Policy for Securities Trading for Employees Located Outside the U.S. and UK

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1 Policy for Securities Trading for Employees Located Outside the U.S. and UK Issued by: MIS Compliance Department Applicable to: All MCO Employees located outside the U.S. Effective Date: December 31, 2012» This policy is in effect as of December 31, 2012 for Employees located outside the U.S. and UK and for accounts that hold Reportable Securities in all regions except the U.S. and the UK, regardless of where the Employee is located.» Employees located in the U.S. and UK and accounts that hold Reportable Securities in the U.S. and UK are bound by the Policy for Securities Trading.» If you are unsure how this Policy and/or the Policy for Securities Trading applies to you, please contact your local Compliance officer. POLICY PROVISIONS APPLICABLE TO ALL EMPLOYEES OF MOODY S CORPORATION Prohibition Against Trading While In Possession of Material Non-Public Information General Prohibition Applicable to All Employees Notwithstanding any other provision of this Policy, Employees and Family Members are prohibited from engaging in any Trade of a Security while in possession of Material Non-Public Information relating to the Issuer of the Security or the Security itself or otherwise in violation of any applicable law, rule or regulation. This prohibition remains in effect until three business days after the information has been widely disseminated to the public. For example, Employees and Family Members may not Trade Moody s Securities while aware of Material Non-Public Information about Moody s. In addition, Employees and Family Members may not Trade any other Security while in possession of Material Non-Public Information relating to that Issuer or the Security. These prohibitions apply regardless of the source from which the Employee or Family Member came into possession of Material Non-Public Information / SP20055

2 Prohibition Against Tipping It is illegal in many countries and a violation of this Policy for a person who is in possession of Material Non-Public Information about Moody s or any other Issuer to: (i) recommend that a third party Trade in the Issuer s Securities; or (ii) convey such Material Non-Public Information to a third party ( Tipping ). Tipping is prohibited regardless of whether or not the Employee or Family Member who provides the tip receives any monetary or other benefit. Additional Restrictions on Trading Moody s Securities Prohibition Against Short Sales of Moody s Securities Selling short is the practice of selling Securities of which you are not the record owner. As a matter of Moody s Policy, Employees and their Family Members may not sell Moody s Securities short regardless of whether or not they are in possession of Material Non-Public Information about Moody s. Other Speculative Trades Involving Moody s Securities Employees and their Family Members are also prohibited from engaging in short-term or speculative transactions involving Moody s Securities, including purchasing or selling put or call options and entering into other derivative transactions involving Moody s Securities. Moody s believes that engaging in speculative transactions signals to the market and regulatory authorities that the Employee or Family Member engaged in such Trading may possess Material Non-Public Information concerning Moody s. Therefore, in order to avoid even the appearance of impropriety, Moody s prohibits its Employees and Family Members from engaging in such Trades. SPECIAL RESTRICTIONS FOR COVERED EMPLOYEES REGARDING TRADING AND OWNERSHIP OF SECURITIES OF ISSUERS OTHER THAN MOODY S As a part of the MIS rating process, Issuers and other parties often share Material Non-Public Information with Covered Employees. In addition, an MIS rating action or other public announcement may have an effect on the price of an Issuer s Securities or Securities not directly related to that Issuer. Accordingly, in addition to legal restrictions that exist in many jurisdictions and the restrictions set forth in this Policy that are applicable to all Moody s Employees, Moody s places limits on Trading and Ownership of Securities by Covered Employees and their Family Members in order to protect against any real or apparent conflicts of interest. These limitations on Trading and Ownership are as follows: Non-Public Information Covered Employees and their Family Members are prohibited from Trading a Security if: (i) they make the Trade while in possession of Material Non-Public Information relating to the Security or the Issuer of the Security; or (ii) the Trade is made while the Employee or Family Member is in possession of Non-Public Information that is proprietary to Moody s, regardless of whether or not the information is Material Information. Information relating to a potential MIS rating action decision (including a decision not to take a rating action) is considered proprietary to Moody s and is presumed to be Material Information for the purposes of this Policy. 2 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

