Moody's will publicly disclose via press release and posting on moodys.com any material modifications to      its rating methodologies and related significant practices, procedures, and processes. Where feasible and      appropriate, disclosure of such material modifications will be made subject to a “request for comment” from      market participants prior to their implementation. Moody’s will carefully consider the various uses of Credit      Ratings before modifying its rating methodologies, practices, procedures and processes.

As a publisher of credit research related to its Credit Ratings, Moody’s will seek to provide clear, accurate,      transparent and high quality research about rated Issuers, debt or debt-like obligations. Research sales      shall be separated from the research and rating process in ways that help protect the latter activities from      improper conflicts of interest. As provided elsewhere in this section, non-public information about Moody’s      future rating actions may not be selectively disclosed to research subscribers or others.

Moody’s and its Employees will:

Moody's will use Confidential Information only for purposes related to its rating activities.

Moody's Employees will take all reasonable measures to protect all property and records belonging to or      in possession of Moody’s from fraud, theft or misuse.

In accordance with Moody’s internal securities trading policies, Moody's Employees will be prohibited from      engaging in transactions in Securities and Derivatives when they possess Confidential Information      concerning the Issuer of such Securities.

Moody's Employees will familiarize themselves with Moody’s internal securities trading policies, and      periodically certify their compliance as required by such policies.

Moody's Employees will not disclose any non-public information about rating opinions or possible future      rating actions of Moody’s, except to the Issuer or its designated agents.

Moody's Employees will not share Confidential Information entrusted to Moody’s with employees of any      affiliated entities except to the extent such employees are acting as agents of Moody’s with respect to the      rating process, and are bound by appropriate confidentiality obligations. Moody’s Employees will not share      Confidential Information within Moody’s except on a “reason-to-know” basis.

Moody's Employees will not use or share Confidential Information for the purpose of trading securities, or      for any other purpose except as described in Provision 3.16 of this Code: