Policy for Investment and Trading in Securities

Beacon Ratings:

• Employees will exhibit honest and ethical conduct, including avoidance of potential or perceived conflict of personal and professional interests and insider trading.
• Employees are subject to specific limitations on securities ownership and prohibition against relationships that may give rise to a potential conflict of interest in the conduct of their credit ratings work.
• Rating Committee member will not take undue material advantage of any confidential information received through their participation in rating process.
• Rating Analysts or Rating Committee members shall disclose conflict of interest to the Compliance Officer and shall not participate in any manner in formulating or arriving at a rating.