# 1. Purpose
This Index Governance Policy (the "Policy") sets forth the governance framework pursuant to which Adjacent Markets, Inc. ("Adjacent") administers, maintains, and oversees its prediction market indexes (each, an "Index" and collectively, the "Indexes").
The Policy is designed to promote the integrity, transparency, independence, and reliability of the Indexes and to support confidence among users, licensees, and other stakeholders. Adjacent's Indexes are constructed from event contracts traded on regulated prediction market exchanges, and the governance framework reflects both the rules-based nature of those markets and the regulatory environment in which they operate.

# 2. Scope
This Policy applies to all Indexes published or administered by Adjacent and to all personnel, committees, and agents involved in the design, calculation, maintenance, review, and oversight of such Indexes.

# 3. Governance Structure
Adjacent maintains a formal governance framework centered on a single standing committee, the **Index Committee ("AIC")**, which is responsible for all aspects of index methodology, operations, and oversight. The AIC operates pursuant to a written charter approved by the CEO and COO of Adjacent Markets, Inc.
The AIC's mandate encompasses:
- Design and approval of new Indexes
- Material and non-material methodology changes
- Day-to-day operational management of all live Indexes, including rebalancing, reconstitution, and data sourcing
- Corrections and restatements
- Market classification decisions and exception handling
- Index terminations
- Conflicts of interest oversight
- Compliance with applicable governance and regulatory standards
The composition, responsibilities, and procedures of the AIC are further described in the AIC charter. The AIC charter and related governance documents are available to stakeholders upon request and are updated from time to time to reflect changes in best practices, regulatory expectations, or Adjacent's business.

# 4. Roles and Responsibilities
## AIC
The AIC is the primary governance body for all Index-related decisions. It ensures that Index methodologies are rules-based, transparent, and consistent with Adjacent's research and design principles. The AIC conducts an annual methodology review, initiates stakeholder consultations where appropriate, and is responsible for the integrity and quality of all Index data and calculations.
The AIC reports to the CEO and COO of Adjacent Markets, Inc. Material decisions of the AIC, including new Index launches, material methodology changes, and Index terminations, are documented in meeting minutes and made available to stakeholders upon request.

The CEO and COO of Adjacent Markets, Inc. provides oversight of the AIC, approves this Policy and any amendments, and serves as the escalation point for complaints, conflicts of interest determinations, and information barrier matters.
Day-to-day Index operations may be delegated to qualified staff, subject to AIC oversight.

# 5. Independence and Conflicts of Interest
Adjacent seeks to maintain the independence of its Index governance function. AIC members and relevant personnel are required to identify, disclose, and manage actual or potential conflicts of interest in accordance with Adjacent's Conflicts of Interest Policy and Information Barrier Policy.
Conflicts of interest are recorded and reported to the CEO and COO. Where an AIC member has a material conflict with respect to a specific matter, that member shall recuse themselves from participating in any decision relating to that matter.
Given that Adjacent's Indexes are composed of event contracts that are themselves actively traded instruments, Adjacent places particular emphasis on the separation between Index governance decisions and any commercial or trading activities. This separation is further governed by the Information Barrier Policy.

# 6. Transparency and Disclosure
Adjacent makes publicly available sufficient information regarding each Index to enable users to understand the objectives, construction, and maintenance of the Index, subject to the protection of proprietary information. Specifically:
- Each Index's methodology is documented and publicly available.
- Material methodology changes, Index terminations, and rebalancing results are communicated to stakeholders in advance in accordance with the Index Methodology Change Policy, the Index Termination Policy, and the applicable Index methodology documentation, respectively.
- Governance policies and the AIC charter are available to stakeholders upon request.
Detailed disclosure and announcement procedures are set forth in the applicable Index methodology documentation and the policies referenced herein.

# 7. IOSCO Compliance
Adjacent's governance framework is designed to be consistent with the Principles for Financial Benchmarks published by the International Organization of Securities Commissions ("IOSCO"). Adjacent periodically reviews its compliance with applicable IOSCO Principles and takes appropriate steps to align its practices with applicable industry standards.

# 8. Regulatory Considerations
Adjacent's Indexes are composed of event contracts traded on exchanges regulated by the Commodity Futures Trading Commission ("CFTC"). Adjacent's governance framework is designed with awareness of the regulatory environment applicable to prediction markets, including rules and guidance relating to market integrity, conflicts of interest, and the use of non-public information. Adjacent cooperates with regulatory inquiries as appropriate and maintains records in a manner consistent with applicable regulatory requirements.

# 9. Review and Oversight
This Policy is reviewed at least annually by the AIC and the CEO and COO and updated as necessary to reflect changes in best practices, regulatory expectations, or Adjacent's business. Any material amendments to this Policy are approved by the CEO and COO of Adjacent Markets, Inc.

# 10. Recordkeeping
Adjacent maintains records of AIC meetings, decisions, and supporting materials in accordance with its record retention policies. Minutes of each AIC meeting are retained and made available upon request.

# 11. Contact
Questions or correspondence regarding this Policy may be directed to:
Adjacent Markets, Inc.
governance@adjacentresearch.xyz