DRC RATING SERVICES INC.
DRC RATING
CODE OF ETHICAL CONDUCT (CODE OF CONDUCT)
FOREWORD AND LIMITATION OF LIABILITY
DRC RATING states that it will comply with the rules of conduct consistent with the Capital Markets Board (CMB), IOSCO principles and IOSCO codes by publishing these ethical codes of conduct and other documents related to the rating business. All full-time or part-time employees of DRC RATING are required to comply with this code of conduct.
While making this code of conduct publicly available, DRC RATING does not accept any responsibility or liability to third parties regarding or arising from these documents, policies or practices, except as provided by law. These codes of conduct, rating methodologies, policies or practices are not intended to form or form part of a contract, and no natural or legal person may directly or indirectly enforce the application of these provisions. DRC RATING reserves the right to update or change this code of conduct, rating methodologies and policies at any time, without notice.
CONTENTS
1. QUALITY AND INTEGRITY OF THE CREDIT RATING PROCESS
A. Nature of the Credit Rating Process
B. Integrity of the Credit Rating Process
2. DRC RATING's INDEPENDENCE AND AVOIDING CONFLICT OF INTEREST
A. General
B. DRC RATING Policies, Procedures, Controls and Disclosures
C. Independence of DRC RATING Employees
3. OBLIGATIONS OF DRC RATING TO INVESTORS, RELATED INSTITUTIONS, DEBTORS, UNDERWRITERS AND REGULATORS
A. Timing and Transparency of Credit Rating Disclosure
B. Handling of Confidential Information
4. MANAGEMENT, RISK MANAGEMENT AND EMPLOYEE TRAINING
5. COMMUNICATION AND DISCLOSURE WITH MARKET PARTICIPANTS
1. QUALITY AND INTEGRITY OF THE CREDIT RATING PROCESS
A. Nature of the Credit Rating Process
1.1 DRC RATING will establish, maintain, document and implement a credit rating methodology for each class of asset or liability for which it has disclosed a credit rating. Every credit rating methodology will result in a credit rating that is capable of precise, consistent application and, where possible, can be made the subject of objective verification based on some form of historical experience.
1.2 Credit ratings reflect all information known and material to DRC RATING, consistent with the applicable credit rating methodology in effect. Therefore, DRC RATING will establish, maintain, document and implement policies, procedures and controls to ensure that the credit ratings and related reports it publishes are based on a detailed analysis of all information.
1.3 DRC RATING will take reasonable measures designed to ensure it has appropriate knowledge and expertise and to ensure that the information it uses to determine the relevant credit rating is of sufficient quality and is obtained from reliable sources that support a high quality credit rating process.
1.4 DRC RATING will refrain from making credit ratings for entities or liabilities for which it does not have the appropriate data, knowledge and expertise. For example, DRC RATING will refrain from setting a credit rating when the complexity of a security or the nature of the type of security, or the lack of robust data on the underlying assets raise serious questions as to whether DRC RATING can provide a high-quality rating service.
1.5 In determining the credit worthiness, analysts participating in the credit rating action must use the credit rating methodology established by DRC RATING for the type of asset or liability subject to the credit rating process. The credit rating methodology is consistently applied to all institutions or liabilities where this methodology is used.
1.6 DRC RATING defines the meaning of each category in the rating scale and applies these categories consistently to all classes of rated institutions and obligations for which a particular rating scale applies.
1.7 Credit ratings are assigned by DRC RATING as an institution (not by an analyst or other staff of DRC RATING).
1.8 DRC RATING will assign to the rating team individually or collectively (especially when credit rating committees are used), analysts with appropriate knowledge and experience who can determine the creditworthiness of the rated entity or type of liability.
1.9 DRC RATING shall maintain internal records that are complete and sufficiently detailed and comprehensive enough to reconstruct the credit rating process for a credit rating action it determines. Records will be retained for as long as necessary to support the integrity of DRC RATING's credit rating process, including allowing internal audit, compliance and quality control functions to review past credit rating actions so that these functions can fulfill their responsibilities. In addition, DRC RATING will establish and maintain policies, procedures and controls designed to ensure compliance with the requirements of DRC RATING's employees for the protection, retention and disposal of internal records and applicable laws and regulations in the preservation, retention and disposal of DRC RATING's records, document and implement.
1.10 DRC RATING shall establish, document, maintain and enforce policies, procedures and controls designed to prevent the publication of misleading or misleading credit ratings, analyzes or reports regarding the overall creditworthiness of a rated institution or liability.
