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Code  of Conduct Code  of Conduct

 

DEFINITIONS
For the purposes of this document, the terms below shall have the following meanings:

An “Analyst” is an employee whose primary function is to participate in the process of credit rating analysis.

“Confidential Information” relates to such information relied upon, and/or provided by the rated Issuer or its advisor/arranger/sponsor/promoter, for the purposes of arriving at a credit rating, unless such information:

is already known to WASO Ratings free of any confidentiality obligation at the time it is obtained;
or becomes publicly known through no wrongful act of WASO Ratings;
or is rightfully received by WASO Ratings from a third party.

Confidential Information also includes: matters arising from any internal discussions in reaching a rating action; information concerning the rating committee process, including, but not limited to the voting decisions and voting members that deliberated; and information concerning the content or timing of a pending rating action prior to public dissemination.

A “Credit Rating” is WASO Ratings’ current opinion on the overall creditworthiness of a particular Issue or an Issuer’s capacity to meet its financial obligations. Credit Ratings are determined by a rating committee and expressed using WASO Ratings’ established “AAA” to “D” and “P1” to “NP” alphanumerical rating scale, or other rating scales as published from time to time by WASO Ratings.

An “Issuer” is any entity that issues a debenture, Islamic securities, private debt securities, a credit commitment or debt-like securities.

An “Issue” includes debentures, Islamic securities, and private debt securities such as bonds, loan stocks like preference share and commercial papers, whether convertible into equity or not and whether redeemable or otherwise.

CRA” is the abbreviation for “credit rating agency”.

 

Meaning of Credit Ratings

Credit Ratings are WASO Ratings’ current opinions regarding the relative creditworthiness of Issuers or Issues, and are not verifiable statements of fact. Credit Ratings do not constitute investment or financial advice, and are not recommendations to purchase, sell, or hold particular securities. Credit Ratings do not comment on the suitability of an investment for any particular investor.

WASO Ratings’ Credit Ratings are based on information furnished by the Issuer or its agents and advisors (e.g. auditors, legal counsel, consultants and other experts) and information obtained by WASO Ratings from sources believed by WASO Ratings to be accurate and reliable. WASO Ratings relies on Issuers and their agents to provide accurate, timely and complete information in connection with the rating and surveillance processes.
WASO Ratings has no obligation to perform, and does not perform, due diligence or independent verification of information it receives or obtains in connection with the rating process, nor does WASO Ratings conduct any audit as to the completeness of such information. The assignment of a Credit Rating by WASO Ratings should not be viewed as a guarantee of the accuracy, completeness, or timeliness of the information relied on in connection with the rating or the results obtained from the use of such information.

WASO Ratings maintains independence in its relationships with Issuers and other interested entities. WASO Ratings does not act as an investment, financial or other advisor to, and does not have a fiduciary relationship with the Issuers it rates. WASO Ratings does not participate in the actual structuring of any security it rates, but may comment on the potential credit implications of the proposed structural elements of a security.

Code of Conduct Provisions

1.0      Quality and Integrity of the Rating Process

Quality of the Rating Process

1.1     Ratings are WASO’s opinions about future creditworthiness, based on past performance. They do not provide a guarantee of future performance of the rated entity or instrument. The performance of ratings should instead be assessed on whether they have been assigned in accordance with WASO’s methodologies and established policies and procedures.

1.2     WASO will utilize rating methodologies and criteria that are rigorous, systematic and, where possible, that result in ratings that can be subjected to some form of objective validation based on historical experience.

1.3     The rating analysis and any rating action shall be based upon criteria and methodologies established by WASO. Each credit rating report shall have reference to the particular methodology that has been followed. Analysts shall apply a given criteria or methodology in a consistent manner, as determined by WASO.

1.4     Ratings shall be assigned by Rating Committee of WASO and not by any individual analyst employed by WASO. WASO shall form a Rating Committee comprised having at least of five members including two senior analysts having appropriate knowledge and experience. The Rating Committee shall have adequate access to information and the authority to make independent decisions. Credit Ratings will reflect all information known, and believed to be relevant, by the applicable WASO Ratings’ Analysts and rating committee, in a manner generally consistent with WASO Ratings’ methodologies. WASO Ratings will employ Analysts who, individually or collectively, have appropriate knowledge and experience in developing rating opinions for the type of credit being analyzed. WASO shall have no obligation to verify or audit any information provided to it from any source or to conduct any investigation or review, or to take any other action, to obtain any information that has not otherwise been collected by WASO.
1.5     The CRC shall maintain internal records including workings of the analysts and proceedings of the Rating Committee meetings concerning its rating decisions for a period of at least five years after expiry of validity of the concerned rating.

