Moody's Management will be responsible for the implementation and the enforcement of the Moody’s      Code. The Office of Compliance will annually review and assess the efficacy of such implementation and      enforcement.

The provisions of this Code are derived from the IOSCO Principles and the IOSCO Code. However,      Moody's made certain modifications to more closely correspond with Moody’s business mode and      practices. Such modifications will be specifically identified and explained in a report that Moody’s will publish      annually outlining compliance with the Moody’s Code and explaining any deviations that may exist between      the Moody’s Code and the IOSCO Code.

With respect to the subjective standards that are incorporated in this Code, Moody’s will use its good faith      efforts in implementing such standards.

This Code, and any modifications made to it going forward, will be made public and readily accessible via      moodys.com.

Moody's Communications Department is charged with communicating with market participants and the      public about any questions, concerns or complaints that Moody’s may receive about Moody’s adherence      with the Code. The objective of this function is to help ensure that Moody’s officers and its Management      have adequate market intelligence when setting Moody’s policies.