of the member of senior management. Business-related meals and/or entertainment are also subject to approval above a certain amount and must always be declared. Price reporting staff are not permitted to offer or receive cash at any time.
As a general guideline, employees should consult with their managers or Human Resources when evaluating whether specific situations could be defined as a conflict of interest.