1.6     WASO shall take steps to avoid issuing any credit analyses or reports that knowingly contain misrepresentations or are otherwise misleading as to the general creditworthiness of any company.

1.7     WASO shall ensure that it can devote sufficient resources to carry out high-quality credit assessments of each company. WASO shall adopt reasonable measures so that the information it uses in assigning a rating is of sufficient quality to support a credible rating. If the rating involves a type of structured financial product presenting limited historical data (such as an innovative financial vehicle), WASO shall disclose, clearly and in a prominent place, as a limitation of credit rating.

1.7-1   WASO shall establish and implement a rigorous and formal review body (initially entrusted on Rating Committee) responsible for periodically reviewing the methodologies and models and significant changes to the methodologies and models it uses. Rating Committee of CRC shall review the rating criteria, methodology and models at least once in every year and shall amend the rating methodology if necessary.

1.7-2   WASO shall assess whether existing methodologies and models used in the process of determining ratings of companies or structured products are appropriate when the risk characteristics underlying the company have changed materially. In cases where the complexity or structure of a new type of structured product or the lack of robust data about the assets underlying the structured product raise serious questions as to whether WASO can determine a credible Credit Rating for the security, WASO will refrain from issuing a Credit Rating or express the limitation clearly.

1.7-3   In order to avoid issuing ratings on the basis of analysis or reports that contain misrepresentations or are otherwise misleading, an Internal Review Committee (IRC) comprising of appropriate professionals shall double-check the documents and information on which the analysts make ratings. In this regard it may also be mentioned that the CRC and its analysts should take steps to avoid issuing any credit analyses or reports that contain misrepresentations or are otherwise misleading as to the general creditworthiness of an issuer or obligation.

1.8     WASO Ratings will structure its rating committee and its rating teams to promote continuity and avoid bias in the rating process. For each rating assignment, WASO Ratings shall assemble a team (with a minimum of 2 members) of Analysts with appropriate training and experience. In order to maintain the integrity and objectivity of the rating process and the robustness of internal proceedings, the deliberations and the identities of persons who had participated in a rating committee shall be kept confidential and not revealed to any external party. All rating decisions shall be announced as a joint decision of the rating committee and the individual votes shall be kept confidential.

 

Monitoring and Updating

1.9     WASO shall prepare standard agreement(s) for each type of rating. The standard agreement shall contain among others, terms and conditions of the rating, rights and obligations of the parties, validity of the agreement, termination and settlement, surveillance rating, mode of payment etc. For entity rating, the agreement will cover a provision of surveillance rating for at least next three years after the initial rating. For an issue or instrument rating, WASO shall perform continuous surveillance rating for the lifetime of the instrument after the initial rating, including yearly rating.

1.10    WASO shall ensure that adequate personnel and financial resources are allocated to monitoring and updating its ratings. Once a rating is published WASO shall, in accordance with its established policies and procedures on surveillance and based solely upon information it receives from public information sources, monitor on an ongoing basis and update the rating by:

a. Regularly reviewing the company’s creditworthiness;

b. Initiating a review of the rating upon becoming aware of any information publicly disclosed that it believes might reasonably be expected to result in a rating action (including withdrawal of a rating), consistent with the relevant criteria and methodologies; and

c. Updating on a timely basis the rating, as appropriate, based on the results of any such review.

d. Where appropriate, subsequent monitoring should incorporate all cumulative experience obtained. Changes in WASO’s criteria and assumptions shall be applied, where appropriate, to both existing ratings and subsequent ratings.

1.10    WASO reserves the right to withdraw any rating at any time for any reason, including withdrawal, without notice, if a rating committee concludes that WASO lacks sufficient information to maintain the rating or that any information publicly published is deemed by WASO to be unreliable. In the event a public rating is withdrawn, WASO shall publish an appropriate commentary that includes the current rating(s) and states that the rating(s) has/have been withdrawn and that WASO will no longer provide the rating(s) or analytical coverage of the company.

Integrity of the Rating Process

1.11    WASO and its employees shall comply with all applicable laws and regulations governing its activities in each jurisdiction in which it operates.

1.12    WASO and its employees shall deal fairly and honestly with company’s, investors, other market participants and the public.

1.13    WASO analysts and automated processes shall be held to high standards of integrity, and, subject to applicable law, WASO shall not knowingly employ individuals where there is evidence that they have compromised integrity.