3 Primary Area of Analytic Responsibility Covered Employees and their Family Members may not Own or Trade any Security issued, guaranteed, or otherwise supported by an Issuer within the Covered Employee s Primary Area of Analytic Responsibility (as defined below). A Manager s Primary Area of Analytic Responsibility includes those Issuers and Securities that are also within the Primary Area of Analytic Responsibility of anyone he or she supervises or manages (directly or indirectly). Although the restriction covers all Covered Employees and their Family Members, it is most directly applicable to Covered Employees who work on rating teams. The Primary Area of Analytic Responsibility for Employees not directly participating in rating actions includes those areas, teams and/or groups that they support. For example, an Employee who is responsible for research coverage for the Corporate Finance Group ( CFG ) or the Structured Finance Group ( SFG ) has as his or her Primary Area of Analytic Responsibility all Issuers and Securities rated by CFG or SFG. If Managers have questions about how to apply the restriction to Covered Employees or Family Members whose job functions support ratings teams (but who are not on ratings teams), they should consult with the Compliance Department. In general, though, Covered Employees who support rating processes and are aligned with specific rating teams are required to abide by the restrictions applicable to the rating team or teams they support. Ratings Teams Outside of SFG A Covered Employee s Primary Area of Analytic Responsibility is any Issuer rated by the Covered Employee s team or any team that directly or indirectly reports to him/her. 1 In addition, because the term Issuer includes all corporate parents and majority-owned subsidiaries, Covered Employees and their Family Members may not Own or Trade any Security issued, guaranteed or otherwise supported by the corporate parent or majority-owned subsidiary of an Issuer that is rated by the Covered Employee s team. For example, no Analyst or Manager on the team that rates GE Capital may Own or Trade any Security issued, guaranteed or otherwise supported by GE Capital or derived from GE Capital equity or fixed income securities, regardless of whether or not the Analyst or Manager has had any direct participation in the rating of GE Capital. In addition, no Analyst or Manager on that team may Own or Trade Securities issued, guaranteed, derived from or otherwise supported by General Electric because it is the corporate parent of GE Capital. Rating Teams in SFG For Covered Employees in SFG, an Employee s Primary Area of Analytic Responsibility is determined by reference to a list of Issuers applicable to that Employee s rating group. Specifically, Covered Employees in SFG and their Family Members may not Own or Trade any Security issued (or any Security derived from the equity or fixed-income Securities issued) by an Issuer identified on the Restricted List applicable to that Employee. There are two lists one global list for the Asset Finance Group (the AFG Restricted List ) and one global list for the Derivatives Group (the Derivatives Restricted List ) which are available and posted on MoodysNet. These lists will be updated on a periodic basis and the most current version will be posted on the ComplianceNet page on MoodysNet. 1 A team is defined based on reporting lines and generally refers to the group of Employees who report to a particular Manager. For the purposes of this policy, any other team construct must be approved by the Compliance Department. 3 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

4 Prohibition Against Investing in Securities Underwriters SFG Employees and their Family Members also may not Own or Trade any Security issued by leading securities underwriters. The entities subject to this restriction are included on both the AFG Restricted List and the Derivatives Restricted List, which are amended from time to time. Participation in Rating Actions Employees may not directly or indirectly participate in a rating action (even if outside their Primary Area of Analytic Responsibility) if they or their Family Members Own any Security that could be affected by that rating action. Direct or indirect participation in a rating action includes, but is not limited to, serving as the Lead Analyst, serving as the back-up Analyst, serving on the rating committee, providing the approval to record and release a rating action, assisting in drafting the materials being considered by the rating committee or working with a rating team or Analyst on a model used in a specific rating action. For example, any Analyst or managing director who Owns any XYZ Securities is barred from participating in any rating committee involving XYZ. Questions about whether or not an MCO Employee may properly, or has already, participated in a rating action should be referred to the Compliance Department. Resolving Conflicts Occasionally, you may find that you have inadvertently breached this Policy due to business or other reasons beyond your control. For example, an Issuer not previously rated by your team may apply for a rating or otherwise become rated by your team, or you may be assigned to another rating team, or you or a Family Member may inherit Securities that fall within your Area of Primary Analytic Responsibility. In such circumstances, it is your obligation to contact your Manager and the Compliance Department immediately in writing to resolve such inadvertent violations of the Policy. Before selling any Security of an Issuer rated by your team, you must obtain clearance from the Compliance Department. 30-Day Holding Period Covered Employees and their Family Members who purchase a Security must hold that Security for at least 30 consecutive calendar days. For example, no sales of a Security may occur less than 30 days after the most recent purchase of such a Security. Further, Covered Employees and their Family Members may not enter into a derivative contract that will expire in less than 30 days. This restriction does not apply to Covered Employees who: (i) are not directly involved in credit rating activities; (ii) do not otherwise participate in determining credit ratings; or (iii) do not ordinarily have access to Material Non-Public Information other than MCO Material Non-Public Information. For example, Employees in Human Resources generally are not subject to this restriction. Covered Employee Reporting Requirements All Covered Employees must report their Securities holdings and Trades, as well as those of their Family Members, for review by their direct Managers. 4 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

