1. Purpose

The purpose of this Policy is to ensure that Inrate AG’s ESG rating activities are conducted with integrity, independence, objectivity, transparency, responsibility and sound governance, and that any actual, potential or perceived conflicts of interest are prevented, identified, disclosed, mitigated and documented, to ensure full compliance with all relevant laws and regulations, in particular Regulation (EU) 2024/3005.

2. Scope

This policy applies to all directors, officers, employees, secondees, temporary staff, contractors, and any other persons acting on behalf of Inrate AG in relation to ESG rating activities, as well as all members of senior management of Inrate AG (“Covered Persons”).

3. Core Principles

Inrate AG keeps and maintains the following principles:

• Independence: ESG rating activities are carried out independently from commercial pressure, ownership influence, advisory incentives or external interference.
• Separation: Where Inrate AG conducts business activities other than ESG ratings, it maintains effective organizational and operational separation sufficient to prevent conflicts of interest between those business activities and its ESG ratings activities.
• Transparency: Inrate AG discloses methodologies, sources, assumptions, objectives, limitations and relevant governance information in the manner required by the relevant laws and regulations.
• Integrity of process: ESG ratings which are developed and distributed by Inrate AG are based on documented methodologies, controlled data processes, and governance arrangements that can be reviewed and audited.
• No influence by rated entities:Rated entities are given limited factual verification opportunities where required, but they may not influence methodology, criteria, assumptions or weightings.

4. Policy Objectives

The objective of this Policy is to ensure that ESG Ratings produced by Inrate AG are not distorted by commercial, ownership, advisory, political, operational, technological, personal or group-level influences, to avoid conflicts arising from, among other things:

• simultaneous provision of consulting, advisory, credit rating, benchmark, data, analytics or other services to rated entities, subscribers, investors or related counterparties;
• ownership links, shared control, common management, revenue dependency, or significant influence relationships within the group or with rated entities;
• access by commercial staff to methodology development, model tuning, pre-publication ratings or rating changes;
• incentives or remuneration structures that link pay, promotion or performance evaluation to rating outcomes, commercial wins, or retention of rated entities;
• use of shared personnel, systems, reporting lines or working environments with other services where such arrangements impair or could appear to impair independence; and
• any attempt by a rated entity, investor, distributor, shareholder, affiliate or internal business sponsor to influence data selection, factor weighting, methodology design or the rating result.

Inrate AG is committed to maintaining an organizational framework capable of demonstrating this on an ongoing basis.

Inrate AG shall make all disclosures required under Regulation (EU) 2024/3005 and any applicable delegated acts or regulatory technical standards, including disclosures to the public, users, rated items and issuers.

Such disclosures shall include, where required, information relating to:

• conflicts of interest and the measures taken to prevent, manage or mitigate them;
• organizational arrangements and governance structures;
• methodologies, models and assumptions;
• data sources and their limitations; and
• material changes to methodologies and rating processes.

5. Separation of Business and Activities

General Rule: Where Inrate AG carries out activities other than ESG rating activities, it maintains effective organizational, operational and decision-making separation sufficient to prevent conflicts of interest and to demonstrate its independence.

Inrate AG does not carry out any activity that is prohibited from being combined with ESG rating activities under Regulation (EU) 2024/3005 and any applicable delegated acts or regulatory technical standards.

Where Regulation (EU) 2024/3005 permits the provision of other activities subject to the implementation of safeguards, Inrate AG shall ensure that:

• such activities are only performed where all regulatory conditions are satisfied;
• a documented conflict of interest assessment is conducted prior to commencing such activity or entering into any relevant contractual arrangement;
• all required organisational, operational, and technical separation measures, including those specified in applicable regulatory technical standards, are implemented and maintained on an ongoing basis.

Inrate AG implements and maintains the following separation measures:

• Separate organizational structure for ESG rating activities, including distinct reporting lines and management oversight;
• Separate working environment for persons involved in ESG rating activities from any persons engaged in other business activities that may give rise to conflicts of interest;
• Restricted, role-based access controls to systems, models, datasets, workpapers and pre-publication rating outputs;
• Physical and/or effective operational separation, including where appropriate separate office space or equivalent safeguards;
• Documented pre-engagement and pre-launch conflict assessments for any new service, product, or contractual relationship;
• Periodic written self-declarations from Covered Persons confirming non-involvement in activities that may create conflicts of interest, as required by applicable regulatory technical standards;
• Additional technical and internal control measures where Inrate AG carries out activities subject to enhanced regulatory safeguards (including, where applicable, investment services, insurance activities, benchmarks or similar regulated activities); and
• Ongoing monitoring, testing and review of separation arrangements by the Independent Compliance Function.