1.14    WASO and its employees shall not, either implicitly or explicitly, give any assurance or guarantee of a particular rating prior to the final rating decision being taken in accordance with WASO’s established policies and procedures. Nothing herein shall preclude WASO from continuing to provide rating assessments and credit assessments — that is, an assessment of creditworthiness that does not constitute a rating in that the analysis is based on hypothetical scenarios and/or limited information.

1.15    WASO’s Chief Compliance Officer and compliance staff shall oversee compliance with this Code, the policies referred to herein and all applicable laws and regulations. The Chief Compliance Officer, and any member of the compliance staff, shall not vote on any rating committees and shall not report to any party responsible for the operational management of the rating function. Their compensation shall be based solely on the quality of the relevant individual and overall company performance. The Chief Compliance Officer shall oversee the design, implementation and performance of a periodic review process through which compliance with this Code and the policies and procedures of WASO shall be thoroughly assessed.

1.16    WASO’s employees are not expected to be experts in the law. Nonetheless, its employees are expected to report to the Chief Compliance Officer, or his or her deputy, the activities about which they have knowledge that a reasonable person would question as a potential violation of this Code or applicable law. The Chief Compliance Officer, or his or her deputy, shall determine the merits of the situation and, if warranted, take appropriate action, as determined by WASO’s Whistleblower policy and procedures and applicable laws and regulations of the relevant jurisdiction. Any employee who, in good faith, makes such a report shall not be retaliated against by WASO or any other employees of WASO. The Chief Compliance Officer shall establish and maintain procedures for employees to report any illegal, unethical or inappropriate conduct, including, to the extent practical, through various telephonic and electronic means, on both an anonymous and a disclosed basis as according to its whistleblower policy. Failure by any WASO employee to comply with the provisions of this Code could result in disciplinary action being taken against such employee, including the dismissal of such employee.

2.0      Independence and Avoidance of Conflicts of Interest

A. General

2.1     The Rating Committee shall be independent in its rating decision-making and shall disregard any internal or external pressure or interference. The Rating Committee shall not consider any positive or negative potential effects of its rating decisions on issuers, investors, the WASO itself or other stakeholders. The directors/shareholders of the WASO shall not interfere in or influence over the activities and decisions of the Rating Committee.

2.2     WASO and its analysts shall use care and professional judgment to maintain both the substance and appearance of independence and objectivity. All employees shall comply with the provisions of the WASO Ratings Confidentiality, Conflicts of Interest and Securities Trading Policy. All employees must use special care to avoid even the appearance of a conflict. An appearance of a conflict arises when a reasonable investor or company could believe that other interests, responsibilities or duties of the employee give rise to bias even if the employee believes that he or she can make an unbiased decision.

2.3     The determination of a rating shall be influenced only by factors known to WASO from as reported sources and believed by WASO to be relevant to such rating.

2.4     The rating WASO assigns to a company shall not be affected by the existence of or potential for a business relationship between WASO (or its affiliates) and the company (or its affiliates) or any other party, or the non-existence of such a relationship. For avoidance of conflict of interest and to ensure independence at the time of credit rating activity, the Chief Compliance Officer shall take the prescribed undertaking/declaration as per SEC Code of Conduct from each member of the Board of Directors and officials related to rating activities.

2.5     WASO shall separate, operationally and legally, its rating business from any other WASO businesses, including consulting businesses, that may present a conflict of interest. WASO shall maintain and publish a formal Firewall Policy governing firewalls and operations between WASO and its non-rating affiliates to mitigate potential conflicts of interest. WASO shall ensure that ancillary business operations, which do not necessarily present conflicts of interest with WASO’s rating business, have in place procedures and mechanisms designed to minimize the likelihood that conflicts of interest will arise or to appropriately manage those conflicts that may arise.

Procedures and Policies

2.6     WASO shall adopt written internal procedures and mechanisms to (1) identify and (2) eliminate, or manage and disclose, as appropriate, any actual or potential conflicts of interest that may influence the opinions and analyses WASO makes or the judgment and analyses of the individuals WASO employs who have an influence on ratings decisions.

2.7     In case of any possible conflict of interest situation, the member of the rating committee or Analyst or employee concerned will disclose such conflict of interest and will not participate in any manner in formulating or arriving at a Credit Rating. Nevertheless, depending on the nature of the conflict and subject to the discretion of WASO Ratings’ senior management, the person may be asked to be a resource person to give information or opinions useful for the consideration of others, but such person will not participate in the voting process itself. WASO Ratings will disclose known actual and potential conflicts of interest. Such disclosures will be complete, timely, clear, concise, specific and prominent.