5 Electronic Reporting of Trades Those Covered Employees whose Trades are reported electronically to Moody s by their brokerage firm(s) (i.e., as part of a data feed rather than duplicate copies of statements sent in.pdf, fax or hardcopy format) do not need to manually report their Trades. Manual Reporting of Trades Those Covered Employees who report Securities Trades manually must promptly but no later than six (6) business days after the Trade report all Securities Trades, including those entered into by their Family Members. Manager Review of Trades After receiving notice of a Trade requiring review, Managers must promptly but no later than six (6) business days after being notified of a Trade review such Trades for compliance with this Policy and immediately report any possible violations or concerns to the Compliance Department. SPECIAL RESTRICTIONS FOR MCMR EMPLOYEES MCMR Limits on Personal Investing In addition to the restrictions set forth in this Policy that are applicable to all Moody s Employees, MCMR Employees and their Family Members are subject to the Securities Trading restrictions outlined in the MCMR Compliance Manual. Please refer to the MCMR Compliance Manual for more details. MCMR Employee Reporting Requirements MCMR Employees are required to report for review their Securities holdings and Trades, as well as those of their Family Members, in accordance with the procedures outlined in the MCMR Compliance Manual. Please refer to the MCMR Compliance Manual for details. EXEMPT TRANSACTIONS Mutual Funds Neither the Trading restrictions nor the reporting requirements of this Policy apply to money market mutual funds. In addition, except as noted immediately below, neither the Trading restrictions nor the reporting requirements of this Policy apply to Trades in widely diversified collective investment schemes (including managed funds such as pension funds and life insurance), open-end mutual funds, exchange-traded funds ( ETFs ) or Unit Investment Trusts ( UITs ). Please note that although widely diversified collective investment schemes, open-end mutual funds, UITs and ETFs are exempt from the Trading restrictions and reporting requirements of this Policy, those restrictions and requirements do apply to sector funds, closed-end mutual funds, and mutual funds/etfs that are not widely diversified. Covered Employees and their Family Members may not Own or Trade sector funds that fall within their Primary Area of Analytic Responsibility. For example, an Analyst on the telecommunications team (or his/her Family 5 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

6 Members) may not Own a telecommunications sector fund, and Analysts in SFG and their Family Members may not Own or Trade financial institution sector funds. Such an Analyst (or his/her Family Members) may, however, Own or Trade a health care sector fund as long as he/she complies with the reporting requirements described in Appendix A. For the purposes of this Policy, it is presumed that a sector fund is one that is described as such in its prospectus, other fund literature or elsewhere (e.g., or For the purposes of this Policy, it is presumed that a mutual fund, UIT or ETF has a widely diversified portfolio if: (i) it is not a sector fund; and (ii) it is described as widely diversified in its prospectus, other fund literature or elsewhere (e.g., Morningstar or Bloomberg websites). Other mutual funds or ETF s may qualify for this exemption on a case-by-case basis. Please contact the Compliance Department with any questions regarding what is, or is not, widely diversified. U.S. Savings Bonds Neither the Trading restrictions nor reporting requirements of this Policy apply to U.S. Savings Bonds that are non-transferable bonds issued and backed by the full faith and credit of the U.S. government. However, government securities (e.g., U.S. Treasury bonds or bills) that may be sold or transferred are subject to the Trading restrictions of this Policy, where applicable. Insurance Policies Neither the Trading restrictions nor the reporting requirements of this Policy apply to personal insurance policies, such as homeowners, life, auto, disability and individual annuity policies. Variable and fixed annuities, however, are considered Securities covered by this Policy. Individual annuities that contain Securities or are derived from Securities are also considered Securities covered by this Policy. As a result, such annuities are subject to the Trading restrictions and reporting requirements. Certificates of Deposit Neither the Trading restrictions nor the reporting requirements of this Policy apply to certificates of deposits of banks, credit unions, and savings and loans. Property Ownership Neither the Trading restrictions nor the reporting requirements of this Policy apply to ownership in any housing co-op, property owners association, or similar not-for-profit association or corporation related to the ownership or enjoyment of an Employee s home or neighborhood. Blind Trusts Neither the Trading restrictions nor the reporting requirements set forth in this Policy apply to Trades of Securities made in a blind trust held for the benefit of an Employee or his/her Family Members. In order to qualify as a blind trust, however, the Employee and/or his/her Family Members must have: (i) no knowledge of the Securities held in the trust; and (ii) no discretion or control over the Trading of Securities in the trust. 6 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

