To ensure that the benchmarks administered by Wilshire Indexes meet the highest standards of accuracy and reliability, Wilshire Indexes has developed a governance framework to oversee all aspects of the determination and dissemination of its benchmarks. The various bodies involved in the oversight of benchmarks administered by Wilshire Indexes are summarised below. Together, these bodies are responsible for the development and/or approval of the various policies and procedures that apply to the Wilshire Indexes business.

As part of the Wilshire group of companies, a number of policies developed at the group level apply to the staff of Wilshire Indexes.  The policies include those embedded within the Wilshire Compliance Manual and the Wilshire Code of Ethics which cover, inter alia the rules concerning personal dealing, and the acceptance and provision of gifts and entertainment. In addition to Wilshire group policies, the Wilshire Indexes Oversight Function has developed and approved index-specific policies that apply to all aspects of the administration of Wilshire Indexes benchmarks.
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Conflict of Interest Policy
The Conflicts of Interest Policy sets out how potential conflicts within the Wilshire Indexes business, and conflicts between Wilshire Indexes and other businesses within the Wilshire group, should be identified, mitigated, managed and reported. For further details please see Wilshire Indexes Conflicts of Interest Policy

Market Abuse Policy
The Market Abuse Policy sets out the policy and procedures that Wilshire Indexes has implemented in order to mitigate and manage the potential risk of abuse of material non-public information (known as inside information in the UK Market Abuse Regulation (UK MAR)), and of potential index manipulation by internal and external parties.  For further details please see Wilshire Indexes Market Abuse Policy

 Queries and Complaints Policy
The Queries and Complaints Policy sets out the procedures to be followed should an index user or other stakeholder wish to query the determination of an index.  If the query is not answered to the complainant's satisfaction, the query can be elevated to a complaint for formal consideration by the Wilshire Indexes Executive Committee.

Benchmark Approval, Change and Cessation Policy
The Benchmark Approval, Change and Cessation Policy sets out the procedures to be followed by Wilshire Indexes when approving a new benchmark methodology, changing an existing benchmark methodology (material and non-material changes are distinguished), and ceasing the calculation and publication of an existing benchmark.

All benchmarks administered by Wilshire Indexes are maintained according to policies that apply to all indexes that select their constituents from a particular asset class.  These policies supplement the methodology documentation for individual indexes and should be read in conjunction with those methodology documents.

Equity Index Calculation and Corporate Action Guide
The Equity Index Calculation and Corporate Action Guide sets out the method of index calculation including the treatment of corporate actions.  The guide also summarises the procedures to be followed in those circumstances where prices for individual securities or securities traded on a particular market are unavailable.

Error Correction Policy for Equity Indexes
The Error Correction Policy for Equity Indexes sets out the procedures to be followed in the event of an error being discovered that affects the calculation of an index.  

Input Data Used in Equity Benchmarks
The Input Data Used in Equity Benchmarks document describes the various types of input data that are used in the determination of Wilshire Indexes equity benchmarks.

Policy for the Exercise of Expert judgement
The Wilshire Indexes methodology documents and the index policies published here are written to be transparent and objective so as to minimise the need for expert judgement in so far as is practical.  However, there may be circumstances in which expert judgement is required, including in the determination of an input data variable, or in the most suitable implementation of a corporate, or market, event. See Wilshire Indexes Policy for the Exercise of Expert Judgement.

UK and EU BMR

Wilshire Indexes is registered as a Benchmark Administrator with the United Kingdom Financial Conduct Authority in accordance with the EU Benchmark Regulation (EU2016/1011) and the supplementary regulatory technical standards, and of the retained EU law in the UK (The Benchmarks (Amendment and Transitional Provision) (EU Exit) Regulations 2019).  

The EU and UK Benchmark Regulations require authorised and registered administrators to comply with certain obligations setout in the regulations, including making available the administrator's governance arrangements index methodology documentation and the index policies to be followed in specified circumstances.  The EU and UK Benchmark Regulations also require the publication of Benchmark Statements for each benchmark or family of benchmarks that summarises the essential features of the benchmark methodology and the administrator’s governance arrangements. Wilshire Indexes benchmark statements for those indexes being made available for use as a benchmark are published below.

The IOSCO Principles for Financial Benchmarks set out the principles administrators should adhere to in order to observe best practice.  Many of the principles were subsequently subsumed by the EU and UK benchmark regulations but for those jurisdictions without a regulatory framework for benchmarks, the IOSCO Principles provide a valuable framework with which to assess an administrator’s adherence to good governance standards. Wilshire Indexes undertakes an annual assessment of its compliance with the IOSCO Principles and the latest report is published here.

The ESMA Guidelines on ETFs and Other UCITS Issues set out the rules that product issuers should adhere to when developing UCITS products.  For index-tracking UCITS products, some of these requirements, particularly those in Sections V and XIII of the guidelines, require information to be supplied from the provider of the index underlying the product.  The "Wilshire Indexes Policy with Respect to the ESMA Guidelines” summarises where the required information can be located in Wilshire Indexes index documentation and on the Wilshire Indexes website.