A.M. BEST RATING SERVICES, INC. RATING DIVISION INTERNAL POLICY AND PROCEDURE. Subject: Dissemination Number: CRPC Policy 5

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1 A.M. BEST RATING SERVICES, INC. RATING DIVISION INTERNAL POLICY AND PROCEDURE Subject: Disseminatin Number: CRPC Plicy 5 Effective Date: Nvember 29, 2006 Revisin Date: January 04, 2016 Purpse: The purpse f this plicy is t frmalize the disseminatin requirements fr public and private Credit Rating pinins and ther AMB pinins classified as assessments r evaluatins. This plicy applies t A.M. Best Rating Services, Inc. (AMBRS) and its credit rating agency subsidiaries (cllectively, AMB). Nte: All unpublished Rating Cmmittee determinatins are cnsidered Material Nn-Public Infrmatin (MNPI) and must be treated with due care and in accrdance with Crprate Plicy 5 (C-5). T prtect MNPI frm unauthrized view, any staff member wh becmes aware f an unpublished Rating Cmmittee determinatin, in any frm (print, verbal, digital), must cnsider the security f the infrmatin. Only authrized persnnel may disseminate an unpublished Rating Cmmittee determinatin t an authrized recipient (e.g. Rating Analysts can ntify cmpany cntacts (including specified third parties) r ther Rating Analysts/administrative staff members wh have a legitimate need t knw, f an unpublished Rating Cmmittee determinatin). 1. Disseminatin Public Credit Ratings: 1.1. Primary Methd f Credit Rating Disclsure: All Rating Actins n public Credit Ratings shall first be disseminated t the public via psting t the Rating Center page f the AMB website (Rating Center Psting) as sn as practicable fllwing the ntificatin f the Rating Actin (see Ntificatin Plicy) t the cmpany/issuer and will include all required public disclsure requirements. Nte: Subsequent secndary republicatins f Rating Actins n public Credit Ratings may be cmpleted using any f the fllwing ancillary distributin methds (nt an exhaustive list), hwever, will nt include the cmplete inventry f Rating Center Psting disclsures: Business Wire News Service; AMB s internal wire service (BestWire); ntificatin lists directed tward subscribers and ther media utlets created and managed by Crprate Cmmunicatins; Publicatins such as BestWeek, Best s Insurance Reprts and Best s Key Rating Guide; and AMB Press Release (if nt already required by this plicy) Credit Rating Disclsure Requirements: A list f the Credit Rating public disclsure requirements t be made in, r linked t, the Rating Center Psting f a Rating Actin is utlined in the Credit Rating Disclsure Matrix (Disclsure Matrix). CRPC Plicy 5: Disseminatin Page 1 f 5

2 Nte: Other Credit Rating Disclsure requirements, nt exclusively made with a Rating Actin, which are required t be public via the AMB website, are als utlined in the Disclsure Matrix Press Release Scenaris: A press release must be disseminated in cnjunctin with the Rating Center Psting f a Rating Actin in any f the fllwing circumstances (r as therwise required) belw: Nte: Fr required press releases assciated with ratings n entities r issuers dmiciled in Brazil, the press release will be published in English and Prtuguese. Fr required press releases emanating frm AMBAL, the press release will be published in English and Spanish Rating Withdrawal: the withdrawal f a Credit Rating (excluding private Credit Ratings) n an existing entity, issuer r security requested by the rated entity r as a result f an AMB business decisin. The press release must be published in cnjunctin with the final Rating Update n the existing entity, issuer r security indicating: the utcme f the Rating Cmmittee (i.e. final rating pinin); the Rating Cmmittee justificatin fr the final rating pinin (i.e. reasn fr withdrawal); by whm the Credit Rating withdrawal was initiated by (i.e. AMB r the entity/issuer); that the Credit Rating will be administratively remved (i.e. n lnger fllwed and mved t the NR categry). Nte: The internal prcess fr the administrative remval f an utstanding Credit Rating fllwing a final Rating Update cmpleted in cnjunctin with a Rating Withdrawal des nt require a separate press release (see CRPC Prcedure 1: Rating Prcess) Fr ratings emanating frm AMBERS/AMBAP nly: if the appeal resulted in a change t the riginal Rating Cmmittee determinatin, this must be disclsed publicly in a press release (excludes private Credit Ratings) Any Rating Actin that includes a methdlgy deviatin; Any Rating Actin issued n a cmpany dmiciled in Mexic; Fr AMBAL, in the case f a rating withdrawal where the issuer/rated entity is asking fr the withdrawal due t a dwngrade, the press release must be issued, at the latest, by the next business day fllwing the rescissin with an indicatin that this is the final Rating Update and that the withdrawal is due t the dwngrade (all ther disclsure requirements still apply); A Rating Cmmittee determinatin t release cmments n a published Credit Rating; Administrative Errrs: In the event that AMB has made public an incrrect Credit Rating, the discvery f such an errr will be immediately made public thrugh the CRPC Plicy 5: Disseminatin Page 2 f 5