7 In order to avail himself/herself of this exemption, a Covered Employee or Family Member must provide the Legal and Compliance Departments with a copy of the agreement covering any blind trust that is held for the benefit of the Covered Employee or his/her Family Members. This exemption does not apply until the documentation establishing the trust has been approved by the Legal Department, reported to the Compliance Department and has become effective (i.e., the Securities have been transferred to the trust account). All changes to an approved blind trust must be made in writing and must be approved by the Legal and Compliance Departments. Moody s Stock Options The prohibition on speculative Trading of Moody s Securities affects only the secondary market in options and not the ability of Employees to exercise Moody s stock options received in connection with their compensation. Employees may not, however, exercise and sell any Moody s stock options while in possession of Material Non- Public Information about Moody s except those that are pursuant to an approved 10b5-1 trading plan. 2 The reporting requirements of this Policy do not apply to exercises of Moody s stock options received in connection with compensation. Moody s Employee Stock Purchase Plan Neither the Trading restrictions nor the reporting requirements set forth in this Policy apply to Trades of Securities in Moody s Employee Stock Purchase Plan (the ESPP ) resulting from an Employee s monthly payroll contributions to the ESPP under an election made when the Employee was not aware of any Material Non-Public Information about Moody s. However, no Employee, while aware of Material Non-Public Information about Moody s, may: (i) elect to begin participating or cease participating in the ESPP; (ii) increase or decrease the percentage of the Employee's monthly payroll contributions to the ESPP; or (iii) sell Moody s Securities purchased pursuant to the ESPP. Moody s Profit Participation Investment Plan Neither the Trading restrictions nor the reporting requirements set forth in this Policy apply to Trades of Securities in Moody s Profit Participation Investment Plan ( PP/IP ) resulting from an Employee s periodic payroll contributions to the plan under an election made when the Employee was not aware of any Material Non- Public Information about Moody s. However, no Employee, while aware of Material Non-Public Information about Moody s, may: (i) increase or decrease the percentage of the Employee's periodic payroll contribution that will be allocated to Moody s stock fund; (ii) make an intra-plan transfer of an existing account balance into or out of Moody s stock fund; (iii) elect to borrow money against the Employee s PP/IP account if the loan will result in a liquidation of some or all of the Employee s Moody s stock fund balance; or (iv) pre-pay a plan loan if the prepayment will result in the allocation of loan proceeds to Moody s stock fund. 2 Rule 10b5-1 under the Securities Exchange Act of 1934 ( Rule 10b5-1 ) and Company policy permit directors, officers and Employees to Trade in Company securities regardless of their awareness of inside information if the transaction is made pursuant to a pre-arranged written trading plan ( Trading Plan ) that was entered into when the person was not in possession of Material Non-Public Information and that complies with the requirements of Rule 10b POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

8 POLICY ADMINISTRATION Certification of Compliance All Employees must certify compliance with this Policy (and as otherwise required by the Compliance Department) within 45 days of commencing employment. Thereafter, all Moody s Employees will be required to certify their compliance with this Policy on an annual basis. The certification procedures are described in detail in Appendix A. Special Rules Affecting Directors, Officers and Certain Other Designated Employees Members of Moody s Board of Directors, officers and certain other designated Employees are subject to additional ownership, trading and reporting restrictions that are set forth in a separate policy. Penalties for Insider Trading and Violations of Moody s Securities Trading Policy Persons who violate insider trading laws in the United States and many other jurisdictions may face criminal penalties, civil penalties, and private damage awards. Aside from such penalties, any Employee who violates this Policy may also be subject to discipline by Moody s, up to and including termination of employment in accordance with applicable law. Reporting Violations/Seeking Advice You must report suspected violations of this Policy to the Legal and Compliance Departments immediately. If you have any questions about this Policy or any doubt as to your obligations under this Policy, you should immediately seek guidance from either of those departments. Do not attempt to resolve uncertainties on your own. The responsibility for protecting Moody s reputation rests with each of us. You must become familiar with, and conduct yourself strictly in compliance with, all applicable securities laws and regulations and Moody s policies and guidelines pertaining to them. Waivers Under certain limited circumstances, the Compliance Department may grant written waivers of the Reporting, Trading and Ownership restrictions imposed upon Covered Employees and their Family Members. If you believe that a waiver of these restrictions is appropriate, you should contact your immediate Manager. If your Manager agrees that a waiver is appropriate, you may then seek a waiver from the Compliance Department. All requests for waivers must be made in writing and must include all relevant facts. Even if the Compliance Department grants a waiver of the Trading or Ownership restrictions with respect to a particular Issuer, the Covered Employee would still be precluded from participating in any rating activities, including attending rating committees, for that Issuer or violating other applicable laws, rules, regulations, policies or procedures. The decision as to whether to grant a waiver is within the sole discretion of the Compliance Department. Under no circumstances shall a waiver permit an Employee or Family Member to violate the insider trading or other applicable laws. 8 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