6. Methodology, Model and Rating Governance

Every ESG rating distributed by Inrate AG is based on a defined methodology and ranking system. Methodologies, assumptions, objectives, data sources and limitations are documented, reviewed and disclosed as required.

Material changes to methodologies or assumptions are:

• reviewed by the Product and Methodology Committee;
• approved by the Head of Methodology based on the recommendation of the Product and Methodology Committee;
• documented with reasons;
• tested for conflict impacts by the Legal & Compliance Department; and
• where applicable, reflected in required public, user or rated-item disclosures.

7. Rated Entity Interaction and Factchecking

Inrate AG notifies all rated entities of the fact that they are a part of Inrate AG's rated universe. This notification is usually made 21 days, and under no circumstances later than two (2) days before the first distribution of any ESG rating relating to that specific rated entity.

The notification includes a link to a form on our website, where all entities rated by Inrate AG can access the dataset underlying their ESG rating, to inform Inrate AG of any factual errors in that dataset. Inrate AG does not provide rated entities access to the ESG rating it plans on distributing.

The Head of Quality & Improvement ensures that any feedback by rated entities is reviewed within 30 days and documents any actions taken by Inrate AG based on such feedback. Any interaction with rated entities is strictly limited to correction of factual inaccuracies, to ensure that rated entities cannot influence methodology, factor selection, weighting, and/or assumptions.

All rated entity interaction, notification, and factual verification processes are conducted strictly in accordance with Regulation (EU) 2024/3005 and applicable delegated acts or regulatory technical standards.

Under no circumstances shall such processes permit rated entities to influence ESG rating methodologies, assumptions, weighting, or outcomes.

8. Remuneration and Incentives

Compensation for staff engaged in ESG rating activities is determined strictly in line with Inrate AG's Remuneration Policy. The Remuneration Policy of Inrate AG does not link pay, promotion or performance evaluation of staff engaged in ESG rating activities to rating outcomes, commercial wins, or retention of rated entities. Any changes to the Remuneration Policy need to be reviewed and approved by the Legal & Compliance Department to ensure continued compliance with this Policy.

9. Restrictions on Trading

Covered Persons are prohibited from buying or selling any financial instrument issued, guaranteed or otherwise supported by any entity rated by Inrate AG or by any entity within the same group an entity rated by Inrate AG, nor engage in any transaction in such financial instruments, with the exception of holdings in diversified collective investment schemes, including managed funds, and of investments made under discretionary portfolio management.

10. Personal Conflicts, Gifts and Outside Interests

Covered Persons must disclose any personal, financial, family, employment, board, advisory or other relationship that may create an actual, potential, or perceived conflict with ESG rating activities to the Legal & Compliance Department. The Independent Compliance Function will assess the issue and may require recusal, restricted access, additional separation measures, suspension of work, methodology review, disclosure, remediation of public statements, or other corrective action.

Covered Persons are prohibited from:

• accepting gifts, hospitality, benefits or inducements that could influence, or appear to influence, the integrity of Inrate AG's ESG rating activities;
• using confidential rating information for personal benefit or for the benefit of third parties;
• participating in ESG rating decisions or methodology approvals where they have a personal conflict; or
• holding outside positions or mandates that compromise the integrity, credibility or independence of Inrate AG's ESG rating activities;
• using ESG rating activities to market, cross-sell or support consulting or advisory mandates that compromises rating independence;
• allowing commercial staff to determine, pressure, review or veto ESG rating outcomes, methodologies, or publication timing;
• permitting methodology, model, dataset or weighting changes to be driven by commercial opportunities, client pressure, issuer engagement or investor preferences rather than documented analytical reasons;
• permitting rated entities to influence the methodology or rating outcome under the guise of factual verification; the Regulation expressly states that dataset verification is a fact-checking tool only and must not permit influence over methodology or rating outcome;
• disclosing confidential pre-publication rating information except as permitted for internal governance and legally required pre-issuance fact-checking processes.

