# Policies: complaints, consultation, errors and restatements, constituent venues, insufficient data

**Version 1.0 — 24 September 2026.** The user-facing procedure documents every serious
administrator publishes as standalone pages. Precedents: IBA Complaints
Policy (Jan 2026), FTSE Complaints-Handling Policy and Operational Enquiries & Price
Challenges policy, IBA Consultation Process, FTSE Policy for Benchmark Methodology Changes,
IBA Precious Metals Error Policy, ISR Republication and Insufficient Data policies, CF
Constituent Exchanges Criteria v8.5 and List v13.7, CF Statuspage.

These sit under the rulebook §7, §8 and §10 and replace the one-line
versions there where they are more specific. **Methodology v1.0 (28 September 2026) is the sole
governing methodology**; where these policies differ from it, it governs. In particular: restatement
is at 1 bp or any error that changes a settlement obligation, within two business days
(Methodology §6.5); complaints are acknowledged within 2 business days and answered within 20
(§9.5); a material change needs at least 30 days' consultation and then at least 30 days' notice
(§9.6).

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## 1. Complaints policy

**Two tracks**, so every question is not a complaint:

| Track | What it is | Handling |
|---|---|---|
| **Operational enquiry / price challenge** | "Was the 22 Sep close right?", "why was cETH `NO FIXING` on Tuesday?" | answered by the administrator from the fixing record within **1 business day**; if the answer is a restatement, §3 applies |
| **Complaint** | an allegation that the methodology was misapplied, that a member acted improperly, or that the administrator's conduct fell short | formal process below |

**Formal complaint process.**
1. In writing to `hello@etpfoundry.com` with subject `Complaint — [instrument] — [date]`, or
   directly to the committee (committee@etpfoundry.com, or any member's roster e-mail); the complainant may write to the
   committee without going through the administrator.
2. **Acknowledged within 2 business days**, with a reference number and the name of the
   investigator.
3. The investigator is **not a person who proposed, computed or confirmed** the fixing in
   question.
4. **Final response, or a holding letter with a date, within 8 weeks.**
5. Unresolved complaints go to the next quarterly meeting and are minuted; the summary
   minutes record the outcome without naming the complainant unless they agree.
6. Records kept **7 years** (rulebook §10).
7. Nothing in this policy limits a complainant's right to go to a regulator or court.

## 2. Consultation policy (methodology changes)

Replaces bare notice periods. The on-ledger `K`-of-`N` vote of rulebook §8 remains the
approval step; this is what happens before it.

- **Material change** = any change that requires an update to the published methodology
  (selection, weighting, waterfall, schedule, committee composition rules, tolerances in
  aggregate, reserve-model treatment).
- **Consultation paper** states: the change; the rationale; the expected impact on the
  published series, with a back-test where possible; the treatment of existing contracts
  referencing the benchmark; the proposed effective date.
- **Standard period: one month.** Urgent: two weeks. Concurrent notice-and-consultation
  only in extremis (a chain event under the chain and wrapper event policy), and then said so.
- **Feedback statement** published with every response and the administrator's answer,
  unless the respondent asks for confidentiality; then the on-ledger vote; then **at least
  30 days' notice** before effect. Non-material changes: 5 business days' notice.
- Open and closed consultations are listed on `etpfoundry.com/news` with dates.
- No retroactive change, ever (rulebook §8.4).

## 3. Errors, restatements and the quarterly error table

- **Republication window per series**, stated in its factsheet. Default for a settlement
  fixing: **never republished after the next business day's strike** (WMR rule); errors
  found later are disclosed, not corrected. Where a licensee needs a same-day correction
  window, the series declares it (CF: same day; IBA: 30 minutes).
- A restatement is a new on-ledger record with the same `K` (rulebook §7.7); the original
  stays visible, marked superseded, and never carries forward the original evidence.
- **Quarterly error table**, published from day one, all zeros being the point:

| Year | Quarter | Fixings published | Errors found | Restated | Largest impact (bp) | Notes |
|---|---|---|---|---|---|---|
| 2026 | Q3 (shadow) | — | 0 | 0 | — | shadow run; nothing settled against |

- Every delay, `NO FIXING`, restatement and market-failure event is posted to
  `etpfoundry.com/status` when it happens, with the reason, and listed in the quarter's
  minutes.

## 4. Constituent venue list and process

The public, versioned document CF publishes as "Constituent Exchanges"; ours lives at
`etpfoundry.com/benchmarks/<id>` in the document bundle and here.

**Criteria**: rulebook §4.0 plus ToR §3 (data-sharing agreement, trade + order API, KYC/AML,
cooperation with inquiries, volume share).

**Process.**
- **Anyone may nominate** an addition or a removal, in writing to `hello@etpfoundry.com`
  with subject `Venue nomination — [venue] — [instrument]`; the nomination is acknowledged
  in 2 business days and taken to the next quarterly meeting, or sooner if the
  administrator suspends.
- The **administrator may suspend** a venue ad hoc (surveillance alert, outage, loss of
  licence); the **committee decides** whether the suspension becomes removal; **every
  decision is published** with its date and reason.
- **Annual conformance review** of every venue, presented to the committee and minuted.
- Volume failures take effect at the next quarterly review, not intra-quarter.

**List — version 1.0 (24 Sep 2026): no venues admitted yet.** No value is published above tier 0
until at least two independently operated venues are on this list (Methodology §6.4); with one
venue, every value is tier 0, published and labelled.

| Venue | Operator | Instruments | Admitted | Status | Notes |
|---|---|---|---|---|---|
| — | — | — | — | — | first two admissions precede the first index value |

## 5. Insufficient data and calculation failure

Formalises the rulebook §7 outputs as named policies:

- **`NO FIXING`** is published as a value slot with a reason code (quorum not reached,
  refusal, missing attestation, unreconciled register, chain event); it is a record, not
  an absence. `EXCEPTIONAL` is never used for these: it means only a move larger than Y;
  chain events are flagged `EVENT-<type>`.
- **`CARRIED FORWARD`**: the prior value with a visible marker; never silently.
- **Three consecutive carry-forwards** on one instrument obliges the committee to authorise
  a response (extend the window, change the input tier, suspend the series) and to minute it.
- The status page shows every such event as it happens.

## 6. Notice and disclaimer (printed on every document and value page)

*ETP Foundry benchmarks may be changed or cease at any time under the consultation and
cessation policies. Users should ensure their contracts contain robust fallback provisions.
Values are published with the number of signatures, the trust level of each, and the
rulebook version that produced them; a value published under the pilot configuration says
so on its face. Nothing here is investment advice, and ETP Foundry is not an authorised or
registered benchmark administrator in any jurisdiction, and does not claim that status
(Methodology v1.0 §12).*

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*Status: v1.0, effective on adoption at the first quarterly meeting; published now as the
process we will follow from the first shadow fixing.*