9 Additional Restrictions In consultation with the Compliance Department, Managers may implement additional restrictions on the Trading and Ownership of certain Securities in order to meet their business needs. Conflicts with Local Laws Where a local jurisdiction s laws contain mandatory requirements that differ from the provisions of this Policy, that jurisdiction s laws prevail for Employees based in that jurisdiction. Please contact the Compliance or Legal Departments if you have any questions regarding the interaction of this Policy and the laws of the country in which you are employed. No Rights Created This Policy is a statement of certain principles, policies and procedures that govern Securities Trading by Employees and Family Members. It is not intended to, and does not, create any obligations to or rights in any Employee, Family Member, client, supplier, competitor, shareholder or any other person or entity. SECURITIES TRADING POLICY APPENDIX A Reporting Requirements for Covered Employees and MCMR Employees Pursuant to the Securities Trading Policy, all Covered Employees and MCMR Employees are required to disclose their Securities holdings and Trades, as well as those of their Family Members. MCMR Employees are subject to the reporting requirements outlined in the MCMR Compliance Manual. Please find below the particular procedures that apply to relevant Employees. All such reporting, and managerial reviews, will be handled via the SunGard Personal Trading Assistant system (the PTA system ), which may be accessed via the ComplianceNet page on MoodysNet. Covered Employees Within 45 days of the Effective Date of this Policy and immediately upon commencing employment, each Covered Employee must provide Moody s with: (i) a complete list of all previously unreported Securities positions 3 in which the Covered Employee and/or his/her Family Members has a beneficial interest or the authority to place Trades; (ii) a complete list of all previously unreported accounts with financial institutions (including the name of the financial institution, account number and the name of the account holder(s)) in which he/she and/or any Family Member holds any reportable Securities; (iii) complete account information, 4 if not previously provided, for all such accounts; and (iv) consent to Moody s authorizing all relevant financial services firms to provide Moody s with duplicate copies of all confirmations and account statements regarding all accounts for which such a letter has not already been provided. 5 3 This includes the security name, CUSIP/ISIN/ticker symbol, number and size of Trade or position. 4 E.g., name/address/contact information of financial institution, account number and name of broker or financial representative. 5 For blind trusts, as described in Section E(6) of the Policy, Employees and/or Covered Employees need not comply with this paragraph. Instead, as noted in Section E(6) of the Policy, the Employee or Covered Employee must provide a copy of the blind trust agreement to the Legal and Compliance Departments. 9 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

10 In addition, Covered Employees must promptly report Trades of all reportable Securities by them or their Family Members. For those who report their Trades manually, reporting shall generally be required within six business days for Covered Employees who: (i) are directly involved in credit rating activities; (ii) otherwise participate in determining credit ratings; or (iii) have access to Material Non-Public Information other than MCO Material Non-Public Information. Other Covered Employees (i.e., those who: (i) are not directly involved in credit rating activities; (ii) do not otherwise participate in determining credit ratings; and (iii) do not ordinarily have access to Material Non-Public Information other than MCO Material Non-Public Information) who manually report their Trades must do so within ten (10) days of the end of each month in which the Trade occurred. Covered Employees must also promptly update the PTA system and notify the Compliance Department (with copies of relevant documents) in the following circumstances: (i) when a Covered Employee or Family Member opens a new brokerage account with reportable Securities or obtains a beneficial interest in, or the authority to Trade in, an additional account containing reportable Securities; or (ii) when an existing account is closed or materially changed. 6 For each such account, this notification must include the information described in the preceding paragraph (if not already submitted). The Compliance Department may require additional documentation regarding such accounts. Each Covered Employee bears the responsibility of ensuring that all financial institutions in which the Covered Employee and/or his/her Family Members are beneficial owners (or in which any one of them can Trade Securities) continue to submit duplicate copies of all statements and confirmations to Moody s in a timely manner. Moody s may arrange with certain financial services firms to receive statements and confirmations electronically rather than in paper format. In such circumstances, if any administrative changes to your account are required in order to provide such electronic access, Moody s will attempt to notify you of any such changes. MCMR Employees Each MCMR Employee should follow the reporting requirements and the review procedures outlined in the MCMR Compliance Manual. Managers Managers of Covered Employees must review for compliance with this Policy all Trades for those Employees who report directly to them for adherence to the obligations under this policy, and document the outcome of that review in writing no later than six business days after receiving notification of a Trade. This review will be done in the PTA system and will note whether approval was given or withheld. Managers must immediately raise all potential conflicts of interest or violations of this Policy or related Policies with the Legal and Compliance Departments. 6 An example of a material change would be the addition of another beneficial owner or person who can authorize Trades in the account or the account becoming (or ceasing to be) a managed account. 10 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

