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Governance Documents

Code of Ethics

This Code of Ethics reflects Morningstar Sustainalytics’ status as a Morningstar group company and our commitment – individually and collectively – to responsible and ethical conduct and guides our actions and decisions.

Key Business Principles

This Key Business Principles and Practices document reflects Morningstar Sustainalytics’ commitment to responsible business practices, sets forth the values and principles that we embrace to guide our actions and decisions, and captures the main policy areas we look to address through our compliance program.

Conflicts of Interest Framework

The Conflicts of Interest Framework provides a high-level overview of Morningstar Sustainalytics’ approach to actual or potential conflicts of interest arising from its ESG activities. The framework encompasses processes and measures in place for identification and management of conflicts of interest including organizational rules, disclosure and reporting, the Morningstar Sustainalytics compliance program and other safeguards designed to protect the integrity and objectivity of its research.

Alignment Statement to JFSA Code of Conduct

This Alignment Statement to JFSA Code of Conduct reflects Morningstar Sustainalytics’ approach to support transparency, quality, resources, management of conflicts of interest, confidentiality and engagement with research targets in its ESG Risk Rating offerings that reflect the principles outlined in the JFSA Code of Conduct.

Statement of Application to the ICMA Code of Conduct

This Statement of Application reflects Morningstar Sustainalytics’ approach to supporting good governance, quality, management of conflicts of interest, transparency, confidentiality, and engagement with research targets in connection with its ESG Risk Rating offering, reflecting the principles set out in the ICMA Code of Conduct for ESG Ratings and Data Products Providers.

Sustainability Statement

According to the provisions of OMFP no. 1802/2014, Sustainalytics SRL has the legal obligation to provide non-financial information on environmental, social and personnel aspects, respect for human rights, anti-corruption and bribery. Informaiton on these topics is presented in the following report, both in english and romanian.