This compliance policy encompasses responsibilities assumed by OPIS’s administrative, editorial and operational departments. Our commitment to excellence and objectivity in market assessments enables OPIS to provide the marketplace with the most comprehensive, equitable, verifiable and reliable price intelligence available. Please go here to let us know if you have a question, complaint, compliment or comment about one of our spot assessments.
All OPIS employees adhere to the Dow Jones Business Code of Conduct, which can be found here.
The following compliance policy applies globally to OPIS’s market assessments and market reporters worldwide with regard to our spot price assessments.
a. Business Code of Conduct Hotline
b. Authority of senior officers to oversee day-to-day compliance with price editing procedures
c. Policy and training on methodology for pricing editors
d. Wall of separation: editorial/marketing/sales
e. Management of advertising conflicts w/market participants
f. Regular training on methodologies, policies and procedures for confidential information, conflicts of interest, personal account dealing, editorial independence
g. Business Relationships and Activities
h. Securities Transactions
i. Cooperation with authorities
j. Remuneration for pricing editors not tied to sales of price reporting services
a. Methodology posting
b. Criteria for excluding deals or transaction data
c. Fair, equitable and unbiased data collection process
d. Policy for confidential information and archiving of transactional data for appropriate time
e. Policies & procedures to identify data that might be provided to OPIS that fails to conform to OPIS methodology
f. Reporting of job offers to pricing editors by market participants
g. Priority to concluded transactions
h. Codification of who may submit data for assessments
i. Record retention – 5 years
j. Corrections policy – who may correct & who must review
a. Timely publication of pricing data, corrections, changes in methodology, feedback from market participants
b. Business continuity plan
c. Publication of complaints policy
d. Appeal of complaints separate from editorial & pricing editors
e. Complaints log with record of decisions
f. Annual attestation of compliance or explanation of non-compliance & corrective measures
g. Independent review of compliance
Code of Conduct Hotline
Dow Jones has a dedicated toll-free Alertline telephone number and an Alertline web site are available for all employees of News Corporation companies to report complaints. The number, available 24 hours a day, 365 days a year, is +1 866-480-6129, and the web site can be found here. An employee can make an anonymous report through Alertline.
Authority to senior officers to ensure day-to-day compliance with price editing procedures
OPIS senior officers are empowered to oversee and supervise the activities of market assessors. They can discipline market assessors and failing improvement in performance, terminate for cause. Senior officers are empowered to ensure compliance with OPIS’s ethics and best practices policies. Senior officers oversee the day-to-day production of market assessments and regularly review them for accuracy and consistency. OPIS senior editors must review and sign off on spot market assessments prior to their publication. OPIS’ systems do not allow spot market assessors to publish assessments unilaterally. Only senior editors who were not involved in that market’s assessment on that day may approve and publish the assessment.
An OPIS senior editor will also review and verify the past three (3) months of spot assessments conducted by a spot market editor if said editor leaves OPIS for employment with a company or entity that had contributed to his or her spot market assessments. This investigation and verification will be conducted and completed within five (5) business days of the employee’s termination of employment.
Policy and training on methodology for pricing editors
OPIS employs a system of mentoring for junior pricing editors and for editors seeking to learn other markets. This training process includes requirements for a deep understanding of our methodologies and policies as well as the nuances of the markets and products covered. No editor is allowed to assess a market without having undergone the prerequisite training and oversight by the mentoring editor.
In addition, each spot market assessor undergoes periodic performance reviews no less frequently than once (1) per year.
Wall of separation: editorial/marketing/sales
OPIS separates its marketing and sales departments from the editorial group functionally. Each has its own director-level senior staffer that is empowered to make individual decisions and report directly to the OPIS CEO.
Additionally, no editor or editorial supervisor is compensated or incentivized via a sales-related bonus plan.
Management of advertising conflicts w/market participants
OPIS’s sales and advertising departments understand there is no “quid pro quo” for advertising with OPIS that would guarantee favorable editorial treatment in either news or market analyses. Routinely, advertisers and sponsors of OPIS publications and events are the subject of objective, unbiased news analysis and market reporting without prejudice to the amount (or lack thereof) of sponsorship and/or advertising revenue spent with the company.
Regular training on methodologies, policies and procedures for confidential information, conflicts of interest, personal account dealing, editorial independence
Every year, OPIS market assessors must undergo refresher courses on OPIS’s methodology, confidential information, conflicts of interest, personal account dealing, editorial independence and ethics policy.
Business Relationships and Activities
See section under Business Relationships and Activities within the Dow Jones Code of Conduct found here.
See section under Securities Transactions within the Dow Jones Code of Conduct found here.
Compliance with Laws, Rules, and Regulations
OPIS cooperates with all appropriate federal authorities to the fullest extent required by law. See section under Securities Transactions within the Dow Jones Code of Conduct found here.
Remuneration for pricing editors not tied to sales of price reporting services
No OPIS pricing editor or market assessor is incentivized on sales of OPIS products.
