CRISIL’S ANALYTIC
FIREWALLS POLICY
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T ABLE OF C ONTENTS
CRISIL’s Analytic Firewalls Policy ... 3
1. Analytic Firewalls Policy...
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2. Protection of Confidential Information Held by Ratings Services ...
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3. Application of Analytic Firewalls Policy with Other Policies and Procedures... 4
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CRISIL’s Analytic Firewalls Policy
CRISIL Limited’s (CRISIL’s) Analytic Firewalls Policy is intended to (i) ensure that Ratings Analysts and Research/Advisory Analysts have the freedom to express their respective opinions free from the improper influence of other CRISIL employees and free from the influence of the commercial relationships between CRISIL and third parties and (ii) protect the confidentiality of information given to Ratings analysts in connection with the rating process.
1. Analytic Firewalls Policy:
a) CRISIL’s Ratings Analysts and Research/Advisory Analysts must reach their analytic opinions independently of each other. CRISIL’s Ratings Analysts may not share any confidential information they receive in connection with the rating process with any CRISIL Research/Advisory Analyst.
b) CRISIL’s Ratings and Research/Advisory Analysts shall arrive at their respective opinions by strictly following CRISIL’s internal processes and shall not be influenced by any commercial relationship between CRISIL and any third party.
c) No employee of CRISIL shall attempt to exert improper influence on the opinions of a Ratings Analyst or a Research/Advisory Analyst. In no circumstances shall an employee of CRISIL try to influence the opinion of a Ratings Analyst or a Research/Advisory Analyst by referring to the commercial relationship between CRISIL and any third party.
d) Ratings Analysts will not participate in consulting or advisory services.
e) Research Analysts may participate in consulting or advisory services as long as their activity is limited to stating and reporting on their published Research opinions.
f) Ratings Analysts will not be involved with the process of rating fee negotiation.
g) Ratings employees involved in rating fee negotiations for an issue or issuer will not be involved in the rating process and hence cannot vote in a credit ratings committee.
h) Ratings Analysts may not discuss the deliberations relating to, or confidential information used in determining, individual credit rating opinions with any Research/Advisory Analyst or any other CRISIL employee, except as permitted by the CRISIL Ratings Code of Conduct.
i) Ratings Originators may only sell credit ratings and ancillary ratings products and services that do not necessarily conflict with the ratings business (“ancillary ratings products and services”). CRISIL’s credit ratings products and services may not be crosssold with advisory or consulting services.
j) CRISIL’s Ratings employees will not jointly sell or call on ratings customers with employees in advisory or consulting. The foregoing does not preclude CRISIL’s personnel from participating in internal general business discussions related to operational or strategic matters of CRISIL, including new product development initiatives.
2. Protection of Confidential Information Held by Ratings Services
a) The confidentiality of all nonpublic information provided as part of the ratings process by an issuer or other third party must be safeguarded.
b) Information about a ratings action or potential ratings action is confidential, and may not be shared with anyone other than (i) Ratings employees who have a legitimate business need to know the information, and (ii) the issuer and persons acting on behalf of the issuer, until such time as such rating action or
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potential rating action is made public. CRISIL Ratings’ policies relating to confidential information are more fully set forth in CRISIL Ratings Code of Conduct.
3. Application of Analytic Firewalls Policy with Other Policies and Procedures
The Analytic Firewalls Policy is intended to be complementary to all other policies and procedures adopted by CRISIL. CRISIL’s personnel who have questions on interpretation or application of this policy should contact their director or CRISIL’s Compliance Department who will coordinate on the appropriate response. Any exceptions to this policy must be given by the Managing Director and CEO of CRISIL and must be formally documented.
In order to disclose this Policy to the public, this policy is available without charge to the public on CRISIL’s public website, www.crisil.com.However, by making this Policy available to the public, CRISIL does not assume any responsibility or liability to any third party arising out of or relating to this Policy. This Policy shall not form a part of any contract with any third party and no third party shall have any right (contractual or otherwise) to enforce any of this Policy's provisions, either directly or indirectly. CRISIL in its sole discretion may revise this Policy to reflect changes in market, legal and regulatory circumstances and changes to CRISIL's controls, policies and procedures.
Updated: 2013
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CRISIL is a global, agile and innovative analytics company driven by its mission of making markets function better. We are India’s foremost provider of ratings, data, research, analytics and solutions. A strong track record of growth, culture of innovation and global footprint sets us apart. We have delivered independent opinions, actionable insights, and efficient solutions to over 100,000 customers.
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