1.11 DRC RATING will ensure that it has and allocates sufficient resources to conduct and ensure the high quality of the credit rating process. In deciding whether to assign a credit rating to an entity or liability, DRC RATING will evaluate whether it can allocate a sufficient number of analysts with the necessary skill tools and whether analysts have access to sufficient information for high quality credit ratings.
1.12 DRC RATING will establish and maintain a review function consisting of one or more senior executives with appropriate experience to review the validity of a credit rating for institutions or types of obligations that are significantly different from those it currently rated.
1.13 DRC RATING will establish and maintain a review function consisting of one or more senior executives who will be responsible for conducting a regular, rigorous, formal and periodic review of all aspects of credit rating methodologies (including models and key assumptions) and significant changes in credit rating methodologies, within a pre-established schedule. For example, DRC RATING will assess whether current credit rating methodologies and models are appropriate for determining the credit rating of a structured finance product when the risk characteristics of the underlying assets of a structured finance product change significantly. When the credit rating business of DRC RATING is valid, appropriate and sufficient in size and content, this function will be independent of its employees responsible for determining the actual credit rating.
1.14 DRC RATING will try to prevent bias/bias in the credit rating process, while promoting continuity in the selection of the analyst or analysts to be involved in the credit rating process. For example, when seeking to balance continuity with objectives of avoidance of bias/bias, when DRC RATING appoints a team of analysts to determine the credit rating, the rated institution or liability for some of the analysts will fall within their primary analytical responsibility area, while others will have different primary analytical responsibilities.
1.15 DRC RATING will ensure that sufficient staff and financial resources are allocated to monitor and update all credit ratings. Once a credit rating is issued, DRC RATING will continually monitor the credit rating by:
a. Regularly reviewing the credit rating of the institution or liability;
b. Initiate a credit rating review consistent with the credit rating methodology, upon awareness of any information that could reasonably be expected to cause a credit rating action (including rating withdrawal);
c. Applying changes in credit rating methodologies, models or significant rating assumptions to relevant credit ratings within a reasonable period of time and reviewing their impact;
d. Timely updating of the credit rating based on the results of this review, as appropriate;
e. Consolidation of all assessments obtained.
1.16 If DRC RATING uses disparate teams of analysts to determine the initial credit rating and then monitor existing ratings, each team will have the level of expertise and resources necessary to perform its functions in a timely manner.
1.17 DRC RATING shall establish, maintain, document and implement policies and procedures that clearly outline the rules for the announcement of credit ratings and the withdrawal of a credit rating, which are the result or subject of rating actions and related reports.
B. Integrity of the Credit Rating Process
1.18 DRC RATING and its employees will treat rated institutions, borrowers, originators, s, intermediaries and users of credit ratings fairly and honestly.
1.19 The highest standard of integrity and ethical behavior is expected of DRC RATING's employees. DRC RATING will implement policies and procedures designed to ensure that individuals with compromised moral integrity are not employed.
1.20 DRC RATING and its employees do not provide any assurance, express or implied, about the outcome of a particular credit rating action, to parties to the credit rating action, to borrowers, to resource agencies, to s, to intermediaries, or to users of DRC RATING's credit rating. or will not guarantee. This does not prevent DRC RATING from developing leading indicators consistent with the IOSCO Code of Conduct Fundamentals for CRA Provisions 1.22 and 2.6 (d) for IOSCO CRAs.
1.21 DRC RATING and its employees will not make promises or threats about potential credit rating actions to influence rated entities, borrowers, sourcing entities, s, intermediaries, or users of DRC RATING's credit rating (e.g. subscribers) to pay in exchange for the credit rating ratings or other services provided by DRC RATING.
1.22 DRC RATING and its employees are responsible for the activities of the rated entity or issuer, including but not limited to their corporate or legal structure, assets and liabilities, business operations, investment plans, financing limits, business-company mergers, structured finance product design. As such, it will not make recommendations or advise that could affect the credit rating of the rated entity or issue.
1.23 DRC RATING will establish, maintain, document and implement policies, procedures and controls designed to ensure that DRC RATING and its employees comply with DRC RATING's code of ethics and applicable laws and regulations in each country in which it operates.
a. DRC RATING will establish a compliance function responsible for monitoring and supervising the compliance of DRC RATING and its employees with the provisions of DRC RATING's code of ethics and applicable laws and regulations.
b. The compliance function will also be responsible for overseeing the adequacy of DRC RATING's policies, procedures and controls designed to comply with DRC RATING's code of ethics and applicable laws and regulations.
c. DRC RATING assigns a qualified senior employee responsible for the compliance function to serve as compliance officer. The reporting hierarchy and remuneration of the compliance officer will be independent of DRC RATING's credit rating processes.
