# 1. Purpose
Adjacent Markets, Inc. ("Adjacent") operates as a prediction market index administrator and is committed to ensuring that Non-Public Index Information, including pending methodology changes, pre-announcement constituent decisions, and rebalancing data, is not accessed, used, or disclosed in a manner that could compromise index integrity, create unfair informational advantages, or give rise to market abuse.
This Information Barrier Policy (the "Policy") establishes the controls by which Adjacent manages the flow of Non-Public Index Information among its personnel and external parties. It is adopted in furtherance of the IOSCO Principles for Financial Benchmarks (July 2013), in particular Principles 4, 5, and 12.

# 2. Scope
This Policy applies to all Covered Persons, including:
- **AIC Members: **members of the Index Committee
- **Adjacent Personnel: **all employees and contractors of Adjacent Markets, Inc.
- **Third-Party Vendors and Advisors: **any external party granted access to Non-Public Index Information in connection with services provided to Adjacent

# 3. Definitions
- **"Non-Public Index Information" (NPII) **means any information relating to an Index that has not been publicly disclosed, including: (a) pending methodology changes under active AIC consideration; (b) constituent additions, deletions, or weight changes not yet announced; (c) rebalancing decisions prior to public announcement; (d) calculation errors under investigation; (e) regulatory inquiries or complaints; and (f) client-specific licensing terms.
- **"Restricted Period" **means the period commencing when the AIC first takes formal action on a pending index decision and ending on the date of public announcement.
- **"Barrier Log" **means the record maintained by the CEO and COO documenting authorized information flows and barrier-related incidents.

# 4. Core Principles
Adjacent's information barrier framework is organized around three core principles:
1. **Index governance decisions are confidential until announced. **Pending methodology changes, rebalancing decisions, and constituent changes are confidential from the moment the AIC begins deliberating. This information is not shared outside of those with a direct operational need to know it.
2. **Commercial functions are separated from governance. **No person whose primary role involves licensing, sales, or commercial negotiations may be informed of pending index decisions prior to public announcement. If a commercial question requires input touching on a pending decision, it is routed through the CEO and COO.
3. **Non-public index information may not be used to trade. **No Covered Person may trade in any event contract or related instrument on the basis of Non-Public Index Information. This applies during any Restricted Period and for 48 hours following public announcement.

# 5. Confidentiality Obligations
All Covered Persons with access to Non-Public Index Information are required to:
- Hold NPII in strict confidence and not disclose it to any person without a direct operational need to know it
- Use NPII solely for the purpose of performing their defined role at Adjacent
- Not use NPII, directly or indirectly, to inform any trading decision
- Promptly notify the CEO and COO if they become aware of any actual or suspected unauthorized disclosure or misuse of NPII
Before sharing NPII with any third-party service provider, consultant, or legal advisor, the CEO and COO must ensure a written confidentiality agreement is in place covering the specific information and restricting its use to the relevant engagement.

# 6. Personal Trading Restrictions
No Covered Person may trade, or cause or encourage another person to trade, in any event contract, financial product, or derivative instrument on the basis of Non-Public Index Information, regardless of whether profit is anticipated and regardless of whether the trade is in the Covered Person's own account or any account they influence.
This prohibition applies throughout any Restricted Period and for 48 hours following public announcement of the relevant index decision.
During a Restricted Period, any Covered Person wishing to trade in any instrument that is or could be affected by the pending decision must obtain CEO and COO pre-clearance before executing the trade. The CEO and COO may deny a request without explanation.
This Policy does not supersede any personal trading restrictions under applicable securities laws, CFTC rules, or fiduciary duties. Where a stricter obligation applies, the stricter obligation governs.

# 7. Breach Reporting and Response
Any Covered Person aware of an actual or suspected breach, including unauthorized NPII disclosure, suspected misuse, or a trading violation, must report to the CEO and COO within one (1) business day. Adjacent will not retaliate against good-faith reporters.
Upon receipt of a breach report, the CEO and COO will:
- Record the incident in the Barrier Log
- Investigate the nature and scope of the breach
- Implement appropriate containment measures
- Escalate to the AIC if the breach may have affected Index integrity or involved trading on NPII
- Consult with legal counsel if the breach may constitute a violation of applicable CFTC rules or other law

# 8. Barrier Log
The CEO and COO maintains a Barrier Log recording:
- Any instance where NPII is shared with an external party, including the recipient, the information shared, and the basis for sharing
- Any Restricted Period, including start and end dates and subject matter
- Any breach reports and their resolution
The Barrier Log is retained for a minimum of five (5) years and is made available to regulatory authorities upon request.

# 9. Training
All Covered Persons must acknowledge this Policy upon joining Adjacent and annually thereafter. Acknowledgment is documented by the CEO and COO.

# 10. Review and Amendment
The CEO and COO reviews this Policy at least annually. Amendments require written CEO and COO approval and must be communicated to all Covered Persons within fifteen (15) business days of adoption.

# 11. Governing Law
This Policy is governed by the laws of the State of Delaware. Where this Policy conflicts with another Adjacent policy, the more stringent obligation controls.

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