Last Reviewed On: May 08, 2023 (Version 4.0)

1. Acuité Ratings & Research Limited has operationally separated its credit rating analytical team from any other businesses of Acuité Ratings & Research Limited that may present a conflict of interest.
2. Acuité Ratings & Research Limited discloses the general nature of its compensation arrangements with the rated entities.
3. When Acuité Ratings & Research Limited receives compensation from a rated entity unrelated to its credit rating services, Acuité Ratings & Research Limited would disclose such unrelated compensation as a percentage of total annual compensation received from such rated entity.
4. Acuité Ratings & Research Limited would make a disclosure if it receives 10 percent or more of its annual revenue from a single rated entity.
5. Acuité Ratings & Research Limited would not trade in instruments presenting a conflict of interest with Acuité Ratings & Research Limited’s credit rating of the concerned entity, if rated by Acuité Ratings & Research Limited.
6. Acuité Ratings & Research Limited'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 Acuité Ratings & Research Limited would derive from that entity..
7. Acuité Ratings & Research Limited'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. Acuité Ratings & Research Limited may review, where the compliance officer finds it so necessary, the past work of an analyst who leaves the employment of Acuité Ratings & Research Limited and joins an entity (if Acuité Ratings & Research Limited comes to know of its former employee taking up such an employment) where Acuité Ratings & Research Limited 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, policy for dealing with conflict of interest for trading and investment, and rules for Acuite’s analytic firewalls which are currently in force and/or that may be adopted by Acuité Ratings & Research Limited from time to time. .
10. Acuité Ratings & Research Limited and its employees do not engage in providing rating advisory services and/or help the issuer(s) in structuring / syndicating the debt programme or loan facility(s) with or without fee.
11. The access person(s) and/or employee(s) has the responsibility to make reasonable efforts to inform and disclose to Acuité Ratings & Research Limited 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.