To perform its ESG rating activities in a fair and faithful manner from an independent perspective, KCGS prescribed principles to manage conflicts of interest as part of its internal control standards, separated departments and human resources between the activities with potential conflicts of interest, such as ESG rating activities and proxy and responsible investment advisory service, and put in place guidelines on the prevention of conflicts of interest to prevent and manage conflicts of interest.

KCGS complies with the following standards to prevent conflicts of interest relating to companies targeted for ESG ratings and their affiliates, clients of proxy and responsible investment-related advisory service of KCGS and their respective affiliates, member organizations of KCGS, and the executives and employees of each organization mentioned above (collectively referred to as “interested persons” hereinafter) and those arising from a special relationship of an officer or employee of KCGS with a rated company.

  • 1. Prohibition of Conflict of Interest Activities Concerning Interested Persons KCGS and its officers and employees do not accept any undue exercise of influence or private benefits from interested persons with regard to the affairs of KCGS.
  • 2. Prohibition of Conflict of Interest Activities Concerning Proxy and Responsible Investment Advisory Service KCGS and its officers and employees do not perform ESG rating activities against clients, do not involve advisory personnel in ESG rating activities, and do not engage in any other activities that may cause a conflict of interest to clients, etc. in relation to rating activities, or that may be mistaken as such.
  • 3. Prohibition of Conflict of Interest Activities Concerning Rated Companies KCGS and its officers and employees do not engage in any commercial activities under any pretext, including the provision of ESG advisory and consulting services for a fee for the companies in the scope of the ESG rating of KCGS,and are not provided with any pecuniary benefits by the rated companies, their affiliates, their respective executives and employees, etc. without legitimate legal grounds.
  • 4. Prohibition of Conflict of Interest Activities Concerning Member Organizations KCGS and its officers and employees do not perform ESG rating activities against the member organizations of KCGSand their affiliates and do not exchange information that may cause a conflict of interest with ESG rating activities with member organizations.
  • 5. Removal from Work of Officers and Employees in a Special Relationship KCGS removes an officer or employee who has a special relationship with a rated company from the duties concerning the pertinent rated company to prevent a conflict of interest arising from the performance of the duties by an officer or employee who has a special relationship (employment, financial investment instrument holdings, credit transactions, etc.) with a rated company.
  • 6. Restriction on Trading of Financial Investment Instruments and Monitoring KCGS has compliance requirements and a trading restriction period with regard to the trading of restricted stocks, etc. by the personnel involved in rating activities and monitors trading details periodically.

Led by the compliance officer, KCGS periodically monitors the compliance of the guidelines on the prevention of conflicts of interest, takes measures necessary to mitigate the likelihood of a conflict of interest by reviewing reports relating to conflicts of interest, if any, and provides regular training for the officers and employees to learn about prohibitions and obligations to help prevent and manage conflicts of interest.

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KCGS

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