Regulatory

The governance of the BBVA Indices is responsibility of the BBVA Index Administration and Management team (“BIAM”) that perform its duties and responsibilities according to a control framework which is designed to ensure that the provisions of BBVA Indices comply with the EU Benchmarks Regulation (“BMR”).

The compliance with that control framework is overseen by the BBVA Index Oversight Group (“BIOG”), whose members are independent of the front office functions of BBVA Global Markets.

BBVA is regulated by the Spanish National Securities Market Commission (Comisión Nacional del Mercado de Valores – CNMV) as a benchmark administrator for the purposes of the BMR. BBVA currently only provides non-significant benchmarks, as defined in the BMR.

Conflict of interest management

The administration of BBVA Indices is integrated in the BBVA Global Markets unit (“BBVA GM”). The BBVA Indices are created with the main purpose of being the reference for the financial products distributed by BBVA GM.

Conflicts of interest may arise where BBVA is, in relation to the indexes used as benchmarks it administers, being a non exhaustive list and among others:
– Being incentivised to determine the level of the indices in a biased manner in order to favour BBVA interests;
– Not correcting any calculation errors on the level of the indices, if these would be beneficial to BBVA;
– Being incentivised to change the compositions of indices in a way to favour BBVA’ interests;
– Being incentivised to change the index rules afterwards in a way to favour BBVA’ interests;
– Usage of unreliable data, in case that data would be provided by other BBVA’s areas or units to determine the level of certain indices

BBVA has identified activities that may give rise to potential conflicts of interest in relation to indices it administers as the day to day trading by the desks involved in the transactions referenced to the BBVA administered Indices or of components of the Indices or highly correlated instruments.
In order to avoid these risks, BBVA has established an oversight function and a set of policies, procedures and controls for the management of the indices.

BBVA has established mitigating measures to prevent, and where appropriate, manage the potential conflicts of interest that may arise.
Organizational, logical and physical separation of the teams involved in the administration and calculation of the indices from the activities that could give rise to the conflict.
Changes in the Index composition are rule based, determined according to the formulas and processes provided by the Index rulebook.
Proposed changes to the rulebooks are subject to the Discretion and Material Changes Policy.

Complaints

Any stakeholder may file a complaint regarding the Indices administered by BBVA by sending an e-mail to indices.request@BBVA.com.