Best Practices for Energy Price Indices © Copyright 2003, CCRO. All rights reserved. 9 the index developer for each index or group of indices in consultation with data providers and index users. 3.2.1 Submit Data Through a Department Independent from Front Office Data providers should use a department that is independent of the front office (e.g., corporate risk control, middle office or back office) to verify the accuracy and completeness of the data and submit it to index developers. Data providers should confirm to the index developers that all such data is being provided by a department independent of the front office and that the data comprises actual transactions undertaken by the reporting entity. 3.2.2 Adhere to EPSA Code of Ethics for Other Employees Only the designated noncommercial group should provide index developers with transaction data for use in developing an index. However, other employees of the data provider may communicate to index developers their views of market conditions and events, provided that they adhere to the Electric Power Supply Association (EPSA) Code of Ethics when doing so. 3.2.3 Error Resolution, Error Revision, and Challenge Processes The data providers should adhere to the error resolution, error revision, and challenge processes and timelines as defined and published by the index developers. In particular, data providers should make reasonable efforts to review the transaction data prior to submission, to be available for index developers queries prior to publication, to notify index developers of errors as consistent with the materiality standard defined by each developer, and to challenge the index only when such challenges are warranted. 3.2.4 Submit Data in Flat Files, Excel Spreadsheet, or –Exceptionally – by Facsimile Transmission Data should be submitted to the index developer electronically, but submission via facsimile is acceptable when otherwise unavoidable. Electronic data should be submitted in a flat file format. Some index developers may accept Excel or XML formats. Each row should contain all data pertaining to one transaction, and each column should contain a single type of data element. These elements should include price, volume, electronic trading exchange used for the trade, and other appropriate product specific elements. If no transactions are executed during the transaction-reporting interval, a flat file containing the statement “intentionally blank” should be submitted to the index developer. This positive confirmation will reduce confusion and delay. 3.2.5 Maintain Records Data providers and index developers should maintain their own records for audit purposes. These records should be maintained as required by each entity’s record retention policy and by the requirements for the index (indices) in question. Companies should also review and consider all applicable state and federal recordkeeping requirements when developing or updating a retention policy.