Nasdaq Global Indexes, a division of Nasdaq, Inc. (“Nasdaq”) strives to provide information of the highest standards to its customers and to conduct its business with integrity and transparency. To facilitate achievement of these standards, Nasdaq maintains responsibility for all aspects of the Benchmark determination process, including submissions to benchmarks, methodology construction and maintenance, as well as compliance with its Benchmark governance, quality, and operational standards.

Governance Framework

To protect the integrity of its Benchmarks and address potential conflicts of interest, Nasdaq employs a robust governance and control framework comprised of several functions responsible for the overall operational management, governance, and oversight of the Benchmark determination process.

Nasdaq’s control framework establishes accountability and transparency mechanisms over significant decisions affecting the construction, issuance, and operation of its Benchmarks. Nasdaq ensures proper execution of its control framework through the support of its governing bodies, the US Oversight Committee and the Index Management Committee. These index committees serve as an oversight function for quality review and monitoring of the Benchmark, maintenance and enforcement of Benchmark policies and procedures, as well as the effective management and mitigation of potential conflicts of interest. The index committees also oversee issue resolution and regulatory monitoring.


Nasdaq has comprehensive governing documents which outline the above frameworks as well as internal processes and procedures. Related information can be found here and detailed information regarding our Ethics and Complaints practices are included in the below links:

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