Reporting lines for Moody’s Employees and their compensation arrangements will be organized to eliminate      or effectively manage actual and potential conflicts of interest. Analysts will not be compensated or      evaluated on the basis of the amount of revenue that Moody’s derives from Issuers that the Analyst rates      or with which the Analyst regularly interacts.

Moody's will not have Analysts without Management responsibilities who are directly involved in the      rating process for an Issuer initiate, or participate in, discussions regarding fees or payments with such      Issuer.

In accordance with Moody’s Core Principles for the Conduct of Rating Committees, no Moody’s Employee      will participate in or otherwise influence the determination of the Credit Rating of any particular entity or      obligation if the Employee:

In accordance with Moody’s internal securities trading policies, Moody’s Employees who are involved in the      rating process (or their spouse, partner or minor children) are prohibited from buying, selling or engaging in      any transaction in any Security or Derivative of any Security issued, guaranteed, or otherwise supported      by any entity within such Employee’s area of primary analytical responsibility.

Moody’s Employees are prohibited from soliciting money, gifts or favors from anyone with whom Moody’s      does business and are prohibited from accepting gifts or favors from such persons or entities other than      those expressly sanctioned by the MCO Code of Business Conduct.

Any Moody’s Analyst or Manager who becomes involved in any personal relationship that creates the      potential for any real or apparent conflict of interest (including, for example, any personal relationship with      an employee of a rated entity or agent of such entity within his or her area of analytic responsibility) will      be required, subject to applicable law, to disclose such relationship to either their immediate supervisor,      their department head, or a member of the Human Resources or Legal Department. Based on the      assessment of this information, Moody’s will take appropriate steps to mitigate the real or apparent      conflict.