Conflict of Interest Policy

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Overview

As a benchmark administrator, Modo Energy (Benchmarking) Ltd (“Modo Energy”) is committed to maintaining the highest ethical standards and ensuring that its benchmark administration activities are free from any actual or potential conflicts of interest that could compromise the integrity, accuracy, or independence of its benchmarks.

Modo Energy recognises that potential conflicts of interest may arise in the course of its benchmark administration activities. These conflicts may occur between Modo Energy’s employees, stakeholders, clients, data providers, and other market participants involved in the benchmark calculation process. Modo Energy has therefore implemented robust governance structures and conflict of interest policies to ensure that such conflicts are identified, disclosed (see Modo Energy Conflict of Interest Disclosure Statement), managed, and mitigated effectively.

Disclosure of Potential Sources of Conflict

Potential sources of conflict and related mitigation measures include, but are not limited to:

Venture capital investors in Modo Energy who may have interests in related sectors (e.g., renewable energy):

Investors in Modo Energy include Fred Olsen Limited, a private fund with significant investments in renewable energy and energy storage projects. Such investors may have a financial interest in assets that are part of the benchmark and could seek to influence the benchmark’s outcome to improve the performance of their investments. Future investors in Modo Energy’s parent entity could have similar interests. To mitigate this conflict, Modo Energy ensures that these investors do not have direct influence over day-to-day operations or the benchmark calculation process. The company maintains an independent board, and investors are restricted from participating in decisions related to benchmark methodologies. Modo Energy’s operations and benchmarks are guided by the strict transparency and governance standards required under the FCA’s Benchmark Regulation (EU 2016/1011), ensuring independence from external commercial interests.

Data providers or service providers who may have a competing interest in the performance of the benchmark:

• Modo Energy relies primarily on publicly available data from reputable sources such as NESO, N2EX, EPEX, EMRS, and public market announcements to calculate the ME BESS GB Indices. By basing the indices on public datasets, the benchmark calculation process remains transparent and free from undue influence.

• Modo Energy does not use customer-specific performance data from battery storage assets in benchmarking calculations. While such data may be available, excluding it ensures the indices remain impartial, standardised, and representative of the broader market, and avoids potential conflicts of interest where asset owners might have incentives to influence results.

• In limited cases where public datasets are ambiguous, incomplete, or conflicting, Modo Energy may exercise discretion to validate the information. This can include cross-checking across multiple public sources and, where necessary, confirming factual details (such as capacity or commissioning date) with asset owners or operators. These confirmations are used only to supplement public data and ensure accurate asset inclusion and identification; they do not replace public data as the basis of the benchmark.

• All discretionary decisions are recorded in the Discretion Register with a clear rationale and supporting evidence, and are subject to independent review by the Oversight Function.

• By following this approach, Modo Energy ensures the ME BESS GB Indices remain objective, transparent, and free from external influence, giving stakeholders justified reliance on their accuracy and impartiality.

Clients who use the benchmark for financial derivatives or investment assessments:

Modo Energy has received interest from major financial institutions in using the ME BESS GB Indices for derivatives trading and investment assessments. These clients may have a vested interest in influencing the benchmark to benefit their financial positions. To mitigate this conflict, Modo Energy enforces a strict separation between its benchmark administration team and any teams interacting with clients. Where members of the Research Team communicate with asset owners that are also financial institutions, such communication is strictly limited to obtaining objective, factual data relating to asset sizing and operational characteristics, as outlined in the Discretion in Benchmark Determination Policy. These contacts are not with trading or investment functions, and no commercially sensitive information is shared or received. Employees involved in client business activities are prohibited from accessing or influencing the benchmark’s data or methodology. Additionally, all benchmark methodologies are published and publicly available to ensure transparency, and any changes to the methodology must be approved by the independent Oversight Function. This ensures that the benchmark remains unbiased and free from external influence, regardless of client interests.

Identifying Conflicts

Modo Energy periodically reviews its business practices and external relationships to identify any potential conflicts of interest. Specifically:

• Annual Disclosures

Employees and each member of the Board of Directors and Oversight Function are required to submit annual disclosures of outside business interests, financial relationships, or investments.

• Ad-hoc Reviews

Any changes in circumstances, such as a new investment by an employee in a relevant industry, are to be reported immediately to the compliance team.

Raising Concerns

To raise a concern about a potential conflict of interest:

1. Reporting

Any employee or stakeholder who identifies a conflict or potential conflict must report it immediately via the conflicts reporting system, which triggers an alert to both the Board and Oversight Function. A link to the reporting form is available here.

2. Conflicts Register

All reported conflicts are logged in a central register, which is reviewed each quarter and audited by the Oversight Function to ensure resolution and transparency. To request access to the Conflicts Register, please email team@modoenergy.com.