1.24 If a DRC RATING employee becomes aware that another DRC RATING employee or a company affiliated with DRC RATING has engaged or has engaged in illegal or unethical behavior or is in breach of DRC RATING's ethical rules, he/she will report this information to the compliance officer. or another appropriate DRC RATING officer, so that appropriate action can be taken. DRC RATING's employees are not necessarily expected to be legal professionals. However, DRC RATING employees are expected to report activities that a reasonable person would suspect. After receiving such a report from an employee, DRC RATING is required to take appropriate action as determined by laws and regulations and the policies, procedures and controls established, maintained, documented and implemented by DRC RATING. DRC RATING prohibits retaliation against any employee or employees who make such reporting in good faith.
2. DRC RATING's INDEPENDENCE AND AVOIDING CONFLICT OF INTEREST
A. General
2.1 DRC RATING will not delay or refrain from credit rating action to a rated entity, issuer, originator, intermediary, investors or other market participants based on the potential impact (economic, political, or otherwise) of DRC RATING's act.
2.2 DRC RATING and its employees will exercise due care and professional care to maintain the independence and impartiality of DRC RATING and its employees, both in appearance and in substance.
2.3 In determining a credit rating by DRC RATING, only factors related to the creditworthiness of the rated entity or liability will be considered.
2.4 The ratings that DRC RATING assigns for a rated entity or liability will not be affected by the potential business relationship or the current relationship between DRC RATING (or its affiliates) and the rated entity, issuer, originator, underwriter, intermediary (or affiliates), or other parties.
2.5 DRC RATING will segregate the credit rating businesses and credit rating analysts from other business of DRC RATING that may present a conflict of interest, operationally, legally and, if practicable, physically. For other business for which a conflict of interest does not exist, DRC RATING will establish, maintain, document and enforce policies, procedures and controls designed to minimize the potential for a conflict of interest to arise. DRC RATING will explain why it believes there is no conflict of interest between its other businesses and its own credit rating business.
B. DRC RATING Policies, Procedures, Controls and Disclosures
2.6 DRC RATING policies, in order to appropriately identify and eliminate or manage and disclose any actual or potential conflicts of interest that may affect credit rating methodologies, credit rating actions or analyzes of DRC RATING or the judgments and analyzes of DRC RATING employees, establish, maintain, document and enforce procedures and controls. Among other things, policies, procedures and controls will address how the following conflicts (if applicable in DRC RATING's business model) could potentially affect DRC RATING's credit rating methodologies or credit rating actions:
a. Payment of the fee by the rated entity or issuer, originator, underwriter, or agent of the rated liability;
b. Payment of the fee by subscribers who have a financial interest that may be affected by DRC RATING's credit rating action;
c. Payment of the fee by subscribers of the rated institution, issuer, source institution, underwriter, intermediary institution or other services other than providing access to credit rating ratings or DRC RATING's ratings;
d. Providing a preliminary indicator or similar indicator of the credit quality of an institution, borrower, source, underwriter, prior to undertaking the job of determining the final credit rating for an institution, borrower, source, underwriter or arranger;
e. DRC RATING has a direct or indirect partnership with the rated entity or issuer, or the rated entity or issuer has a direct or indirect partnership with DRC RATING.
2.7 DRC RATING discloses actual and potential conflicts of interest (related to, but not limited to, conflicts of interest as defined in Principle 2.6 above) in a full, timely, clear, concise, specific and distinct manner. When an actual or potential conflict of interest may arise specific to a credit rating action relating to a rated entity, issuer, originator, lead underwriter, intermediary or liability, such conflict of interest will be disclosed in the same manner and with the same tools as the relevant credit rating act.
2.8 DRC RATING will disclose the general nature of remuneration agreements with rated entities, issuers, lead underwriters or intermediaries.
a. When DRC RATING receives a fee not related to credit rating services from a rated organization, issuer, source organization, lead underwriting organization or intermediary institution, DRC RATING is responsible for such unrelated fees, or the percentage of the total annual fee received from such rated organization, issuer organization, source organization, lead underwriter organization, the intermediary institution in the relevant credit rating report or elsewhere.
b. If DRC RATING accounts for 10% or more of its annual revenue from a single customer (for example, a rated organization, issuer, source organization, lead underwriter, intermediary or subscriber or their related parties), then the relevant credit rating report or elsewhere appropriate.
