ICE Benchmark Administration (IBA) has an independent board comprised of Executive Directors and Independent Non-Executive Directors.

The ICE LIBOR Oversight Committee is comprised of benchmark submitters, benchmark users, Independent Non-Executive Directors and other relevant experts, working together to return credibility to LIBOR and ensure its continued relevance.

IBA has developed a Conflicts of Interest Policy to apply specifically to IBA’s regulated activities.

IBA will consult publicly from time to time on proposed changes in relation to ICE LIBOR.

Independent Directors

André Villeneuve

André Villeneuve served as Chairman of the City of London’s International Regulatory Strategy Group from 2006 to 2012. He was Non-Executive Chairman of LIFFE (now part of Intercontinental Exchange), from 2003 to 2009. He was an Executive Director of Reuters from 1989 to 2000. He was Chairman of Instinet Corp., an electronic brokerage subsidiary of Reuters, from 1990 to 1999, and Executive Chairman from 1999 to 2002.

André was Chairman of Promethee, the French think tank, from 1998 to 2002, Non-Executive director of Aviva PLC from 1996 to 2006, Non-Executive director of International Financial Services London (IFSL) from 2007 – 2010, and Non-Executive director of TheCityUK from 2010 - 2012. He was also a Non-Executive director of IFRI (Institut Francais des Relations Internationales) from 2003 to 2009 and EuroArbitrage from 2003 to 2009.

Michel Prada

Over the course of his career, Michel Prada has been deeply involved in and committed to matters of regulatory standard setting. He has been a leading proponent of the establishment of International Financial Reporting Standards (IFRSs) and led the effort to establish the Public Interest Oversight Board (PIOB) of the International Federation of Accountants (IFAC) in 2005. As a member of the Financial Crisis Advisory Group, Michel also advised the IASB and the US-based Financial Accounting Standards Board on their response to the financial crisis. On 1 January 2012, Michel began a three-year term as Chairman of the IFRS Foundation Trustees.

In 12 years as the Chairman of the Autorité des Marchés Financiers (AMF) and its predecessor body (1995-2008), he was an outspoken advocate for investor protection and global standards. During this time he served as Chairman of the Executive and Technical Committees of IOSCO and was a founding member of the Financial Stability Forum (now the Financial Stability Board). He attended the Institut d'études politiques de Bordeaux, and the Ecole Nationale d'Administration. He graduated from the University of Law and Economics in France with a Masters degree in Law.

Dame DeAnne Julius

Dame DeAnne Julius is chair of University College London, and an independent non-executive director of Jones Lang LaSalle (USA). From 2003-2012, she was chairman of the Royal Institute of International Affairs (Chatham House, UK).

Dame DeAnne serves on the advisory boards of Temasek (Switzerland), Rock Creek Global (US) and the China Investment Corporation. She is vice president of the Society of Business Economists in the UK.

From 1997-2001, Dame DeAnne was a founder member of the Monetary Policy Committee of the Bank of England. From 2001-2004 she served on the Court of the Bank.

Prior to joining the MPC, she held a number of positions in the private sector including chief economist at British Airways and Shell. She has been senior economic advisor at the World Bank and a consultant to the IMF and UNCTAD.

Dame DeAnne is a dual US/UK citizen. She holds a BSc from Iowa State University and a Ph.D in economics from the University of California.

In 2012, DeAnne was made a Dame for her services to international relations.

Candice Koederitz

Candice Koederitz served as a Managing Director of Morgan Stanley from 1993 to 2016, most recently coordinating capital management globally for the Financial Holding Company. She served on the Risk and Asset Liability, Franchise and Real Estate Investment Committees. Candice co-chaired the Capital Commitment Committee, approving corporate lending commitments, and the Equity Underwriting Committees. Candice has extensive experience in the capital markets, new product development and regulatory requirements.

Candice served as Chief Executive Officer of Morgan Stanley Asia (S) Ltd Pte from 1998 to 2001, with management and leadership responsibilities for Morgan Stanley's Singapore office and business in Southeast Asia.

Candice holds a BSc in Civil Engineering from The University of Texas at Austin and an MBA from Harvard Business School.

Paula Madoff

Paula Madoff serves as an Advisory Director at Goldman Sachs, a global investment banking, securities and investment management firm. Paula has spent 24 years at Goldman Sachs, where she most recently was a Partner and Head of Sales and Distribution for Interest Rate Products and Mortgages until her retirement in August 2017. She brings experience in managing regulatory and market structure changes, investing, risk management, and capital markets activities. Paula serves as a non-executive director on the boards of Great-West Lifeco (GWO) and KKR Real Estate Finance Trust (KREF).

Paula held several additional leadership positions at Goldman Sachs, including: Co-Chair of the Retirement Committee, overseeing 401k and pension plan assets; CEO of Goldman Sachs Mitsui Marine Derivatives Products, L.P.; and was a member of its Securities Division Operating Committee and Firm-wide New Activity Committee. Paula is a 2018 David Rockefeller Fellow, a Director of Hudson River Park Friends, a member of the Harvard Women’s Leadership Board, and an Advisory Board Member of the NYU Hospital Child Study Center.

Paula received a Master in Business Administration from Harvard Business School and a Bachelor of Arts degree in Economics from Lafayette College.

John Crompton

John Crompton has spent the majority of his career in the Investment Banking Division of Morgan Stanley, working in London, New York and Hong Kong. John worked briefly for Merrill Lynch and, for six years until 2016 was at HSBC, where he headed the global Equity Capital Markets and Corporate Finance groups. John has also worked for HM Treasury: initially as a graduate entrant in the mid-1980s; as its corporate finance advisor in the mid-2000s; and, during the financial crisis, was a founder member of UKFI, HM Treasury’s investment vehicle, where he was responsible for HM Treasury’s stakes in Lloyds Banking Group and RBS. He was a member of the UK Takeover Panel during 2016.

John is Chairman-designate of Wyelands Bank, a UK trade and working capital-focused bank; chairs the advisory board of Issufy, a capital markets-focused fintech business; and is a governor of the Trinity Laban Conservatoire of Music and Dance in Greenwich, London.

John is a graduate of Oxford University.

Whistleblowing Procedure

Control Framework

IBA has developed and implemented a control framework for the design, calculation, maintenance and distribution of the benchmarks it administers. The control framework is formally documented and the IBA Board is responsible for regularly reviewing the control framework and its effectiveness.

The control framework is an overarching document that along with methodologies, policies and procedures, oversight and accountability mechanisms, and business processes covers the requirements of the IOSCO Principles. A summary of the main features are set out below:

The control framework describes processes and control activities relating to:
a. how conflicts of interest are managed and resolved in the business (with reference to IOSCO Principle 3).

b. (i), (ii), (iii), (iv) the integrity and quality of the design, calculation, maintenance and distribution of benchmarks (referring to IOSCO Principles 6 to 19); the automated calculation and distribution of the benchmark; and IT General Controls (“ITGCs”) supporting benchmark calculation, maintenance and distribution processes, including system-enforced password authorisation from two operators.

The ITGCs also include: User access management; systems change control; and Backup procedures.

IBA has a formally documented risk framework, approved by IBA's Board.

c. There is a formal whistle-blower policy in place. An annual Whistleblowing report is made to the IBA Board.

d. All employees are subject to external screening prior to appointment and then required to complete a probationary period of employment which includes training on benchmark production. All employees are subject to annual performance appraisals.