11. Training and Annual Certification

Covered Persons will receive initial and periodic training on:

• regulatory requirements impacting ESG Ratings providers;
• conflicts of interest and separation of activities;
• methodology governance and disclosure obligations;
• rated-item interaction and factual verification protocols; and
• recordkeeping and escalation requirements.

Covered Persons shall certify at least annually that they:

• have read and understood this Policy;
• have disclosed all relevant conflicts;
• have complied with trading, separation and confidentiality requirements; and
• will promptly notify Legal & Compliance of any change in circumstances.

12. Independent Compliance Function

The Legal & Compliance Department of Inrate AG maintains an Independent Compliance Function to which it allocates resources that are sufficient in light of the scale, complexity and risk profile of its ESG rating activities, and in any case no less than 0.5 FTE. The Independent Compliance Function is responsible for identifying, assessing and monitoring conflicts of interest, overseeing separation controls, maintaining records, as well as reporting material issues to the Managing Director and/or the Board of Directors of Inrate AG.

The Managing Director is responsible for ensuring that the Independent Compliance Function has the authority, expertise, resources and access necessary to perform its duties, as well as ensuring that the Independent Compliance Function has a direct and unrestricted reporting line to the Board of Directors.

13. Escalation, Breach Management and Remediation

Covered Persons must escalate any actual, potential or perceived conflict of interest, breakdown in separation controls, inappropriate commercial influence, methodology integrity concern, or rated-item influence attempt to the Independent Compliance Function immediately. The Independent Compliance Function will assess the issue and may require recusal, restricted access, additional separation measures, suspension of work, methodology review, disclosure, remediation of public statements, or other corrective action.

Material breaches must be reported by the Independent Compliance Function to the Board of Directors of Inrate AG. Where law or supervisory expectations require it, Inrate AG shall notify the relevant authorities or reflect the matter in authorization or ongoing supervisory communications.

14. Data Retention

Inrate AG retains all information referred to in Annex I and II of Regulation (EU) 2024/3005 for at least five years, in such a form that it is possible to replicate and fully understand the determination of an ESG rating.

Inrate AG ensures that all conflict of interest assessments, mitigation measures, separation controls, and related decisions are fully documented and auditable, such that compliance with Regulation (EU) 2024/3005 can be demonstrated to the relevant authorities upon request.

15. Oversight

The Independent Compliance Function is responsible for overseeing and ensuring compliance with this Policy, as well as maintaining a centralized Conflict of Interest Register, recording all identified conflicts, their classification (actual/potential/perceived; material/non-material), mitigation measures, and resolution status.

Inrate AG shall identify, assess and document conflicts of interest on an ongoing basis, including at a minimum in the following situations:

• prior to accepting any new client engagement, subscription or contractual relationship;
• prior to assigning Covered Persons to ESG rating activities, methodology development, or rating approval processes;
• prior to implementing any material change to methodologies, models, data sources, assumptions or weightings;
• upon any change in ownership structure, control, or relationships involving shareholders, affiliates or other entities with significant influence; and
• on a periodic basis, as determined by the Independent Compliance Function.

All identified conflicts shall be recorded in the Conflict of Interest Register and assessed for materiality, with appropriate mitigation measures implemented and documented.

The Independent Compliance Function, together with the Board of Directors, shall ensure that any shareholder, parent undertaking, subsidiary, affiliate or other person exercising direct or indirect significant influence over Inrate AG is assessed for potential conflicts of interest.

Where such relationships create conflicts of interest that cannot be effectively prevented or managed in accordance with Regulation (EU) 2024/3005, Inrate AG shall take appropriate remedial action, including restructuring, restriction of activities, or termination of the relevant arrangement.

Conflicts arising from shareholders, parent undertakings, subsidiaries or other affiliated entities are assessed at least annually and upon any material change in ownership structure.

The Board of Directors retains ultimate responsibility for ensuring that conflicts of interest are effectively managed.

16. Review of Policy

This Policy will be reviewed by the Legal & Compliance Department at least annually and whenever there is:

• a material change to Inrate AG's business model;
• a restructuring within Inrate AG's staffing model;
• new regulatory developments; or
• any significant incident affecting ESG rating independence or transparency.

All changes to this Policy are subject to final approval by the Board of Directors of Inrate AG.