3 issuance f a press release (in the applicable language) that states: (1) where the incrrect publicatin f the rating has taken place, fr example, an incrrect rating appears within the Rating Center n AMB s website; and (2) the crrected Credit Rating Press Release Cntent Requirements: Where the publicatin f a press release in cnjunctin with the Rating Center Psting f a Rating Actin is required, r is issued fr ther reasns, the press release must: Include a web link t the Rating Center Psting f the Rating Actin; Be develped using the apprved press release template based n the emplyed lcatin f the primary Rating Analyst. Nte: In the case f a business decisin t prduce a jint ffice press release that includes Rating Actins emanating frm multiple ffice lcatins, the ffice lcatin f the primary Rating Analyst f the mst senir entity within the rganizatins perating structure will gvern which press release template is used. The names f at least ne member f each Analytical Team shuld be identified in the press release All AMBAL Rating Actin press releases t be issued n a cmpany/issuer dmiciled in Mexic shall: be develped using the A.M. Best America Latina (AMBAL) press release template; include in the bdy f the press release, except where a web link is permitted, the related public disclsure requirements utlined in the Credit Rating Disclsure Matrix; include, if applicable, the cntractually bligated infrmatin AMB shuld receive frm its client pertaining t any securities rating that is slicited by the client frm a third party CRA in the tw mnths prir t the issuance f an AMB Issue Credit Rating (see CRPC Plicy 8); The name f the third party CRA that granted the respective rating, as well as the rating it gave t the securities in questin. Nte: A jint ffice press release that includes an AMBAL Rating Actin can nly supplement and nt replace the AMBAL Rating Actin press release. 2. Disseminatin Private Credit Ratings and ther Private AMB Opinins: 2.1. Requests made t AMB t develp a Credit Rating r ther type f assessment r evaluatin n a private basis (i.e. a private Credit Rating, private assessment r private evaluatin) are nt released by AMB t the general public in any medium. CRPC Plicy 5: Disseminatin Page 3 f 5

4 2.2. A private Credit Rating, private Preliminary Credit Assessment (PCA) r ther private evaluatins r assessments will nly be disseminated t the requesting party as part f the rating ntificatin The Rating Evaluatin Service (RES) and Rating Assessment Service (RAS) are private AMB pinins. The required disseminatin requirements fr these pinins are lcated in their respective prcedures A private Preliminary Credit Assessment Letter indicating that AMB has assigned a PCA will accmpany the rating ntificatin. 3. Press Release Develpment and Disseminatin Prcess: When required, the Analytical Team will wrk with Public Relatins and Quality Assurance in the fllwing manner t develp a press release t accmpany the Rating Center psting f the Rating Actin The Analytical Team will develp and prvide a draft press release t the Public Relatins and Quality Assurance Grups Quality Assurance will crss-check the draft press release cntent against the prepped internal system disseminatin (i.e. item(s) t be released t the Rating Center website) Public Relatins will review/edit and return a clean cpy f the press release t the Analytical Team t send t the subject cmpany. The Analytical Team must send the release t a persn authrized t receive Material Nn-Public Infrmatin (MNPI) at the subject cmpany, requesting such persn t review the release. The cmpany is nt permitted t change any cntent cntained in the draft press release ther than edits that: remve MNPI; crrect factual errrs (includes grammatical/spelling errrs); crrect factual misperceptins; add material factual missins, excluding MNPI, that were cnsidered by the Rating Cmmittee. Nte: Other than utlined abve, n edits are permitted. This includes changes in text using a synnym f the riginal wrd Fllwing the cmpany review, the Analytical Team revises the press release, if apprpriate, and frwards t Public Relatins. Nte: A recrd f any cmpany recmmended change will be maintained Public Relatins prvides the final draft release t the Analytical Team; If warranted, the Analytical Team will facilitate the translatin f the final press release int the apprpriate language and prvide t Public Relatins. CRPC Plicy 5: Disseminatin Page 4 f 5

5 3.6. Fr ratings emanating frm AMBERS, the Quality Assurance Grup cnfirms with the Analytical Team that the rated entity was infrmed f the pending Credit Rating t be published: During its wrking hurs (i.e. the entity s wrking day), and; At least a full wrking day befre publicatin f the Credit Rating Fllwing the rating divisin release f the rating(s) (i.e. rating Center Psting f the Rating Actin), a system generated ntificatin is prvided t Public Relatins and the Quality Assurance Grup; 3.8. Upn ntificatin, Public Relatins will: Pst the press release t the AMB website and Business Wire (all language versins); Pst t BestWire fr subscriber distributin (English versin nly) 3.9. Upn ntificatin, Quality Assurance will: Cmpare the website publicatin f the rating(s) t internal systems. Review that the final press release (including any translatin) was psted t the website. Effective Date: 11/29/06 Revisin Dates: 06/21/07; 01/01/09; 04/10/09; 04/14/10; 09/03/10; 09/07/10; 01/19/11; 09/02/11; 12/20/12; 02/22/13; 06/20/13; 10/22/13; 09/22/14; 01/16/15; 06/15/15; 01/04/16 CRPC Plicy 5: Disseminatin Page 5 f 5

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