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Benchmark Policy

Benchmark Policy

This is a benchmark policy ("robust written plan"):


  • required under article 28(2) of the Benchmark Regulation (Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014 (Text with EEA relevance));
  • in relation to investment funds using benchmarks within the meaning of article 3.1(7)(e) the Benchmark Regulation.


This template is suited for members of boards of directors/managers, investment managers, AIFMs, UCITS Management Companies. It does not cover any other aspect of the Benchmark Regulation (such as requirements for benchmark administrators). 


The template will need to be adapted to your specific needs depending on whether (i) your firm is an investment fund, a MiFID firm, AIFM, UCITS Management Company or another type of company and (ii) whether the fund(s) to which it relates is/are UCITS or AIFs.


    Please refer to our general terms and conditions and remember to always ask your legal adviser for help in case you have any doubt relating to the document. 


    Word file .docx

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