2.8     WASO Ratings receives compensation from Issuers to enable it to perform credible credit analysis. This compensation must not influence an Analyst’s credit opinions or other analytical processes.

a. Where applicable, WASO Ratings will disclose if it receives material compensation from rated entities that is unrelated to its rating services.
b. WASO Ratings will disclose if it receives 10% or more of its annual rating revenue from a single Issuer, originator, arranger, client or subscriber.
c. WASO Ratings will encourage structured finance Issuers and originators of structured finance products to publicly disclose all relevant information regarding these products, so that investors and other CRAs can conduct their own analysis independently of WASO Ratings.

2.9     In accordance with the WASO Ratings Confidentiality, Conflicts of Interest and Securities Trading Policy WASO’s employees shall not engage in any securities or derivatives trading presenting conflicts of interest with their involvement in WASO’s rating activities.

2.10    If a rated entity (for example, a government or central bank) has, or is simultaneously pursuing, affiliated oversight functions related to WASO shall use different employees to conduct its rating actions with respect to such entity than those employees involved in its oversight issues.

C. Analyst and Employee Independence

2.11    Reporting lines for WASO employees and their compensation arrangements shall be structured to eliminate or effectively manage actual and potential conflicts of interest.

a.       An analyst will not be compensated or evaluated on the basis of the amount of revenue that WASO derives from companies.
b.       WASO shall conduct formal and periodic reviews of its compensation policies and practices for its employees who participate in or who might otherwise have an effect on the rating process to ensure that these policies and practices do not compromise the objectivity of WASO’s rating process.

2.12    Employees who are directly involved in the rating process shall not initiate, or participate in, discussions regarding fees or payments with any entity they rate. Discussions on fees or payments will be carried out by WASO’s Client Relationship Management Unit.

2.13    In accordance with the WASO Ratings Confidentiality, Conflicts of Interest and Securities Trading Policy, no WASO employee shall participate in or otherwise influence the determination of WASO’s rating of any particular entity or obligation if the employee:

a.       Owns securities or derivatives of the rated entity, other than holdings in diversified collective investment schemes;
b.       Owns securities or derivatives of any affiliate of a rated entity, the ownership of which may cause or may be perceived as causing a conflict of interest, other than holdings in diversified collective investment schemes;
c.       Has had a recent employment or other significant business relationship with the rated entity that may cause or may be perceived as causing a conflict of interest;
d.       Has an immediate relation (i.e. a spouse, domestic partner, minor child, other dependent and/or relatives sharing his/her home) who currently works for the rated entity;or
e.       Has, or had, any other relationship with the rated entity or any affiliate thereof that may cause or may be perceived as causing a conflict of interest.

2.14    In accordance with the WASO Ratings Confidentiality, Conflicts of Interest and Securities Trading Policy, anyone involved in the rating process (or their spouse, domestic partner or minor children) shall not buy or sell or engage in any transaction in any security or derivative based on a security issued, guaranteed or otherwise supported by any entity within such employee’s responsibility, other than holdings in diversified collective investment schemes.

2.15    In accordance with the WASO Ratings Confidentiality, Conflicts of Interest and Securities Trading Policy , WASO employees are prohibited from soliciting money, gifts or favors from anyone with whom WASO does business and are prohibited from accepting gifts offered in the form of cash or any gifts exceeding a minimal monetary value.

2.16    In accordance with the WASO Ratings Confidentiality, Conflicts of Interest and Securities Trading Policy, any WASO employee who becomes involved in any personal relationship that creates the potential for any real or apparent conflict of interest (including, for example, any personal relationship with an employee of a rated entity or agent of such entity within his or her area of responsibility) shall, subject to applicable law, disclose such relationship to the appropriate manager or officer of WASO.

3.0      Responsibilities to the Investing Public and companies

A.        Transparency and Timeliness of Ratings Disclosure

3.1     WASO will announce to the public as soon as practicable its Credit Rating opinions and actions regarding the Issuers and Issues it rates or discontinue with a rating. WASO will not unduly delay disseminating any rating action. If WASO rates or updates a rating or discontinue with a rating of a publicly listed company or any instrument of such a company, it shall disseminate the information through a news release to the SEC and the stock exchanges within 1(one) hour of such decision.

3.2     WASO shall publish all Credit Ratings in such media and using such means as WASO determines are appropriate on a non-selective basis.

