MOODY'S CORPORATION
Policy Regarding the Independence of Ratings and Disclosure of Affiliations of Moody's Directors and Shareholders with Rated Entities
It is the policy of Moody's Investors Service, Inc. ("MIS") and its parent corporation, Moody's Corporation ("MCO"), that MIS's rating opinions and research should reflect a completely independent assessment of relative credit risk produced by MIS's professional analytical staff. In order to avoid the appearance of inappropriate influence over or involvement with the credit rating process, it is MCO's long-standing policy that MIS personnel shall not disclose or discuss potential or pending rating actions or market-sensitive rating policies with external parties, including non-employee shareholders and non-employee members of MCO's board of directors, unless and until that information has been publicly disclosed. Exceptions to this policy with respect to disclosures to MCO's board of directors (or a committee thereof) of a potential rating action or change in rating policy may only be made if MCO's Chief Executive Officer determines in the particular case that an exception is necessary in furtherance of the establishment of corporate policy and the disclosure and rationale therefor is documented with MCO's General Counsel.
In order to allow interested parties information regarding known affiliations of MCO directors with rated entities, and rated entities that also have publicly reported to the SEC an ownership interest in MCO of more than 5%, such affiliations and interests shall be publicly disclosed on MIS's website (moodys.com) and updated on an annual basis.
An appropriate reference to this policy shall be included with ratings and research published by MIS.
Affiliations of Moody's Directors and Shareholders with Rated Entities
As of June 1, 2009, members of the MCO board of directors serve as officers, directors or faculty members of the following rated entities:
Basil L. Anderson
Becton, Dickinson and Company (director)
Hasbro, Inc. (director)
Staples, Inc. (director)
Darrell Duffie
Stanford University (faculty member at the Stanford Graduate School of Business)
Robert R. Glauber
Freddie Mac (director)
XL Capital LTD (director)
Ewald Kist
DSM N.V. (director)
Royal Philips Electronics (director)
Connie Mack
Darden Restaurants, Inc. (director)
H. Lee Moffitt Cancer Center (director)
Mutual of America Life Insurance Company (director)
Henry A. McKinnell, Jr.
Angiotech Pharmaceuticals, Inc. (director)
Nancy S. Newcomb
The DIRECTV Group (director)
Sysco Corporation (director)
John K. Wulff
Celanese Corporation (director)
Sunoco, Inc. (director)
During the calendar year ended December 31, 2008, the following entities (directly or through subsidiaries or sponsored entities) held credit ratings from MIS and also publicly reported to the SEC an ownership interested in MCO of more than 5%.
Berkshire Hathaway Inc. – 20.4%
MIS maintains policies and procedures to address the independence of its rating process in light of such affiliations.
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