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B. Monitoring and Updating |
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Except for Credit Ratings that clearly indicate they do not entail
ongoing surveillance, once a Credit Rating is published,
Moody's will monitor the Credit Rating on an ongoing
basis and update it by: |
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A) Periodically reviewing the creditworthiness of the
Issuer or other relevant entity; |
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B) Initiating a review of the
status of the Credit Rating upon becoming aware of any information
that might reasonably be expected to result in a Credit Rating
action (including termination of a Credit Rating), consistent with
the applicable rating methodology; and |
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C) Updating on a timely basis the rating, as
appropriate, based on the results of such review. |
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In accordance with
Moody's published Rating Withdrawal Policy Moody’s will
announce via press release if it discontinues a public Credit Rating on an Issuer or
obligation. |
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C. Integrity of the Rating Process |
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Moody's and its Employees will comply with all applicable
laws and regulations governing their activities in the jurisdictions
in which Moody’s operates. |
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Moody's and its Employees will deal fairly and honestly
with Issuers, investors, other market participants, and the public. |
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Moody's will hold its Employees to high standards of
integrity. Moody’s will not knowingly employ any individuals
with demonstrably compromised integrity. |
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Moody's and its Analysts will not, either implicitly or
explicitly, give any assurance or guarantee of a particular Credit
Rating prior to a rating committee. This does not preclude Moody’s
from developing provisional assessments used in structured
financings or similar transactions. |
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The Office of Compliance will be responsible for assessing adherence to the various
procedural provisions of this Code. The reporting line of the Office of Compliance
will be independent of Moody’s rating operations and the compensation of
individuals in this function will be determined by individuals without Credit Ratings
operation responsibilities at
Moody's. |
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While Employees are not expected to be experts in the law, they are expected to
report activities of which they are aware that a reasonable person would question
as a potential violation of the law or this Code. Any Moody’s Manager or officer
who receives such a report from an Employee is obligated to report it promptly to
the Legal Department or the Office of Compliance, which will take appropriate
action, as determined by the laws and regulations of the jurisdiction and the rules
and guidelines set forth by
Moody's. Employees may also report any such matters
on a confidential or anonymous basis by calling Moody’s anonymous hotline. |
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Moody's management will prohibit retaliation by any
Moody’s Employee or by Moody’s itself against any Employee who, in
good faith, reports a possible violation of the law or this Code. |
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