Last Reviewed On: September 24, 2020 (Version 2.0)

1. Acuite has operationally separated its credit rating analytical team from any other businesses of Acuite that may present a conflict of interest.
2. Acuite discloses the general nature of its compensation arrangements with the rated entities.
3. When Acuite receives compensation from a rated entity unrelated to its credit rating services, Acuite would disclose such unrelated compensation as a percentage of total annual compensation received from such rated entity.
4. Acuite would make a disclosure if it receives 10 percent or more of its annual revenue from a single rated entity.
5. Acuite would not trade in instruments presenting a conflict of interest with Acuite’s credit rating of the concerned entity, if rated by Acuite.
6. Acuite's access person(s) and/or employee(s) 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 Acuite would derive from that entity.
7. Acuite's access person(s) and/or employee(s) 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. Acuite may review, where the compliance officer finds it so necessary, the past work of an analyst who leaves the employment of Acuite and joins an entity (if Acuite comes to know of its former employee taking up such an employment) where Acuite has an outstanding rating and the concerned analyst had participated in the rating exercise of that entity.
9. This policy is complementary to the gift policy, and policy for dealing with conflict of interest for trading and investment, which are currently in force and/or that may be adopted by Acuite from time to time.
10. The access person(s) and/or employee(s) has the onus to make reasonable efforts to inform and disclose to Acuite at the earliest of situation(s) and/or circumstances that may potentially or actually cause or be perceived to cause a conflict of interest in the discharge of his/her duties and obligations.