2.9 DRC RATING will disclose whether the issuer of a structured finance product has informed DRC RATING about the rated issue that it has shared all relevant information publicly or that the information is kept private.
2.10 DRC RATING will not invest in or transact with financial instruments that present a conflict of interest with credit rating activities.
2.11 Where rated entities or issuers are also responsible for the supervision and oversight of DRC RATING (e.g. sovereign states), DRC RATING employees responsible for negotiating oversight matters with the rated entity or debtor's officers (e.g. employees of regulatory authorities). They will be separate from employees who decide on credit rating actions to be applied to the entity or issuer, or who develop or modify credit rating methodologies.
C. Independence of DRC RATING Employees
2.12 Reporting responsibility and compensation arrangements of DRC RATING employees will be structured to eliminate or effectively manage actual and potential conflicts.
a. Remuneration or evaluation of DRC RATING employees who participate in or may have an impact on a credit rating action regarding a rated entity or liability will not be based on the amount of income DRC RATING derives from that institution or issuer.
b. DRC RATING will conduct a formal and periodic review of its remuneration policies, procedures and practices for DRC RATING employees who participate in or may have an impact on a credit rating action, to ensure that DRC RATING has not and still does not jeopardize the impartiality of the credit rating process.
2.13 DRC RATING employees who participate in or may have an impact on a credit rating action cannot initiate or participate in negotiations with the rated institution, issuer, intermediary institution or subscribers regarding fees or payments issued to such rated institution, issuer, intermediary institution or subscribers.
2.14 If a DRC RATING employee or a close relative of a DRC RATING employee (spouse, close relative or dependent) or an employee-managed organization has the following conditions, DRC RATING employees cannot participate in and influence the credit valuation process related to the organization or liability:
a. Holds or trades an investment instrument issued by the rated institution or obligor;
b. If it holds or trades a derivative instrument (other than a diversified joint investment plan) that has a partnership with the rated institution or obligor, or issued by the rated institution/individual;
c. If it holds or trades an investment instrument of a company affiliated to the rated institution or obligor, whose ownership by a DRC RATING employee may cause a conflict of interest;
d. If it is an investment issued by the lead underwriter or issuer of a rated liability and whose ownership by a DRC RATING employee may cause a conflict of interest;
e. If the rated entity or liability, or the lead underwriter or the issuer of the rated liability that may cause a conflict of interest, is in a current or recent employment relationship with or could be considered significant;
f. Is the director of the rated entity or its liability or lead underwriter or issuer of the rated liability, or is in a relationship or a partnership relationship that could result in a conflict of interest with the rated entity, the obligor, or the lead underwriter or the issuer of the rated liability.
2.15 The DRC RATING analyst cannot hold or trade an investment instrument that falls under his analytical responsibility and is issued by the rated institution or obligor. However, holding or trading an investment instrument that falls under the analyst's analytical responsibility and issued by the rated institution or obligor; does not preclude holding or trading the diversified joint investment plan.
2.16 A DRC RATING employee cannot request money, gifts or benefits from an institution with which it has a business relationship, and it is prohibited to receive cash or cash-like gifts or gifts exceeding a certain monetary value.
2.17 If the DRC RATING employee has a personal relationship with an employee of the institution that creates or may create a conflict of interest, he/she shall notify the manager/person responsible for compliance in accordance with the policies, procedures and internal controls of DRC RATING.
2.18 DRC RATING establishes, maintains, documents and implements relevant policies, procedures, internal controls, by reviewing the past work done on behalf of a underwriter or regulator (or their affiliates) by the personnel who joined an institution/obligated company whose business relationship with DRC RATING was terminated and subsequently rated by him who had a business relationship that could be considered important in terms of their job description in the past.
3. OBLIGATIONS OF DRC RATING TO INVESTORS, RELATED INSTITUTIONS, DEBTORS, UNDERWRITERS AND REGULATORS
A. Timing and Transparency of Credit Rating Disclosure
3.1 DRC RATING should explain in clear language the limitations and nature of credit ratings, and the drawbacks and risks of over-reliance on them when making investments and financial decisions, so that investors and rating agencies can have a deeper understanding of these ratings. DRC RATING cannot make a statement that this board approves or implies that the credit ratings given by DRC RATING, which is authorized and supervised by a national board (Turkish Capital Markets Board - SPK).
3.2 DRC RATING will explain the necessary information about the credit rating process and methodology so that investors and other users are informed about how the credit rating is given.
