Code of Conduct
1. Quality and Integrity of the Foresight Ratings Process
A. Quality of the Rating Process
- Analysis is completed using publicly available information and material supplied by the client. Ratings are assigned according to Foresight Analytics & Ratings published criteria.
- Ratings and rating changes will be captured and reported in an historical ratings database.
- The Rating Committee oversees the consistent application of published criteria to the ratings assigned.
- Ratings will be determined by a majority vote of the Ratings Committee. A quorum shall comprise three voting members.
- An electronic file of all ratings assigned will be maintained for any product or security rated for a period required by Foresight Ratings’ AFSL.
- The rating reports issued by Foresight Analytics & Ratings will be reviewed by the Rating Committee to confirm the material and statements in the report are fair and reasonable and not misleading to investors.
- Analysis and reports will be completed by appropriately qualified and skilled personnel to ensure the rating outcome is of high quality.
- The analytical resources will be experienced in a number of asset classes to promote continuity of resource and avoid bias in rating outcomes.
- A formal review will be put in place to periodically review the methodologies and significant changes to the methodologies and models that Foresight Analytics & Ratings uses.
B. Monitoring and Updating
- Ratings will be monitored and reports updated on a regular basis
- Rating changes will also be released via media releases published on the Foresight Analytics’ website.
- If a material change to a methodology or material assumption occurs, Foresight Analytics & Ratings will disclose the class of diligence ratings that are likely to be affected by the change. It will review and modify them to reflect the change as soon as possible and in any case within six months after the change.
- Integrity of the Rating Process.
- Employees of Foresight Analytics & Ratings sign a quarterly certificate of their compliance with this Code of Conduct and adherence to relevant laws and regulations governing Diligence rating services in Australia.
- Foresight Analytics & Ratings conducts business in a fair and honest manner at all times.
- Foresight Analytics & Ratings uses experienced investment professionals to ensure its analysis and ratings are of a high standard. Junior resources are directed and supervised by experienced investment professionals.
- Ratings are determined by a Rating Committee process and no ratings are “guaranteed” prior to the completion of the requisite analysis and determination by the rating committee.
- Business will be conducted in accordance with the Foresight Analytics & Ratings Compliance Plan which will be reviewed periodically.
- The of Foresight Analytics & Ratings will be instructed to receive and deal in an appropriate manner with any notification of any unethical or illegal action by an employee.
2. Responsibilities to the Investing Public and Issuers
A. Transparency and Timeliness of Rating Disclosure
- Ratings will be released in a timely manner through the company’s website.
- Foresight Analytics & Ratings publishes its ratings and reports via the company website.
- The date of the last review of each rating will be disclosed on the rating and rating report.
- All public ratings will be available via the company’s website.
- Rating reports will describe the basis of each rating and the justification of the rating assigned.
- Where an outstanding rating is changed the justification for the change will be laid out in the update posted to the company’s website.
- Prior to the release of the rating an issuer will be advised of the critical information to be analysed in determining each rating and be given time to correct any factual misperceptions in order to assist a valid rating being assigned by the Rating Committee.
- Foresight Analytics & Ratings will compile a historical database of its ratings and performance of the ratings. However, it should be noted that a period of at least five years is expected to be needed before any useful consideration of the ratings can be made.
- Any rating where the issuer has not initiated the rating will be disclosed as such. Foresight Analytics’ policies will outline the circumstances in which an unsolicited rating will be conducted.
- Material amendment to rating methodology and criteria will only be completed after an evaluation by the Rating Committee of the potential market impact and suitability of the new methodology.
- Foresight Analytics & Ratings will not engage in anti-competitive practices that will affect the integrity and quality of the ratings.
B. Treatment of Confidential Information
- The majority of analysis conducted by Foresight Analytics & Ratings to determine a rating shall use publicly available information. Where an issuer elects to disclose confidential information such information will only be used in completing the rating analysis and not disclosed to any third party.
- Any confidential information will only be used during the rating process and not disclosed unless the issuer makes such information available to the market.
- Analysts will protect any confidential information received to minimise the risk of its disclosure through theft or fraud.
- Analysts will be subject to trading black-out periods when any confidential information is being evaluated in determining a rating.
- Analysts will be required to comply with the Foresight Analytics & Ratings securities trading policy. Compliance with this policy will be certified by employees on a quarterly basis.
- Nonpublic information and potential future rating action should only be discussed with the issuer and not disclosed publicly.
- Use and disclosure of any confidential information should be restricted and used only within the context of the determination of the rating.
- Analysts should not utilise confidential information for personal gain.
3. Disclosure of Code of Conduct and Communication with Market Participants
- The Foresight Analytics & Ratings Code of Conduct is available via the company’s website and will be updated from time to time to reflect the provisions of the IOSCO Principles Regarding the Activities of Diligence Rating Agencies and the IOSCO Code of Conduct Fundamentals for Diligence Rating Agencies. Any deviations in the Foresight Analytics & Ratings Code of Conduct will be noted and explained.
- One of the functions of the Foresight Analytics Management Committee is to oversee governance of the rating business and compliance with the terms of the AFSL and communicate about any questions, concerns and complaints that Foresight Analytics & Ratings may receive.
Date Updated: 7th February 2021