11 Certification of Compliance Pursuant to the Securities Trading Policy, all Moody s Employees are required to certify their compliance with this Policy within 45 days of commencing employment and, thereafter, on an annual basis. Covered Employees All Covered Employees must complete an Initial Compliance Certificate for Covered Employees within 45 days of commencing employment in which he/she: (i) acknowledges that he/she has read and understands the Securities Trading Policy; (ii) agrees to comply with the Policy, including providing Moody s with a complete list of all reportable Securities Owned and all brokerage accounts with reportable Securities held by the Covered Employee and/or his/her Family Members, if any, and authorizing Moody s to receive duplicate confirmations and statements for any such brokerage accounts held by the Covered Employee and/or his/her Family Members; (iii) confirms that Moody s has a record of all such accounts; (iv) confirms that he/she has separately reported all Trades conducted by the Covered Employee and/or his/her Family Members that are required to be reported under the Policy where the Security was not held in a brokerage account (e.g., when the physical certificate for the Security is held). In addition, each Covered Employee must complete an Annual Compliance Certificate for Covered Employees in which he/she: (i) acknowledges that he/she has read and understands the Securities Trading Policy; (ii) agrees to comply with the Policy, including providing Moody s with a complete list of all reportable Securities Owned and all brokerage accounts with reportable Securities held by the Covered Employee and/or his/her Family Members, if any, and authorizing Moody s to receive duplicate confirmations and statements for any brokerage accounts held by the Covered Employee and/or his/her Family Members; (iii) confirms that Moody s has a record of all such accounts; (iv) confirms that he/she has separately reported all Trades conducted by the Covered Employee and/or his/her Family Members that are required to be reported under the Policy where the Security was not held in a brokerage account (e.g., when the physical certificate for the Security is held); and (e) certifies his/her compliance with the Policy during the preceding year, including compliance with the reporting requirements of the Policy. Non- Covered Employees Non-Covered Employees must complete an Initial Compliance Certificate for Non-Covered Employees within forty-five (45) days of commencing employment acknowledging that he/she has read and understands the Securities Trading Policy and agreeing to comply with the Policy. Such Non-Covered Employees must also complete an Annual Compliance Certificate for Non-Covered Employees. In the Annual Compliance Certificate, each Non-Covered Employee must: (a) acknowledge that he/she has read and understands the Securities Trading Policy; (b) agree to comply with the Policy; and (c) certify his/her compliance with the Policy. MCMR Employees Each MCMR Employee should follow the certification requirements outlined in the MCMR Compliance Manual. 11 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

12 DEFINED TERMS Analyst An Analyst is any MIS Employee assigned to a ratings team with the title of Associate Analyst or higher whose function is to a) assign or monitor Ratings, b) assist in drafting materials or developing deal specific models being considered for rating committees, or c) supervise MIS Employees included in (a) or (b) of this definition. The definition of Analyst excludes any MIS Employee assigned to a rating team who: (1) is not involved in the Ratings process or (2) supports the rating process solely through administrative tasks, such as entering information into internal systems. Employee, Covered Employee, MCMR Employee and Non-Covered Employee The term Employee means any full-time or part-time employee of Moody s Corporation or any of its majorityowned subsidiaries, wherever located. The term Covered Employee includes all full-time or part-time Employees of:» Moody s Investors Service, Inc. ( MIS );» Moody s Shared Services, Inc.;» Credit Rating Affiliates of MIS in Item 3 of Form NRSRO filed with the U.S. Securities and Exchange Commission (available on moodys.com);» those subsidiaries or affiliates of MIS that provide credit rating services; and» those full-time or part-time employees of non-credit rating affiliates or subsidiaries of MIS whose services are placed at the disposal or under the control of MIS (or an affiliated credit rating agency) and who are directly involved in credit rating activities, who otherwise participate in determining credit ratings or who otherwise have access to Material Non-Public Information other than MCO Material Non-Public Information. The term MCMR Employee includes all full-time or part-time employees of Moody s Capital Markets Research, Inc. The term Non-Covered Employee refers to all other Employees who are not either Covered Employees or MCMR Employees. Family Members The term Family Members refers to the following persons: a. an employee s spouse or domestic partner (or any other person with whom an employee cohabits and shares financial responsibilities); b. an employee s minor or dependent children; c. any other relative sharing the same household as the employee; d. any persons who do not live in the same household as the employee but whose Trades in Securities are directed by or are subject to the employee s influence or control (either direct or indirect) (such as parents or children living in separate households who consult with the employee before they Trade); and 12 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

