As a credit rating agency, Acuité Ratings & Research Limited. (Acuité) is committed to observe highest standards of integrity and fairness in all its dealings. Acuité's mission is to provide high quality, objective, independent, impartial, professional and rigorous analytical information to the marketplace. Acuité is committed to continuously reviewing and monitoring its policies and procedures in light of the contemporary developments. This Code will be available to public without charge on Acuité's website at www.acuite.in However, Acuité does not assume any responsibility or liability to any third party arising out of or relating to this Code.

This Code shall not form a part of any contract with any third party and no third party shall have any right (contractual or otherwise) to enforce any of this Code's provisions, either directly or indirectly. Acuité in its sole discretion may revise this Code to reflect changes in market, legal and regulatory circumstances and/or changes in Acuité's policies and procedures.

Acuité requires all its employees to comply with this Code and the related policies and procedures. The CEO of Acuité shall be responsible for interpretation of this Code and the related policies and procedures. Failure to comply with this Code and the related policies and procedures shall be sufficient reason for disciplinary action, including dismissal from service and possible legal action.

In the conduct of its business, Acuité and/ or its employees shall:

• make all efforts to protect the interests of investors.
• observe high standards of integrity, dignity and fairness in the conduct of its business.
• fulfill its obligations in a prompt, ethical and professional manner.
• at all times exercise due diligence, ensure proper care and exercise independent professional judgment in order to achieve and maintain objectivity and independence in the rating process.
• have a reasonable and adequate basis for performing rating evaluations, with the support of appropriate and in depth rating researches and maintain records to support its decisions.
• have in place a rating process that reflects consistent and international rating standards.
• not indulge in any unfair competition nor shall it wean away the clients of any other rating agency on assurance of a higher rating.
• keep track of all important changes relating to the client companies and develop efficient and responsive systems to yield timely and objective ratings.
• monitor closely all relevant factors that might affect the credit worthiness of the issuers.
• disclose its rating methodology to clients, users and the public.
• wherever necessary, disclose to the clients, possible sources of conflict of duties and interests, which could impair its ability to make fair, objective and unbiased ratings.
• ensure that no conflict of interest exists between any member of its rating committee participating in the rating analysis, and that of its client.
• not make any exaggerated statement, whether oral or written, to the client either about its qualification or its capability to render certain services or its achievements with regard to the services rendered to other clients.
• not make any untrue statement, suppress any material fact or make any misrepresentation in any documents, reports, papers or information furnished to the Securities and Exchange Board of India ("Board"), stock exchange or public at large.
• ensure that the Board is promptly informed about any action, legal proceedings etc., initiated against it alleging any material breach or non-compliance by it, of any law, rules, regulations and directions of the Board or of any other regulatory body.
• maintain an appropriate level of knowledge and competence and abide by the provisions of the Securities and Exchange Board of India (Credit Rating Agencies) Regulations, 1999 ("Act"), regulations and circulars, which may be applicable and relevant to the activities carried on by the credit rating agency.
• comply with award of the Ombudsman passed under the Securities and Exchange Board of India (Ombudsman) Regulations, 2003.
• ensure that there is no misuse of any privileged information including prior knowledge of rating decisions or changes.
• not render, directly or indirectly any investment advice about any security in the publicly accessible media.
• not offer fee-based services to the rated entities, beyond credit ratings and research.
• ensure that any change in registration status/ any penal action taken by Board or any material change in financials which may adversely affect the interests of clients/investors is promptly informed to the clients and any business remaining outstanding is transferred to another registered person in accordance with any instructions of the affected clients/investors.
• maintain an arm's length relationship between its credit rating activity and any other activity.
• develop its own internal code of conduct for governing its internal operations and laying down its standards of appropriate conduct for its employees and officers in the carrying out of their duties within the credit rating agency and as a part of the industry. Such a code may extend to the maintenance of professional excellence and standards, integrity, confidentiality, objectivity, avoidance of conflict of interests, disclosure of shareholdings and interests, etc. Such a code shall also provide for procedures and guidelines in relation to the establishment and conduct of rating committees and duties of the officers and employees serving on such committees.
• provide adequate freedom and powers to its compliance officer for the effective discharge of his duties.
• ensure that the senior management, particularly decision makers have access to all relevant information about the business on a timely basis.
• ensure that good corporate policies and corporate governance are in place.
• not, generally and particularly in respect of issue of securities rated by it, be party to or instrumental for:
  (a) creation of false market;
  (b) price rigging or manipulation; or
  (c) dissemination of any unpublished price sensitive information in respect of securities which are listed and proposed to be listed in any stock exchange, unless required, as part of rationale for the rating accorded.