3.3     WASO shall ensure that ratings are clearly marked so that a user can determine when a rating was last updated. Each rating announcement shall also indicate the principal methodology or methodology version that was used in determining the rating and where that methodology can be found. Where the rating is based, to a significant extent, on more than one methodology or where a review of only the principal methodology might cause financial market professionals to overlook other important aspects of the rating, WASO shall indicate where the different methodologies and other important aspects, as the case may be, that were factored into the rating decision can be found.

3.4     Except for “private ratings”, and in line with WASO’s rating process, once an Issuer accepts and uses the Credit Rating assigned, WASO will make its Credit Rating (throughout the life of the issue) available to the public without cost. Such a Credit Rating will be disseminated via WASO’s public website and through transmission to the news media as well as via electronic or print subscription services. The public will be able to obtain a current Credit Rating for any Issuer or Issue without cost. Press releases of the Credit Rating and a brief explanation of the basis for the rating actions will remain on WASO’s public website for a minimum of three business days.

3.5     WASO shall base its rating analyses and rating decisions, which are WASO’s opinions, upon WASO’s established criteria, methodologies and ratings definitions, applied in a consistent manner. WASO’s criteria, methodologies and ratings definitions shall outline the factors that it considers during the rating and surveillance processes.

3.6     When issuing or revising a Credit Rating, WASO will explain in its press releases and reports the key elements underlying the Credit Rating. WASO may provide the Issuer with a draft copy of a press release and/or rating rationale that will accompany an assigned Credit Rating when it is disseminated to the public. The documents are provided solely for the purpose of allowing the Issuer to correct any factual errors and preventing any Confidential Information from being inadvertently disseminated. WASO shall retain full discretion to disseminate its press releases and/or rating rationales to the market in whatever form WASO, in its editorial judgment, determines to be the most appropriate.
3.7     As an independent Rating Agency with no financial inducement from the companies being rated, WASO will publish the Credit Rating without consideration or favor to any company being rated. WASO will however accept from the company concerned at its sole discretion, any publicly available corrections to the as reported data on which WASO based a rating. WASO always retains the right to publish the commentary at the most appropriate time and in whatever form it deems most appropriate in its editorial judgment.

3.8     In order to promote transparency and to enable the market to best judge the aggregate performance of its ratings, WASO, where possible, shall conduct periodic studies on the performance of WASO-rated companies, including current and historical default rates by rating category and rating transition analyses. Where feasible, this information shall include verifiable, quantifiable historical information about the performance of its ratings, organized and structured, and, where possible, standardized in such a way to assist financial market professionals in drawing performance comparisons between different rating agencies.

3.9     WASO is not initially interested to assign unsolicited ratings. However, WASO reserves the right, in its sole discretion, to issue unsolicited ratings in the future if WASO believes: (i) there is a meaningful credit market or investor interest served by the publication of such a rating; and (ii) it has sufficient information to support adequate analysis and, if applicable, ongoing surveillance. WASO Ratings will indicate if its Credit Ratings are unsolicited. Even in the case of an unsolicited rating, WASO Ratings will exert efforts to carry out credit assessments in the same rating process as for a solicited rating, by assessing sufficient information and/or interviewing Issuers.

3.10    WASO shall review, and update to the extent it deems appropriate, its criteria and methodologies on a regular basis. WASO shall publicly disclose any material modification to its methodologies and significant practices, procedures and processes. Where feasible and appropriate, WASO shall undertake to disclose planned material modifications prior to the effective dates of such modifications. WASO shall consider the various uses of ratings before modifying its methodologies, practices, procedures and processes.

B. Treatment of Confidential Information

3.11   WASO will adopt procedures and mechanisms to protect the Confidential Information shared with WASO by Issuers under the standard terms and conditions of the contract between WASO Ratings and the Issuers. Unless WASO has received permission from the Issuer, WASO and its employees will refrain from disclosing Confidential Information in press releases, through research conferences, conversations with investors, other Issuers, or any other person.

3.12    In spite of Clause 3.11, WASO will not be restricted from: (a) publishing any Credit Rating or other opinion regarding a particular Issuer or Issue that incorporates Confidential Information, without specifically disclosing it; (b) using third-party contractors or agents bound by appropriate confidentiality obligations to assist in any aspect of the rating process or related business activities; or (c) disclosing information as required by any applicable law, rule, or regulation, or at the request of any governmental agency or authority.

3.13    WASO Ratings will use Confidential Information only for purposes related to its rating activities. WASO Ratings may use Confidential Information for publishing ratings-related research and analytical reports and for modeling purposes, provided that the Confidential Information is not presented in a way that can be directly tied to the Issuer.

