Independence and Avoidance of Conflict of Interest
- Rating actions are to be taken as deemed appropriate based on factual information and determination of applicable rating criteria.
- Foresight Analytics and its employees will exhibit professionalism and act in an independent and objective manner in completing analysis and determining ratings
- Ratings will be based on published rating methodology using publicly available information and any additional data supplied by clients.
- Ratings assigned to counterparties, fixed income products and debt securities will not be influenced by existing or potential commercial relationships.
B. Procedures and Policies
- The activity of Foresight Analytics and the engagement of analysts to complete ratings will be conducted in a manner to avoid any actual or potential conflicts of interest. The management of potential conflicts will be monitored by the Board and through relevant disclosure.
- Foresight Analytics will evaluate and monitor any actual or potential conflicts of interest at the time of client engagement and throughout the rating process. Disclosure of any conflict and the materiality of the conflict will be advised on rating reports and disclosed in a timely manner on the company’s website.
- Where applicable Foresight Analytics will disclose the general nature of its rating fees paid by issuers requesting a rating.
- Analysts are not permitted to trade in securities or derivatives in rated entities which represent a conflict of interest.
- Any analyst involved in liaising with Federal Government regulators will not be involved in rating assessment of the Federal Government.
C. Analyst and Employee Independence
- Analyst remuneration will be based on a standard remuneration contract.
- Analysts will not be directly involved in the negotiation of fees.
- Analysts will not be assigned to rate entities in which they have direct and personally material investment in the entity (or related entity) which could influence the determination of the rating. This does not preclude an analyst’s participation where the investment is through a diversified collective investment scheme. Further analysts are not to be assigned to rate an entity for whom they, or an immediate family member, have worked or have a significant business relationship in the last six months.
- Analysts (or their spouse, partner or minor children) will not be permitted to invest or trade in securities or derivatives of any entity whose rating falls within the analyst’s area of responsibility.
- Analysts will be subject to the Foresight Analytics Gift and Entertainment policy which requires entertainment and gifts for a value greater than $250 to be disclosed and recorded on the Foresight Analytics Gift and Entertainment register.
- Any personal relationship with an employee of a rated entity will be disclosed to the Managing Director where the nature of the person’s role in the organisation is of significance in the rating of the organisation.
- Foresight Analytics will review the past work of analysts that leave the company and join a rated organisation that the analyst has been involved in rating, or a financial services firm which the analyst has had significant dealings as part of the analyst’s duties.
Date Updated: 15th March 2021