3.3 DRC RATING discloses significant changes in the credit rating methodology before the application will be used effectively, as long as it does not unduly delay the credit rating process and this situation adversely affects the credit rating process. In any case, DRC RATING will non-selectively disclose the significant methodology change.
3.4 DRC RATING will explain its policies and procedures regarding non-demand credit risk assessment.
3.5 DRC RATING will explain its policies and procedures regarding credit rating disclosure, reporting and withdrawal processes.
3.6 DRC RATING clearly states what each of the credit ratings means categorically (including the definition of the degree of default).
3.7 DRC RATING distinguishes structured finance products from corporate and liability credit ratings, preferably with a different credit rating definition. DRC RATING explains how this separation works.
3.8 DRC RATING should be transparent to investors, rated institutions, borrowers, s and regulators about how an entity or liability is rated.
3.9 DRC RATING, if appropriate and possible, explains to the rated institution, borrower or liability issuer what critical information component and main idea the process will be based on before the credit rating is released. DRC RATING shares the issue of transferring information from the rated institution, debtor or liability issuing institution regarding actual errors, omissions, misperceptions that may affect the credit rating. DRC RATING immediately evaluates responses from the rated institution, debtor or liability issuer. In some special cases, if the rated institution has not given any warning to the debtor or the issuing institution before publishing the credit rating, DRC RATING immediately makes an explanation as to why it did not inform the institutions before giving a credit rating.
3.10 When DRC RATING publicly discloses or distributes to its subscribers (depending on DRC RATING's business model) a credit rating that is the subject or result of its rating action, it should do so as soon as practicable after such action is taken.
3.11 DRC RATING must do so in a non-discriminatory manner when it makes public or distributes to its subscribers (depending on DRC RATING's business model) a credit rating that is the subject or result of its rating action.
3.12 DRC RATING discloses whether the rated institution, borrower, source, underwriters or regulators are involved in a credit rating process regarding the content and results of the rating. A credit rating that has not been initiated by the rated institution, borrower, underwriters or regulators is specified as such.
3.13 DRC RATING verifies the nature and limitations of each credit rating and the information provided to it by the rated institution, borrower, underwriter and regulator. For example: if a credit rating covers an institution or liability for which there is little information, DRC RATING explains this fact and how this will limit the credit evaluation process.
3.14 DRC RATING announces when the credit rating was last reviewed and updated when announcing a credit rating resulting from the credit rating process. Credit rating also discloses information about the underlying methodology or adaptation of methodology used in rating and where a description of that methodology can be found. If credit valuation involves more than one method, or if the underlying methodology will cause investors or other credit rating users to miss important details in the credit rating, DRC RATING will state this in its credit rating announcement and shows the location of the statements describing how different credit rating methods and important aspects of credit rating will affect the credit rating decision.
3.15 DRC RATING, when rating a structured financial product, to ensure that investors and credit rating users or subscribers who hold the product understand the basis of the credit rating; must publicly disclose or distribute to its subscribers (in line with DRC RATING's business model) information about the loss of value and cash flow of the financial product, along with its credit rating. DRC RATING should also publicly disclose and share information to what extent the credit rating of the structured financial product analyzes the sensitivity to changes in assumptions in the applied credit methodology.
3.16 When issuing or reviewing a credit rating, DRC RATING should disclose in its report key assumptions and information on the credit rating of the rated institution or obligor, including adjustments to items that deviate from the published financial statements.
3.17 When DRC RATING stops the process of monitoring the credit rating of a rated institution or obligor, it immediately informs the public or its subscribers (in line with its business model) about this pause. In the announcement that the credit rating will not be monitored, DRC RATING indicates when the credit rating was last updated, for what reason the monitoring process was stopped and the credit rating is no longer updated.
3.18 To promote transparency and to compare the performance of different credit rating agencies for investors and other credit rating users, DRC RATING discloses sufficient information about the historical change and default rates of the credit rating categories of the various classified institutions and liabilities it rates. This information is used to compare the performance of different credit rating agencies; It includes historical information that can be proven, measured, organized over a period of time and, if possible, standardized. If historical change or default information is inappropriate or statistically invalid due to the nature of the rated institution and liability or for other reasons, or is likely to mislead investors and other users of credit ratings, the reasons for this will be disclosed by DRC RATING.
