Last Reviewed On: December 30, 2016 (Version 1.0)

1. Acuité has operationally separated its credit rating analytical team from any other businesses of Acuité that present a conflict of interest
2. Acuité discloses the general nature of its compensation arrangements with the rated entities.
3. When Acuité receives compensation from a rated entity unrelated to its credit rating services, Acuité would disclose such unrelated compensation as a percentage of total annual compensation received from such rated entity.
4. Acuité would make a disclosure if it receives 10 percent or more of its annual revenue from a single rated entity.
5. Acuité would not trade in instruments presenting a conflict of interest with Acuité credit rating of the concerned entity, if rated by Acuité.
6. Acuité's employee who participates in a credit rating action with respect to an entity would not be compensated or evaluated on the basis of the amount of revenue that Acuité would derive from that entity.
7. Acuité's employees who participate in a credit rating action would not participate in discussions with rated entities regarding fees or payments charged to such rated entity.
8. Acuité may review, where the compliance officer finds it so necessary, the past work of an analyst who leaves the employment of Acuité and joins an entity that the employee has participated in the rating exercise.
9. This policy is complementary to the gift policy and the policy for dealing with conflict of interest for trading and investment, which is currently in force and/or that may be adopted by Acuité from time to time.