Governance and Conflicts Policy

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• Role-based access to unpublished values and production systems.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.