The European Money Market Institute adopted a Whistleblowing Policy on 26 September 2014 (and revised it on 24 November 2016) to allow any individual to alert, on an anonymous basis if necessary, to potentially suspicious or manipulative activity, or to other issues that may affect the integrity of The European Money Markets Institute’s benchmarks.
The policy applies to alerts and whistleblower claims made in relation to the determination of The European Money Markets Institute’s benchmarks, activities, and decisions as a benchmark administrator, and to other instances of potentially suspicious or manipulative behaviour which affect the production, publication, and application of The European Money Markets Institute’s benchmarks.
Whistleblowing alerts and claims may be made by any individual, including employees of the Panel Banks, the Calculation Agent, and The European Money Markets Institute.
If you are not an employee of The European Money Markets Institute, and your employer has in place a Whistleblowing Policy and mechanism, The European Money Markets Institute strongly urges you to consider making any disclosures through that process.
- Whistleblowing Policy
- Access the Whistleblowing online form (secured access)
Should your claim not be directly related to suspicious or manipulative activity, or to other issues that may affect the integrity of a benchmark of The European Money Markets Institute, please use the complaints form.
Handling of whistleblowing alerts or claims by The European Money Markets Institute
Upon receipt of the whistleblowing alert or claim, The European Money Markets Institute will record receipt of the alert or claim in a central register. Information recorded will include the delivery method of the alert or claim, the description of the alert or claim, any contact information that is provided, and whether the whistleblower has requested anonymity.
If the contact information of the whistleblower has been provided, The European Money Markets Institute will provide notification, within 7 working days of the alert or claim, via letter that the alert or claim has been received and that a resolution will aim to be provided within 60 days of receipt, given that The European Money Markets Institute is able to acquire the necessary documents, evidence, and testimonies in a timely manner.
If the whistleblowing alert or claim is deemed appropriate and related to potentially suspicious or manipulative activity, or to other issues that may affect the integrity of The European Money Markets Institute’s benchmarks, the relevant Oversight Committee of The European Money Markets Institute will investigate the whistleblowing alert or claim.
The investigation with regards to the alert or claim may include, but not be limited to, a review of appropriate communications, documentation, and data as well as discussions with relevant stakeholders.
The investigation may necessitate holding a hearing in front of the relevant Oversight Committee with the individual(s) at the focus of the whistleblowing alert or claim. The European Money Markets Institute will adhere to the strictest standards of confidentiality and respect the whistleblower’s preference for anonymity, if such a preference is indicated, throughout the processing and investigation phase.
The confidentiality of the individual(s) at the focus of the whistleblowing alert or claim will also be respected through the processing and investigation phase. The European Money Markets Institute’s Board of Directors may be asked for an advisory opinion if the aforementioned relevant Oversight Committee is unable to reach agreement on whether the whistleblowing alert or claim is valid.
In the event the whistleblowing alert or claim, deemed appropriate, is related to issues that affect the integrity of The European Money Markets Institute at the Association level, the Board of Directors itself will exercise the functions of investigation, hearing, and issuance of a resolution report.
In the event such alert or claim is related to issues concerning potential, actual or perceived conflicts of interest situation affecting The European Money Markets Institute at the Association level, the procedure described in the Conflict of Interest Policy (as available on website) applies and the Conflict of Interest Oversight Committee is involved in the resolution.
If the whistleblowing alert or claim is deemed legitimate following its investigation and information-gathering process, The European Money Markets Institute will provide notification and appropriate documentation to relevant regulatory and supervisory agencies. In the event The European Money Markets Institute does not concur with the whistleblowing alert or claim, The European Money Markets Institute will notify the whistleblower via an explanatory letter.
Whistleblowing documentation is subject to the record-keeping policies of The European Money Markets Institute.
Confidentiality & data protection
IOSCO Principle 4 for financial benchmarks requires that “Administrators should establish an effective whistleblowing mechanism to facilitate early awareness of any potential misconduct or irregularities that may arise.”
All whistleblowing alerts and claims that are received by The European Money Markets Institute will be addressed and resolved in accordance with relevant EU and national legislation. The identity of those making whistleblowing alerts and claims, as well as any element allowing their identification, will be kept confidential at all stages of the process.
In particular, their identity will not be disclosed to third parties, the person(s) addressed by the whistleblowing claim or alert, or other employees, unless The European Money Markets Institute is obliged to, in the event of any subsequent judicial proceedings or in case of an investigation by regulatory and supervisory agencies.
In the event the allegations made by a third party turn out to be false and made in bad faith, The European Money Markets Institute may decide to take legal action or file a complaint with a regulatory or supervisory agency.
Contact Us
To file a Whistleblowing claim use whistleblowing form or alert by letter, phone, or email. Please use following contact information:
Whistleblowing Manager
The European Money Markets Institute
56 Avenue des Arts | 1000 Brussels | Belgium
whistleblowing@emmi-benchmarks.eu
Tel. +32 2 229 08 325