Compliance

Each Participant will have a compliance program commensurate with the size and scope of its trading activities on the Exchange and designed to ensure appropriate, timely and ongoing review of trading practices and compliance with the Rules.

Participants and Clearing Members will act in accordance with these practices for compliance and monitoring with regard to its Exchange and Clearinghouse activity:

1. Provide for proper training of personnel on the provisions of the Rules.

2. Maintain internal policies and procedures to promote compliance with the Rules.

3. Promptly disclose to the Exchange the details of any violations of the Rules involving Participant's activities on the Exchange or provision of market information to the Exchange or any of its Affiliates.

4. Provide an environment that encourages employees within the Participant's or Clearing Member's organization to engage in safe and confidential discussions and to disclose to senior management any trading practices that might violate the Rules.

5. Require any consultant, contractor and/or subcontractor to disclose all financial affiliations and conflict of interests with Participants, Clearing Members, the Exchange, the Clearinghouse and its affiliates. Ensure that consultants, contractors or subcontractors do not cause any disclosure of information in violation of any Rule and that confidentiality agreements are in effect where appropriate.

6. Establish clear lines of accountability for the Participant's or Clearing Member's trading practices, including provisions relating to the responsibilities of corporate officers, with appropriate oversight by the Participant's or Clearing Member's board of directors or other senior corporate management committee.