Restricted persons and conflicts

B.1 MLM's own policy (adopted by the Index Committee; published at /governance)

1. Restricted Persons. The following are Restricted Persons:(a) Major League Markets, Inc. and any affiliate;(b) every officer, director, employee and contractor of MLM;(c) every member of the Index Committee, including the independent member;(d) any person with write access to a settlement ledger, the close process, the results-ingestion code or the production deployment of the index; and(e) any household member of a person in (b) to (d), and any account a person in (b) to (d) controls or directs.
2. No trading. No Restricted Person may trade, hold or have any beneficial interest in any contract, on any venue, whose settlement value or price references an MLM index or an MLM constituent. This includes Index-Linked Products A to F and any third-party product referencing them.
3. No market making. MLM does not quote, make markets, provide liquidity, hold inventory or take any position in any contract referencing its indices. MLM does not trade on its own account in any sports event contract.
4. No outcome positions. No Restricted Person may trade an event contract on the outcome of a game, playoff round or final standing of a league for which MLM publishes a live index, while that index is live.
5. Non-public information. Restricted Persons may not disclose to any person, before publication, any close value, correction event, methodology change under consideration or the content of an Index Committee deliberation, except to the venue or a regulator as provided in Appendix H.
6. Annual attestation. Each Restricted Person signs an attestation of compliance at onboarding and each January. MLM keeps the attestations for at least five years and provides them to a licensee or, through the licensee, its regulator on request.
7. Breach. A breach is reported to the Index Committee and to each licensee within two business days of discovery, with the positions involved and the remedy.