Governance
Governance and Conflicts Policy
Responsibility, oversight function, and the controls that separate benchmark determination from commercial influence.
Responsibility
Almena Energy retains responsibility for benchmark design, calculation, publication, correction, records and any outsourced functions.
Oversight function
An oversight function independently challenges new benchmarks, material changes, conflicts, judgement, incidents, complaints, assurance and cessation.
Controls
- Separation of benchmark determination from commercial influence.
- Role-based access to unpublished values and production systems.
- Annual and event-driven conflict declarations.
- Conflicts and discretion registers.
- Recusal and independent approval.
- Restrictions on personal trading where a conflict could arise.
- Disclosure of material residual conflicts.
No client, investor, employee or commercial team may request a preferred benchmark outcome.
Governance functions
| Function | Responsibility |
|---|---|
| Methodology | Design, assumptions, evidence and reference-asset schedules |
| Calculation | Controlled calculation, exception handling, reconciliation and release approval |
| Data governance | Sources, licences, quality, fallback and coverage |
| Oversight | Material changes, conflicts, corrections, complaints and cessation |
| Security | Service access, authentication and information classification |
| Commercial | Customer tiers without control over benchmark determinations |
Launch4 S.L. retains primary responsibility for benchmark design, methodology, determination, publication, corrections, changes and cessation, including where data, infrastructure or calculation services are supplied by third parties.
MCP governance
The Almena Analytics MCP provides subscription-based access to selected analytical capabilities. Access is authenticated, entitlement-scoped and monitored, and no customer-specific override of a public benchmark is possible.