13 e. any other natural or legal person, trust, entity or partnership (other than blind trusts, as defined in the Securities Trading Policy): i. whose managerial responsibilities are discharged by; ii. that is set up for the benefit of; iii. that is directly or indirectly controlled by; or iv. whose economic interests are substantially equivalent to, the employee or any Family Member 7. Issuer or Issuers The term Issuer means any entity by which a Security has been issued, guaranteed, or by which the credit underlying the Security has been otherwise supported. The term Issuer also includes the corporate parent or majority-owned subsidiary of an Issuer. Issuers is the plural form. To enhance clarity for Covered Employees in the Structured Finance Group ( SFG ), Issuers applicable to the Employee s rating group in SFG (e.g., global derivatives group or global asset finance group) shall be enumerated on a list that is available to such Employees on Moody s intranet. Such a list shall include entities in the roles of sponsor, seller, seller/servicer, depositor, manager, collateral manager or originator for transactions rated by the rating group during the past three years and, as applicable, publicly traded corporate parents or other affiliates. Each such list shall be updated on a periodic basis. Lead Analyst A Lead Rating Analyst, Lead Analyst or Lead is the MIS Employee who is currently assigned with the primary responsibility for assigning or monitoring a given Rating. Material Information Material Information means any information that: (i) might have an effect on the market for a Security generally; or (ii) might affect an investment decision of a reasonable investor. Examples of Material Information may include, but are not limited to: sales results; earnings or estimates (including reaffirmations or changes to previously released earnings information); dividend actions; strategic plans; new products, discoveries or services; important personnel changes; acquisition and divestiture plans; financing plans; proposed securities offerings; marketing plans and joint ventures; government actions; major litigation, litigation developments, or potential claims; restructurings and recapitalizations; the negotiation or termination of major contracts; and potential or pending MIS rating actions. Information about pending or future MIS credit rating actions or other material public announcements (including, but not limited to, research reports) is presumed to be Material Information for the purposes of this Policy. If you have any question as to whether or not a particular piece of information is Material Information, you should err on the side of caution and assume that it is Material Information. Manager, "Management" or "Managers" Those Employees who have personnel management responsibilities. 7 Accounts not covered by this Policy are those that meet ALL of the following criteria: (i) those that are managed by a registered or licensed investment adviser or manager; (ii) those that are part of, or owned by, a trust or estate created for the benefit of a deceased Family Member; (iii) those accounts in which the Employee has no beneficial ownership in the account; and (iv) those accounts over which an Employee does not exercise control by directing Trading activity. 13 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

14 Non-Public Information Information is considered to be Non-Public Information unless it has been publicly disseminated (for example, through public filing with a securities regulatory authority; issuance of a press release; disclosure of the information in a national or broadly disseminated news service; or the issuance of a proxy statement or prospectus). Material Non-Public Information The term Material Non-Public Information refers to that information that is both Material Information and Non-Public Information. Own and Ownership The terms Own and Ownership refer to all methods by which an Employee may possess an interest in a Security or an account with a financial services institution, including direct ownership and beneficial ownership (i.e., sole or shared dispositive or voting power over a Security). For the purposes of this Policy, direct ownership includes all Securities held in trust (other than a blind trust) and all Securities held in any individual retirement account ( IRA ) or 401(k) other than Moody s Profit Participation Investment Plan. For the purposes of this Policy, Employees are deemed to be the beneficial owner of all Securities held by their Family Members. Rating A Rating is any rating or assessment with respect to Credit Rating Services, Ancillary Services, and Other Permissible Services. Security The term Security means any non-deposit financial instrument that is, or is derived from, any equity or fixedincome security. This includes, but is not limited to: stocks, bonds, debentures, options, equity securities, convertible securities, warrants, derivative instruments (including swaps, commodities and futures based on or linked to equity or fixed income securities), notes, collective investment schemes, fixed annuities, variable annuities, open- or closed-end mutual funds, exchange traded funds (ETFs) and unit investment trusts (UITs). For example, as used in this Policy, references to Securities issued or guaranteed by an Issuer such as Moody s Corporation include securities derived from any equity or fixed-income security issued by Moody s Corporation, even if the derivative security is not issued directly by Moody s. For exemptions to this definition, please refer to Section E, below. Trade The term Trade refers to any transaction by which a person acquires or divests himself/herself from an interest or position in a Security, including but not limited to purchases, sales, repurchase agreements, short sales, spread betting (and other forms of gambling on Securities) and entering into derivative transactions, including put options, calls and equity swaps as well as liquidating such derivative positions through purchase, sale or exercise. 14 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

