Last Reviewed On: March 04, 2023 (Version 3.0)

1. The objective of this policy is to protect confidential and/or material non-public information, including confidential information received from an entity rated/proposed to be rated and non-public information about a credit rating action (e.g., information about a credit rating action before the credit rating is publicly disclosed or disseminated to public).
2. Acuité and its access persons and employees are prohibited from using or disclosing confidential and/or material non-public information for any purpose unrelated to Acuité’s credit rating activities, including disclosing such information to other access persons or employees where the disclosure is not necessary in connection with Acuité’s credit rating activities.
3. Acuité and its access persons and employees shall take reasonable steps to protect confidential and/or material non-public information from fraud, theft, misuse, or inadvertent disclosure.
4. With respect to confidential information received from a rated entity, Acuité and its access persons and employees are prohibited from using or disclosing such information in violation of the terms of any applicable agreement or mutual understanding that Acuité will keep the information confidential.
5. Acuité and its access persons and employees are prohibited from selectively disclosing information about an unpublished credit rating action, except to the rated entity.
6. Acuité prohibits its access persons and employees who possess confidential and/or material non-public information to disclose such information to anyone other than a Acuité access person or employee involved in the rating process strictly on a need-to-know basis. Acuité access persons or employees are not allowed to use such information for personal gain.
7. Notwithstanding the above, Acuité and its access persons and employees reserve the right to disclose confidential/material non-public information, in their possession, to the Regulatory / Statutory authorities such as Securities and Exchange Board of India (SEBI), Reserve Bank of India (RBI) / Government, including, but not limited to, a Court of Law, when required to do so under any applicable law or regulation.
8. This policy is complementary to the Analytic Firewall Rules, Document Archival policy and the clear desk and clear screen policy currently in force and / or that may be adopted by Acuité from time to time.
9. This policy is location agnostic and applicable to access persons and employees whether working from office or remotely (such as working from home).
10. This policy is complementary to "Policy on Outsourcing of Activities”