Governance

Version 1.1
Last Updated: December 2019

Introduction:

The Principles for Oil Price Reporting Agencies ('PRA Principles'), as published by the International Organization of Securities Commissions (IOSCO) on 5th October 2012, encouraged PRAs to implement the PRA Principles to any assessment of any commodity that is used to reference the terms of a derivative contract. In response to the PRA Principles, all Spark Commodities ('Spark') assessments have been designed to align to the required Principles.

This documentation outlines our Governance procedures and we are constantly looking to improve on how we develop in this area.

Organisation and Business:

Spark has a robust governance structure in place to ensure the business is conducted responsibly, effectively, and with due regard for all stakeholders' interests.

Neither Spark nor its shareholders participate in the markets Spark assesses. Independence, neutrality and impartiality are central to the work Spark does. Spark has no financial interest in the price of the products or commodities on which it reports. Spark's aim is to reflect market value.

Spark methodologies are designed to clearly describe:

  1. The specifications of the commodity Spark is assessing.
  2. The way that Spark collects relevant assessments.
  3. How these assessments are used to create the relevant Spark Price.

Spark Principles:

Our Contracts:

Existing Spark Contracts which align to IOSCO principles for Price Reporting Agencies:

LNG Freight:

Spark methodologies are designed to produce price assessments that are representative of market value of the particular markets to which they relate and are available for review on the website..

3 step process to Spark contract creation:

  1. Market Engagement and Contract Design: extensive conversations/meetings with market participants and brokers to assess demand and preferred contract specifications.
  2. Contract Testing:
    1. Release of contract for testing with brokers: feedback received and contract refined where needed.
    2. Release of contract for market acceptance testing in form of trial period.
  3. Contract Implementation: launch of contract after completion of contract testing phase with all contract specifics made available to all users via the platform.

Who can submit data?

Platform Permissions:

Spark manages a strict permission system for users of the platform. Access to the information on the platform is restricted by permission rights.

What are the requirements for Brokers to contribute and how does Spark ensure they reflect the market?

Price Assessments and Data:

Spark Methodology Documentation:

Spark Methodology documentation is available on the website. It describes the specifications and processes that Spark adheres to in collecting data and the methods Spark uses to calculate assessments from its data inputs.

How do we assess Spark prices and how can I submit?

Verification of Submitted data:

Order of importance for collated data informing the Spark Price Assessment:

Broker assessments will be primarily be based on the following types of data (in descending order of importance). However price assessments will take into account the lack of standardisation and current lack of liquidity in the LNG freight market.

  1. Concluded Transactions
  2. Bids and Offers (currently being tested via reported/confirmed assessment feature)
  3. Other Market Information

Assessment guidelines:

Corrections to assessments:

Spark will on occasion publish corrections to price assessments after the publication date. These errors may arise from clerical mistakes or miscalculation errors amongst other things. Spark will not allow retrospective submissions after the price assessment window has closed.

Spark Governance:

Ethics and compliance:

Review of methodology:

Changes to methodology:

Spark follows a clear process for introducing or making changes to its methodologies. This process is based on full transparency and communication with industry stakeholders aimed at gaining market acceptance for any proposed introduction or change to methodology.

Discontinuing Assessments:

There may be occasions when a Spark assessment ceases to be relevant to the marketplace. Where possible, Spark will provide at least 120 days' notice of its intention to discontinue an assessment. If an unforeseen event causes a severe disruption in a particular market, the timeline for discontinuing an assessment (sometimes on a temporary basis) may be shortened. Spark will communicate a proposal to discontinue an assessment by formally writing to all users.

Skills and Training:

Spark hires suitable candidates from a broad range of backgrounds. All employees go through an onboarding process to ensure that they have a thorough and adequate understanding of Spark business processes and procedures.

Compliance:

At the beginning of each calendar year, all Spark employees must complete conflict of interest disclosure questionnaires and satisfy other compliance-related requirements.

Complaints Procedure:

The Complaints Procedure has been designed so that anyone may submit a complaint regarding any issue relating to the services Spark provides. Details of the process are highlighted below:

Data Security and Confidentiality:

Audit:

Alignment with IOSCO Principles:

Our methodology, governance process and data policies are aligned to IOSCO principles. Please find the link to the relevant IOSCO principles below:

IOSCO Principles

Revision History:

Latest Changes:

Version Date of Revision Description of Changes

1.1

5th December 2019

Addition and clarification on the following topics:

  • Introduction
  • Organisation and Business
  • Discontinuing Assessments
  • Verification of submitted data: updates
  • Spark Methodology Documentation
  • Complaints Process: clarification and more detail
  • Conflicts of Interest
  • Risk and Compliance
  • Skills and Training
  • Permissions
  • Revision History