The Jacobsen Submitter Code of Conduct

Any member of The Jacobsen in good standing can submit trade data and market information to a member of The Jacobsen PRA staff. Data submission must be done through email, chat, telephone calls or a face-to-face encounter from an approved data submitter.  The data submitter must be involved in the buying, selling or facilitation of the trade of a physical commodity reported within The Jacobsen and the counterparty to said trade will be contacted to verify the details of the reported data. Sales, procurement and marketing managers for companies are permitted to submit aggregated data and market information to The Jacobsen in lieu of individual traders. These trades must also be verified with counterparties and must be arms-length transactions. The Jacobsen will accept trade data deliveries through an API as well.

Your role as a Market Data Submitter

Submitters have the responsibility of maintaining necessary oversight, instruction and review to ensure the integrity of data submitted to The Jacobsen. In accordance with IOSCO principle 14, the market data submitters are required to confirm their adherence to the Submitter Code of Conduct on an annual basis and after any changes to the Code of Conduct have been implemented.

Market Data Submitters are required to submit data that is representative of their market activity on a whole. Trade reports must be current with the report data, i.e. market data submitted within the appropriate time frame in accordance with the specific rules for the product reported on.


By submitting information to The Jacobsen you are agreeing to comply with The Jacobsen’s Submitter Code of Conduct. You are also acknowledging that you have adequate oversight within your organization to prohibit the reporting of false data which includes procedures to identify suspicious activity, which may include conflicts of interests. Additionally, you are agreeing to report data that are indicative of the economic reality of the market, e.g. trades that are representative of the whole of your trading activity and limit trading reporting to arms-lengths transactions outside of any corporate affiliation.

Violations of the Submitter Code of Conduct can result in the loss of reporting privileges.

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