- Code of Conduct
- 1. Overview / Employee Relations
- 2. Ethical Business Practices
- 3. Confidentiality
- 4. Conflicts of Interest
- 5. Corporate Opportunities
- 6. Privacy, Security and Standards of Use of Company Equipment
- 7. Insider Trading / Market Abuse
- 8. Fair Dealing
- 9. Antitrust and Competition
- 10. Government Investigations and Civil Litigation
- 11. Bribery of Government Officials
- 12. Environment, Health and Safety
- 13. Political Activities
- 14. Other Laws
- 15. Code Administration
- 1. Quality and Integrity of the Rating Process
- Quality of the Rating Process
- Monitoring and Updating
- Integrity of the Rating Process
- 2. Independence and Management of Conflicts of Interest
- General
- Procedures and Policies
- Analyst and Employee Independence
- 3. Responsibilities to Investors and Issuers
- Transparency and Timeliness of Ratings Disclosure
- Treatment of Confidential Information
- 4. Enforcement and Disclosure of the Code of Professional Conduct and Communication with Market Participants