OPIS publishes its market assessment methodology in full and in abbreviated form in its nightly reports. The methodology is written in clear, easy-to-understand language and is fully available to the public and does not require a user name or password for access.
Criteria for excluding deals or transaction data
OPIS adheres to its methodology language first and foremost. Any data that does not conform to the methodology’s definitions regarding timing, size, specification, volume or verifiability are not included in OPIS’s market assessments.
Fair, equitable and unbiased data collection process
OPIS does not discriminate between reporting parties that are in good standing and have demonstrated a commitment and reputation for truthful and accurate price discovery when calculating its market assessments.
Policy for confidential information and archiving of transactional data for appropriate time
OPIS does not disclose sources of market information or counterparties of market transactions to any source or subscriber. Proper safeguards are observed for ensuring source confidentiality. Transactional data is archived in a secure location on OPIS servers for a period of no less than five years.
See also Information – Confidential and Proprietary Information, IHS Inc. Business Code of Conduct, p15.
Policies & procedures to identify data that might be provided to OPIS that fails to conform to OPIS methodology
OPIS market editors are fully trained in the parameters of OPIS methodology and any market data provided that falls outside of those parameters is not included in OPIS market assessments. OPIS market editors are required to exercise diligence in ensuring data considered in its ranges are in strict concordance with OPIS methodology.
Reporting of job offers to pricing editors by market participants
OPIS market editors are required, upon pain of disciplinary action up to, and including, termination, to report any and all job offers proffered by market participants as soon as those offers, if any, are made.
Priority to concluded transactions
OPIS market editors give all due priority to concluded transactions when making market assessments.
Codification of who may submit data for assessments
OPIS market editors are instructed to accept market data submissions only from bona fide sources that are participants in the markets OPIS assesses. OPIS spot market assessors expect data submitters act in good faith to submit only complete and truthful market intelligence about their trading activity. If any data submitter is found to be submitting incomplete or inaccurate data, OPIS spot market assessors will no longer accept data from that submitter. OPIS considers the data it receives to be sufficient and accurate to assess a spot product’s value.
Only “bona fide” market participants with a stake in the supply chain may provide data to OPIS for the purpose of assessing spot markets. “Bona fide” data submitters include spot product producers, consumers, traders, brokers engaged in getting buyers and sellers to a transaction or entities with a financial stake in spot market products.
Record retention – 5 years
OPIS market editors retain records of all market data used in market assessments for a period of no less than five years in a secure electronic environment.
Corrections policy – who may correct and who must review
Upon discovery of the need for a correction whether realized internally or from an outside party alerting an OPIS market editor, a correction is drafted by the market editor who assessed the market in question. That corrections draft is reviewed by a direct supervisor who reviews it for accuracy and then issues the correction through the same communication medium used to assess the market. Only market editors who are directly involved in the market assessment in question may draft a correction and only a supervisor of that market editor can authorize the issuance of a correction.
Timely publication of pricing data, corrections, changes in methodology, feedback from market participants
OPIS publishes its pricing data by a strict deadline each day the market is assessed. Corrections are posted as soon as they have been properly reviewed by the appropriate market supervisor. Changes in methodology, once vetted by market sources, are published with at least 30 days’ notice in OPIS’s publications, on OPIS’s website and in letters sent to OPIS customers. Feedback from market participants is evaluated as soon as it is received.
Business continuity plan
Each market OPIS assesses has three fully trained market editors assigned to it. Each of these market editors is fully versed in the latest methodology, market participants and market intelligence available for that market. In the event the primary market editor is not available to assess his or her market, the secondary editor is fully capable of stepping in to assess the market. Additionally, a third level of redundancy in editorial continuity is built in. All OPIS data is thoroughly archived and backed up by information technology systems and hardware on- and off-site.
Publication of complaints policy
OPIS’s complaint policy is posted on its website and is freely and publicly available. Please go here to view it.
Appeal of complaints separate from editorial & pricing editors
In the event a complainant wishes to appeal the treatment of his or her complaint about an OPIS market assessment to someone other than the market editor involved or his or her editorial supervisor, OPIS management is available to field that appeal and act accordingly based on the information presented by the complainant in a timely manner.
Complaints log with record of decisions
OPIS maintains a complaint log that records any and all complaints about market assessments issued by OPIS, how those complaints were fielded and treated and the reasoning behind why the complaint was treated in the manner it was treated. This complaint log is readily available to customers and market participants.
Annual attestation of compliance or explanation of non-compliance & corrective measures
OPIS employs both internal and external good practices auditors who ensure OPIS market editors and editorial supervisors adhere strictly to our own methodology, policies and procedures. Annual audits are conducted and OPIS compliance is attested to by both independent and corporate governance and in the instance of non-compliance, if any, corrective measures taken or to be taken are fully described.
Independent review of compliance
The above-mentioned annual attestation of compliance will be available publicly on OPIS’s website within 30 days of its completion.