MCO Code of Ethics

[Virtual Presenter] MCO employees are expected to uphold high standards of personal behavior when conducting company business. Integrity, honesty, and personal responsibility serve as the foundation of MCO's business practices. The code outlines MCO's ethics policies, which are not exhaustive statements of professional conduct. Employees should consult their managers or HR department for clarification on any questions or issues. Senior management is accountable for ensuring compliance with legal and ethical obligations, and that all personnel adhere to the policy. Managers at every level are responsible for educating and training those under their supervision on the policy. All employees share responsibility for the policy's success and must utilize it to report any suspected misconduct or wrongdoing. This policy is not a contractual obligation and may be modified at any time..

[Audio] As part of our compliance requirements, we are responsible for reporting certain information about our personal finances and business activities. We must disclose any individuals who receive primary financial support from us, or for whom we provide discretionary advisory services. Additionally, we need to disclose any trusts or arrangements that benefit us, or any entities in which we have a significant beneficial interest or exercise control. These disclosures help ensure transparency and prevent conflicts of interest. By providing this information, we maintain the highest standards of personal behavior and uphold the principles of integrity, honesty, and personal responsibility that guide our business practices..

[Audio] The Firm and its associated persons are prohibited from trading on or disclosing material non-public information to persons outside the Firm. While in possession of material, non-public information about an issuer, we shall not buy or sell securities for our personal accounts or for accounts in which we have a beneficial interest or over which we have the power directly or indirectly to make investment decisions. We also cannot disclose that information or any conclusions based thereon to any person other than the Chief Compliance Officer of the Firm. Additionally, all associated persons of the Firm shall certify annually that they understand and will comply with the insider trading provisions contained in the Code of Ethics and Written Supervisory Procedures of the Firm..

[Audio] No reports are required for transactions that occur automatically according to an investment plan. Nevertheless, if a transaction deviates from the predetermined schedule or allocation of the automatic investment plan, it needs to be reported every quarter. Furthermore, no reports are necessary for securities held in accounts where the Covered Person has neither direct nor indirect influence or control..

[Audio] MCO discourages participation in corporate hospitality events and in the giving or receiving of gifts, as this can create potential conflicts of interest and biases in dealings with outside suppliers and external relationships. Gifts and gratuities received should be referred to the Conflict of Interest policy. No gifts or gratuities with a value exceeding $100 per calendar year can be given to or from any current or prospective vendor, customer, or supplier of MCO. When calculating the $100 limit, the value of all gifts and gratuities given by the same company or individual during the year must be aggregated. If there is any doubt about the value of a gift or gratuity, discussion with your manager before its provision is recommended. All gifts and gratuities given, excluding those of nominal value like calendars, diaries, pens, and pencils, must be reported to your manager. Business meals, tickets to theatrical productions, and sporting events are exempt from the above limit, but their frequency should not be excessive enough to raise suspicions. Occasionally, business requirements may necessitate working beyond contractual hours, and outside activities should not hinder fulfillment of this obligation. For further clarification on outside business relationships, consult your manager or the CEO..

[Audio] It is essential to maintain high ethical standards in our business dealings. We have established controls to ensure our operations are conducted in an ethical and compliant manner. Our anti-bribery and corruption policy applies globally, covering all countries and territories where we operate. We define bribery as the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. We take a zero-tolerance approach to bribery and corruption, committing to act professionally, fairly, and with integrity in all business dealings and relationships. We implement and enforce effective systems to counter bribery, upholding all relevant laws in the jurisdictions where we operate. Failure to comply with anti-bribery regulations could result in severe consequences, including fines and reputational damage. Exercise caution when engaging in business activities, particularly when attending events or interacting with third-party individuals. Prior approval from your manager is required for major events, ensuring the value involved aligns with business needs. We encourage open communication and transparency in all our interactions, promoting a culture of integrity and accountability within our organization..

[Audio] Employees must not engage in any form of bribery, either directly or through any third party. Specifically, they must not bribe a public official anywhere in the world. Facilitation payments are a type of bribery made to expedite or facilitate a public official's performance of a routine governmental action, and not to gain or maintain an improper business advantage. The company strictly prohibits facilitation payments. However, in exceptional circumstances where an employee's personal security is at risk or that of their family, and a facilitation payment is unavoidable, specific steps must be taken: the amount paid should be kept to a minimum, a record must be created, and the payment reported to a line manager. Political contributions are prohibited because they can be seen as an attempt to gain an improper business advantage. Charitable contributions are acceptable, but only if they comply with local laws and practices. No donation on behalf of the organization can be made without the prior approval of a member of the Leadership Team..

[Audio] All employees must keep accurate records of gifts received or offered and submit expenses claims according to our expenses policy. If you have any concerns or suspicions about potential malpractice, including bribery or corruption, please report them to your line manager immediately. If you're unsure whether an act constitutes bribery or corruption, or have any other queries or concerns, consult our Whistleblowing Policy. It's vital to report any instances of bribery or corruption promptly, and we'll provide support to anyone who raises genuine concerns in good faith..