3.14    WASO Ratings’ employees will take all reasonable measures to protect all property and records belonging to or in possession of WASO Ratings from fraud, theft or misuse.

3.15    In accordance with WASO’s Personal Investment and Trading of Securities policy, its employees will be prohibited from engaging in transactions in securities upon receipt of Confidential Information concerning the Issuer of such securities until the end of the Blackout Period.

3.16    WASO Ratings’ employees will not disclose any non-public information about rating opinions or possible future rating actions of WASO Ratings, except to the Issuer or its designated agents.

3.17    WASO Ratings’ employees will not share Confidential Information entrusted to WASO Ratings with the employees of any affiliated entities, except to the extent that such employees are acting as agents of WASO Ratings with respect to the rating process, and are bound by appropriate confidentiality obligations. WASO Ratings’ employees will not share Confidential Information within WASO Ratings except on an “as needed” basis.
3.18    WASO Ratings’ employees will not use or share Confidential Information for the purpose of trading securities, or for any other purpose except the conduct of WASO Ratings’ business.

Disclosure of this Code and Communication with Market Participants

4.1     This Code is based on the provisions of SEC Code of Conduct Regarding the Activities of Credit Rating Agencies and the IOSCO Code of Conduct Fundamentals for Credit Rating Agencies. WASO will disclose on a timely basis any changes to this Code or to how this Code is implemented and enforced.

4.2     The Managing Director or Chief Executive Officer and Chief Compliance Officer shall be responsible for communicating with market participants and the public about any questions, concerns or complaints about WASO Ratings’ adherence with the Code of Conduct. The objective of this is to help ensure that WASO Ratings’ officers and management have adequate market intelligence when setting WASO Ratings’ policies.

    1. All market participants and the public are welcome to have a voice regarding WASO and its policies, including raising any questions, concerns or complaints they may have. Contact information is available on WASO’s free public website,                     www.wasocreditrating.com. Companies should note however that as the rating is based upon the data that they disclosed according to the law of the country in which they report, only factual publicly available data will be considered to revise a WASO Credit Rating.

 

Disclaimers

5.1     WASO does not intend to assume, and is not assuming, any responsibility or liability to any party arising out of, or with respect to, this Code. This Code is not intended to, and does not, form a part of any contract with anyone, and no one shall have any right (contractual or otherwise) to enforce any of this Code’s provisions, either directly or indirectly. WASO may amend this Code at its sole discretion, in any way WASO sees fit at any time.

5.2     Users of ratings should be aware that WASO’s ratings are opinions reflecting the ability of an entity or a securities issue to meet financial commitments such as interest, preferred dividends and repayment of principal, in accordance with their terms. Ratings are not themselves facts and therefore cannot be described as being “accurate” or “inaccurate”.

5.3     Credit ratings do not directly address any risk other than credit risk. In particular, ratings do not deal with the risk of loss due to changes in interest rates and other market considerations.

5.4     Ratings are based on information that was disclosed by the company itself as reported basis. WASO does not audit or verify the truth or accuracy of such information and has undertaken no obligation to so audit or verify such information or to perform any other kind of investigative diligence into the accuracy or completeness of such information. If any such information should turn out to contain misrepresentations or to be otherwise misleading, the rating associated with that information may not be appropriate and WASO assumes no responsibility for this risk. The assignment of a rating to any company or any security should not be viewed as a guarantee of the accuracy, completeness or timeliness of the information relied on in connection with the rating or the results obtained from the use of such information.

5.5     WASO does not have a fiduciary relationship with any company, subscriber or other individual. Nothing is intended to or should be construed as creating a fiduciary relationship between WASO and any company or between WASO and any user of its ratings.

5.6     Ratings do not constitute recommendations to buy, sell or hold any security nor do they comment on the adequacy of market price, the suitability of any security for a particular investor or the tax-exempt nature or the tax liability of any payments of or for any security.

5.7     Ratings may be changed, qualified, placed on Rating Watch or withdrawn as a result of changes in, additions to, accuracy of, unavailability of or inadequacy of information or for any reason WASO deems sufficient.

5.8     WASO does not provide to any party any financial advice or legal, auditing, accounting, appraisal, valuation or actuarial services. A rating should not be viewed as a replacement for such advice or services.

5.9     The assignment of a rating by WASO shall not constitute consent by WASO to use its name as an expert in connection with any registration statement, offering document or other filings under any relevant securities laws.