3. Escalation

Where necessary, conflicts that pose a significant risk to benchmark integrity are escalated to the board for further action, which could include reassignment of responsibilities or changes to internal procedures.

Managing and Mitigating Conflicts

Modo Energy has established the following key measures to ensure the fair and transparent management of conflicts. This includes:

Governance and Segregation

Modo Energy has implemented appropriate segregation of duties and responsibilities to ensure that decisions related to the benchmark calculation are made independently and without undue influence from other business activities, external relationships, or internal cross-functional interactions that could introduce conflicts of interest. Employees directly involved in the provision of the benchmark are subject to effective procedures controlling the exchange of information with other employees who may be engaged in activities that could create a potential conflict, such as commercial operations or client engagement.

Example: Employees responsible for compiling and analysing benchmark data operate separately from those involved in business development or client-facing roles. Access to sensitive data is managed through role-based controls, ensuring that information is shared only on a need-to-know basis and cannot be accessed or influenced by individuals whose activities may pose a conflict of interest. Access to data is controlled, and decisions on methodology changes are reviewed by the Board of Directors and an independent Oversight Function.

Procedural Controls

• Strict role-based access control is applied to sensitive benchmark data and systems to prevent unauthorised interference with benchmark data.

• Employees involved in the benchmark calculation process undergo mandatory training to ensure they understand their obligations related to information sharing and conflict prevention.

• Internal communications that could potentially impact benchmark decisions are monitored, logged, and reviewed periodically to identify any inadvertent breaches of segregation protocols.

• Employees are required to disclose any incidental interactions that could lead to conflicts and report them via Modo Energy's internal reporting system.

Transparency of Methodology

The benchmark is calculated using a transparent, standardized methodology based on publicly available data from sources such as NESO, Elexon, and EPEX. This ensures that benchmark levels can be independently verified and recalculated by users, reducing the risk of manipulation or bias.

Example: A detailed methodology document outlining the exact sources of data, calculation steps, and criteria for adjustments is made available to clients, ensuring that any discrepancies can be checked against the published methodology. A copy of this methodology is available at: https://modoenergy.com/methodology/gb

Prohibition of Trading and Improper Influence

Employees involved in the calculation and administration of the ME BESS GB Indices are prohibited from engaging in personal trading of any financial instruments related to the benchmark.

Confidentiality and Data Handling

Modo Energy is committed to protecting the confidentiality of all information submitted to or produced by the company in relation to its benchmarks. Access to sensitive data is restricted to authorised personnel, and appropriate security measures are in place to ensure that confidential information is not disclosed or misused.

Key security measures include:

Role-Based Access Control (RBAC)

Access to databases and sensitive systems is managed through role-based access control. Only employees with specific roles (e.g., benchmark data administrators) are authorised to access production databases. Permissions are granted based on job responsibilities, and are reviewed regularly to ensure compliance with this policy.

Separation of Environments

Modo Energy enforces strict separation between development, testing, and production environments. Only authorised employees have the ability to write or make changes directly to the production database, ensuring that only verified and approved updates are deployed. All code or data changes must go through a multi-stage approval process before being applied in the production environment.

Two-Factor Authentication (2FA)

All employees must use two-factor authentication when accessing sensitive systems or databases. This adds an extra layer of security beyond passwords, ensuring that only authorised users can gain access.

Example: Only employees on the Engineering and Data Science teams have access to the codebase that handles the logic for benchmark calculations. This access is strictly controlled and monitored to ensure that no external parties or other employees can interfere with the calculation process. Access is tracked via an internal authentication system to ensure full compliance with confidentiality and security policies.

Policies

In addition, Modo Energy has other policies and procedures in place addressing potential conflicts of interest, including those on:

• Information Security;

• Data Management;

• Anti-corruption and bribery;

• Whistleblowing.

More detailed explanations of these policies, including responsibilities, procedures, and escalation pathways, can be found in the Benchmarking Compliance Manual.

Material Residual Conflicts

Having regard to the governance, controls, and procedures in place to mitigate potential conflicts, Modo Energy does not consider there to be any material residual conflicts of interest that would impair the integrity or independence of its benchmark administration activities.

Ongoing Review

Modo Energy’s conflicts of interest policy is reviewed and updated regularly to ensure that it remains effective and aligned with both regulatory requirements and best practices in the industry. Any updates to the policy are communicated to employees, clients, and other stakeholders as necessary.

Audit Process

Each quarter, the Oversight Function reviews the Conflicts Register, assesses how identified conflicts were managed, and reports findings to the Board. This ensures ongoing alignment with internal policies and FCA regulations.