Moody's will not forbear or refrain from taking a Credit Rating action based on the potential effect      (economic, political, or otherwise) of the action on Moody’s, an Issuer, an investor, or other market      participant.

Moody's and its Analysts will use care and professional judgment to maintain both the substance and      appearance of independence and objectivity.

The determination of a Credit Rating will be influenced only by factors relevant to the credit assessment.

The Credit Rating Moody’s assigns to an Issuer, debt or debt-like obligation will not be affected by the      existence of, or potential for, a business relationship between Moody's (or its affiliates) and the Issuer      (or its affiliates) or any other party, or the non-existence of any such relationship.

Moody's will separate its Credit Rating business and Analysts from other businesses that may reasonably      present a conflict of interest, as described in Moody’s Policy with Respect to Non-Rating Services.5 Rating      committee members may neither sell nor provide such services to rated Issuers. Moody’s will ensure that      any existing or future ancillary business operations that do not necessarily present conflicts of interest      with the Moody’s Credit Rating business have in place procedures and mechanisms, to minimize the      likelihood that conflicts of interest will arise.

Moody's will adopt written internal procedures and mechanisms to:

Moody's disclosures of known actual and potential conflicts of interest will be complete, timely, clear,      concise, specific and prominent. Such disclosures will be made through moodys.com.

Moody's will disclose the general nature of its compensation arrangements with rated entities, including      whether it receives compensation unrelated to its Credit Ratings and related research.

In accordance with Moody’s internal securities trading policies, Moody’s and its Employees will not engage      in any Securities or Derivatives trading that present conflicts of interest with Moody’s rating activities.

In instances where rated entities (e.g., governments) have, or are simultaneously pursuing, affiliated      oversight functions related to Moody’s, Moody’s will use different Employees to conduct its Credit Rating      evaluations for such rated entities than those Employees involved in its oversight issues.