NON-MEMBER:

MAREX SPECTRON INTERNATIONAL LIMITED

EXCHANGE RULES: EXCHANGE RULE 526. BLOCK TRADES

The Exchange shall designate the products in which block trades shall be permitted and determine the minimum quantity thresholds for such transactions. The following shall govern block trades:

F. The seller must ensure that each block trade is reported to the Exchange within five minutes of the time of execution. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.

LEGACY EXCHANGE RULE 538 EXCHANGE FOR RELATED POSITIONS

G. Identification and Submission to the Clearing House

Each EFRP transaction shall be designated as such and shall be cleared through the Clearing House. Each such transaction shall be submitted to the Clearing House within the time period and in the manner specified by the Exchange. Clearing member firms are responsible for exercising due diligence as to the bona fide nature of EFRP transactions submitted on behalf of customers.

FINDINGS:

Pursuant to an offer of settlement that Marex Spectron International Limited (“MSIL”) (formerly known as Spectron Energy Services Limited and Spectron Commodities Futures, Inc.), presented at a hearing on February 18, 2015, in which MSIL neither admitted nor denied the factual allegations or rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that MSIL was subject to the jurisdiction of the BCC pursuant to Exchanges Rules 400 and 402 as an affiliate of a NYMEX member, and that for the time period of January 2012 through July 2012 and May 2014, MSIL executed block trades for customers that were not reported to the Exchange within the applicable time limit following execution and also misreported Exchange for Swap (“EFS”) transactions as block trades to the Exchange.

The Panel concluded that MSIL violated Exchange Rules 526.F. (“Block Trades”) and Legacy Rule 538.G (“Exchange for Related Positions”).

PENALTY:

In accordance with the settlement offer, the Panel ordered MSIL to pay a fine to the Exchange in the amount of $25,000.