15 2012 Moody s Corporation and/or its licensors and affiliates (collectively, MOODY S ). All rights reserved. CREDIT RATINGS ISSUED BY MOODY'S INVESTORS SERVICE, INC. ( MIS ) AND ITS AFFILIATES ARE MOODY S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND CREDIT RATINGS AND RESEARCH PUBLICATIONS PUBLISHED BY MOODY S ( MOODY S PUBLICATIONS ) MAY INCLUDE MOODY S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES. MOODY S DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY MAY NOT MEET ITS CONTRACTUAL, FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS AND MOODY S OPINIONS INCLUDED IN MOODY S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. CREDIT RATINGS AND MOODY S PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND CREDIT RATINGS AND MOODY S PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. NEITHER CREDIT RATINGS NOR MOODY S PUBLICATIONS COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY S ISSUES ITS CREDIT RATINGS AND PUBLISHES MOODY S PUBLICATIONS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILL MAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE, HOLDING, OR SALE. ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY S PRIOR WRITTEN CONSENT. All information contained herein is obtained by MOODY S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided AS IS without warranty of any kind. MOODY'S adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources MOODY'S considers to be reliable including, when appropriate, independent third-party sources. However, MOODY S is not an auditor and cannot in every instance independently verify or validate information received in the rating process. Under no circumstances shall MOODY S have any liability to any person or entity for (a) any loss or damage in whole or in part caused by, resulting from, or relating to, any error (negligent or otherwise) or other circumstance or contingency within or outside the control of MOODY S or any of its directors, officers, employees or agents in connection with the procurement, collection, compilation, analysis, interpretation, communication, publication or delivery of any such information, or (b) any direct, indirect, special, consequential, compensatory or incidental damages whatsoever (including without limitation, lost profits), even if MOODY S is advised in advance of the possibility of such damages, resulting from the use of or inability to use, any such information. The ratings, financial reporting analysis, projections, and other observations, if any, constituting part of the information contained herein are, and must be construed solely as, statements of opinion and not statements of fact or recommendations to purchase, sell or hold any securities. Each user of the information contained herein must make its own study and evaluation of each security it may consider purchasing, holding or selling. NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY SUCH RATING OR OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY S IN ANY FORM OR MANNER WHATSOEVER. MIS, a wholly-owned credit rating agency subsidiary of Moody s Corporation ( MCO ), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MIS have, prior to assignment of any rating, agreed to pay to MIS for appraisal and rating services rendered by it fees ranging from $1,500 to approximately $2,500,000. MCO and MIS also maintain policies and procedures to address the independence of MIS s ratings and rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold ratings from MIS and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, is posted annually at under the heading Shareholder Relations Corporate Governance Director and Shareholder Affiliation Policy. Any publication into Australia of this document is by MOODY S affiliate, Moody s Investors Service Pty Limited ABN , which holds Australian Financial Services License no This document is intended to be provided only to wholesale clients within the meaning of section 761G of the Corporations Act By continuing to access this document from within Australia, you represent to MOODY S that you are, or are accessing the document as a representative of, a wholesale client and that neither you nor the entity you represent will directly or indirectly disseminate this document or its contents to retail clients within the meaning of section 761G of the Corporations Act Notwithstanding the foregoing, credit ratings assigned on and after October 1, 2010 by Moody s Japan K.K. ( MJKK ) are MJKK s current opinions of the relative future credit risk of entities, credit commitments, or debt or debt-like securities. In such a case, MIS in the foregoing statements shall be deemed to be replaced with MJKK. MJKK is a wholly-owned credit rating agency subsidiary of Moody's Group Japan G.K., which is wholly owned by Moody s Overseas Holdings Inc., a wholly-owned subsidiary of MCO. This credit rating is an opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or any form of security that is available to retail investors. It would be dangerous for retail investors to make any investment decision based on this credit rating. If in doubt you should contact your financial or other professional adviser. 15 POLICY FOR SECURITIES TRADING FOR EMPLOYEES LOCATED OUTSIDE THE U.S.

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