B. Handling of Confidential Information
3.19 DRC RATING establishes, maintains, documents and implements the necessary policies, processes and controls regarding how non-public information will be protected in the event that non-public information is received by a rated institution, debtor, intermediary or underwriter, regulator in a rating process. (for example, information about the credit rating action is provided before the credit rating is made public or published to subscribers).
a. Policies, procedures and controls, prohibits notification to other employees of DRC RATING (unless required by law) when DRC RATING discloses confidential and/or non-public information not related to the credit rating process, including although it is not required to disclose in the context of the credit rating process.
b. Policies, procedures and controls require DRC RATING and its employees to take reasonable steps to prevent fraud, theft, misuse or unintentional disclosure of confidential and/or non-public information.
c. Within the scope of confidential information received from a rated institution, debtor, agent, underwriter or regulator, policies, procedures and controls prevent such information from being disclosed within the framework of agreements in force (or mutual agreement of confidentiality unless required by law) of DRC RATING and its employees.
D. As part of an ongoing credit rating process, policies, procedures and controls prevent DRC RATING and its employees from disclosing selective information regarding the ongoing credit rating process to institutions other than the rated institution, borrower, regulators, designated intermediaries, and except as required by law.
3.20 DRC RATING establishes, maintains, documents and implements policies, processes and controls to prevent violations of laws and regulations governing the use and operation of confidential and/or non-public information to be considered important.
3.21 DRC RATING establishes, maintains, documents and implements policies, processes and controls that prevent personnel who have access to confidential or important non-public information about the trading instrument from trading this instrument or gaining advantage by transferring this information to another institution/person.
4. MANAGEMENT, RISK MANAGEMENT AND EMPLOYEE TRAINING
4.1 DRC RATING's board of directors (or similar body) Code of Conduct for Credit Rating Agencies Bases of conduct in line with IOSCO; It has the final authority to create, preserve and document its creation.
4.2 DRC RATING establishes a risk management group consisting of one or more senior executives with sufficient experience in order to evaluate, monitor and report legal, reputational, operational and strategic risks within the company (in addition to other risks) . The function of the risk group operates independently of the internal control group; and prepare periodic reports to assist the board of directors (or corresponding boards) and senior management in assessing the effectiveness of policies, procedures, and controls (including policies, procedures, and internal control at IOSCO Codes of Conduct for Credit Rating Agencies); It regulates the establishment, maintenance and documentation of the necessary principles to manage company risk.
4.3 DRC RATING is obliged to establish, maintain, document and implement policies, procedures and controls in order to ensure that its employees receive the necessary training to increase their professional competence and strengthen their compliance with the relevant regulations. The topics covered during the training should be compatible with the current responsibilities and authorities of the company employees and the responsibilities and authorities they will take in the future, and as far as possible DRC RATING's ethical values, credit rating methodology, legal and international regulations regarding credit evaluation; It should include DRC RATING's credit rating activities, DRC RATING's anti-conflict policies, procedures and controls, and policies and procedures on the use of confidential documents. Policy, procedures and controls should include the certification that company employees have attended the compulsory training and the measures to be taken in this regard.
5. COMMUNICATION AND DISCLOSURE WITH MARKET PARTICIPANTS
5.1 credit rating disclosures to be made by DRC RATING; Including those specified in the provisions of the IOSCO Credit Rating Company Code; must be complete, fair, precise, timely and understandable to investors and other users.
5.2 DRC RATING should make a statement demonstrating the compatibility of its own (code of conduct) provisions together with the provisions of the moral code of conduct, with the IOSCO Code of Conduct Fundamentals for CRA. If DRC RATING's code of conduct shows divergence from any IOSCO provision, DRC RATING identifies this provision and explains the reason for the divergence and explains how the code of conduct meets the objectives of IOSCO provisions despite this deviation. Explains how to effectively enforce the DRC RATING code of conduct. DRC RATING also describes how changes in the code of conduct are implemented in practice and how they are effectively implemented.
5.3 DRC RATING is obliged to establish and maintain a structure that will accept, internalize and handle complaints from market participants. This body should establish, maintain, document and effectively implement policies, procedures and controls on how complaints (including confidential complaints) are received, processed and evaluated. Policies, procedures and controls should set out the grievance conditions and explain what types of grievances should be reported to senior management and/or the board (or the appropriate body).
5.4 Publicly and prominently on the DRC RATING website, free of charge:
a. Code of Conduct of DRC RATING;
b. DRC RATING's Credit Rating Methodology;
c. Historical performance information of DRC RATING;
d. Consistent with DRC RATING's business model, disclosures should be included in the provisions of the IOSCO Code of Conduct for CRAs.
